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MFAT has now released detailed guidance on Compliance, Due Diligence and Understanding Evasion Risk. While to date the financial services sector and AML reporting entities have done the heavy lifting, this is important for all sectors and trading businesses.

Even 2 years on from NZ introducing its first autonomous sanctions law, there seems a degree of business confusion out there. Many firms have assimilated it to an AML compliance programme, without properly noting and adjusting for more binary and absolute restrictions that sanctions compliance brings.

This guidance compiles good info about what due diligence may be useful to avoid breach of Russia sanctions, endorsing a risk-based approach but mindful of the differences in legal frameworks. It includes helpful worked examples and diagrams to illustrate the difficult area of spotting associates or relatives of a sanctioned person, who may be in an innocuous third-country or positioned so as to obscure the real connection/control aspects.

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