JVC Russian Diamond Sanctions FAQ

Why is March 1, 2024 significant?

On March 1, 2024, the G7 government-coordinated restrictions began on rough and polished diamonds. All G7 governments (United States of America, Canada, France, Germany, Italy, Japan, the United Kingdom and the European Union) have agreed to restrict Russian-origin diamonds of certain sizes from entering the G7, even if they are cut & polished (“substantially transformed”) in a third country before import. The purpose of the sanctions is to prevent the Russian Federation from continuing to use the financial systems of the G7 to fund its unjustified war in Ukraine. Alrosa, the state diamond mining corporation which is partially owned by the government of the Russian Federation, uses the country’s diamonds to raise revenue that directly contributes to the war in Ukraine.

In the U.S., the restriction was implemented by an Executive Order on December 22, 2023 with subsequent determinations by the Office of Foreign Assets Control and guidance from Customs & Border Protection.

What is actually going into effect on March 1?

Starting March 1, companies importing rough or polished diamonds 1 carat or higher must demonstrate that the diamonds were not mined, extracted, or polished in the Russian Federation.

The U.S. government has given required self-certification language for shipments containing diamonds and diamond jewelry in the Customs guidance communication excerpted below. All diamond imports containing rough or polished diamonds 1.0 carat or higher must file this declaration. CBP is empowered to check for this information upon import into the U.S. and will be inspecting packages of diamonds at the point of importation into the U.S. as usual.

The self-certification for U.S. import must meet the following criteria:

  1. Be provided on official company letterhead in PDF format.
  2. Contain the statement:

For non-industrial diamonds with a weight of 1.0 carat or greater, effective March 1, 2024:

“I certify that the non-industrial diamonds in this shipment were not mined, extracted, produced, or manufactured wholly or in part in the Russian Federation, notwithstanding whether such diamonds have been substantially transformed into other products outside of the Russian Federation.”

For diamond jewelry and unsorted diamonds, effective March 1, 2024:

“I certify that the diamond jewelry and unsorted diamonds in this shipment are not of Russian Federation origin or were not exported from the Russian Federation.”

Statements regarding origin made in these declarations should be truthful; falsifying information at Customs is a federal offense. Importers can further demonstrate that their diamonds are not of Russian origin using invoice statements, chain of custody demonstration, blockchain tracking, and more.

March 1 marks the beginning of the “sunrise period” requiring self-attestations that will terminate by September 1 with the implementation of traceability technology requirements.

What kind of information do I need to keep about diamond shipments coming into the U.S.?

The following information must be available:

  • Mining origin
  • Names of buyer and seller
  • HS codes and description
  • Number of parcels in a shipment
  • Weight in carat of the diamond(s) if at least one diamond (if multiple diamonds are shipped in a parcel) is of 1.0 carat or above
  • Value of the diamonds
  • Place of importation, exportation, and route of transportation as applicable depending on the respective G7 country and lifecycle of the diamond(s) prior to importation in a G7 jurisdiction.

What about the “documentary evidence” mentioned by the G7?

Businesses should have available documentation that shows proof the diamonds they are shipping did not originate from the Russian Federation. The types of documents containing the above information required for submission with entry may vary depending upon the requirements of each individual G7 country.

For shipments into the U.S., importers do not need to submit this information directly to U.S. customs, but must have it available in case of further inspection. Examples of documentation include the following non-exhaustive list:

For rough natural diamonds:

  • Kimberley Process certificates with single origin (DeBeers DTC mixed origin allowed) for diamonds at or above 1.0 carat
  • Kimberley Process certificates with mixed origin accompanied by documentary evidence, proving that no diamonds at or above 1.0 carat in the shipment were mined in Russia

Additional documents proving the above can include:

  • Customs declaration form
  • Invoice
  • Packing list
  • Transport documentation, e.g. waybill document
  • Evidence from traceability systems

For polished natural diamonds:

  • Signed attestation or supplier declaration confirming that none of the diamonds at or above 1.0 carat in the shipment were mined in Russia.

Additional documents proving the above can include:

  • Customs declaration form
  • Invoice
  • Packing list
  • Transport documentation, e.g. waybill document
  • Laboratory grading report
  • Evidence from traceability systems

Are the U.S. restrictions the same as those in other countries?

No. For example, in the E.U., more documentary evidence of where the diamonds do originate is required. Businesses importing diamonds into other G7 countries should be sure to check with relevant customs authorities.

What should I be doing to ensure I am compliant?

JVC has been providing its members with information and guidance on this topic since February 2022 when Russia first invaded Ukraine. U.S. businesses should be working directly with their suppliers to ensure the suppliers are capable of segregating their goods and providing verifiable confirmation that the goods purchased are not of Russian origin. The fundamentals of this can be built on top of a business’s existing AML program and KYC / vendor identification programs. While you need to receive ongoing confirmation about goods you are purchasing, establishing good vendor policies and procedures is paramount to ensuring you are receiving goods with verifiable origin information.


Source: Jewelers Vigilance Committee