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Understanding Sanctions

Sanctions are a penalty used by governments to coerce another to conform to an international agreement or norms of conduct, typically in the form of restrictions on trade. Within the jewelry industry, sanctions can be levied on companies, people, products, or entire countries to exert influence over other governments and block institutions from financing bad actors.

Evasion of sanctions is a crime and a serious threat to national security and foreign relations. Violations of sanctions are punishable with significant civil monetary fines (often in the millions of dollars) and criminal prison sentences. Businesses are strongly encouraged to report any potentially unlawful transactions and seek assistance by calling the OFAC hotline at 1-800-540-6322 or, in the case of money laundering concerns, filing a Suspicious Activity Report via

Each individual business must determine how to ensure they are not sourcing goods that violate sanctions or put themselves at risk for derivative or secondary sanctions, or other financial crimes. Businesses looking for a place to start can begin with their AML program and make sure they have strong policies in place to know where their goods are coming from. More information on AML and JVC’s AML services can be found here.

Russia-Related FAQs

Today, the G7 government-coordinated restrictions begin 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.

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. OFAC has provided some basic information in FAQs here, here, and here, including the specific harmonized tariff codes affected.

The U.S. government has given required self-certification language for shipments containing diamonds and diamond jewelry in the Customs guidance communication seen here and 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.

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.

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

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.

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.

The G7 technical committee is working on a traceability mechanism for diamonds that will be tested between March 1 and September 1, the “sunrise period”. Contemplated in this system is the requirement for rough diamonds to enter the G7 via specific “nodes” for uploading onto a blockchain to ensure source verification. One node is planned for Antwerp, Belgium; additional nodes may be added (for example, a registration point in Canada directly for Canadian diamonds, which are already in the G7.) We don’t yet fully know what this looks like or how expeditiously goods will move from source countries to the node for registration to cutting factories. 

The G7 has also stated that the restrictions will apply to finished jewelry, laboratory-grown diamonds, and watches starting on September 1. We don’t yet know how this restriction will be structured nor how it will be enforced.

JVC continues to work alongside the jewelry industry and with the U.S. government to clarify the requirements and provide input regarding what is achievable in the market. The U.S. government officials working on these restrictions have been incredibly open to input from the trade, and we will continue to facilitate these discussions on an ongoing basis.

JVC is tracking this information and will continue to distill it for our members. The solutions designated by the G7 are being designed to be multi-country efforts. As changes are announced, we’ll make sure you know about them.

They’re not.  In the various executive orders issued on the topic, diamonds, gold, and jewelry have been lumped together with seafood and alcohol products. Seafood products, it turns out, have many of the same concerns we do; Russian pollock and other fishes were shipped to China and turned into “substantially transformed” fish sticks and other products that were being imported into the U.S. This is now prohibited by the same executive order that prohibits substantially transformed diamonds from entering the U.S. The U.S. is looking at every sector in an attempt to close off funding for the war.

All businesses in the jewelry trade need to be asking suppliers questions, evaluating those responses, keeping records of those responses, and asking questions about the technology their suppliers have/are acquiring.

Beginning on September 1, businesses importing 0.5 carat or higher diamonds, laboratory-grown diamonds, or diamond jewelry and watches containing diamonds 0.5 carats or higher will be required to implement traceability systems to ensure the diamonds did not originate in the Russian Federation. This may include the registration of rough diamonds at the diamond office in Antwerp, Belgium, before cutting and polishing. Our understanding is that multiple traceability solutions will be allowed, and that this portion of the restrictions is still in development. The traceability mechanism will be tested during the “sunrise period” between March 1 and September 1. We will continue to share information as we receive it.

Retailers should be speaking directly with their suppliers about how they plan to implement the traceability mechanisms of the G7 restrictions. Retailers should prepare staff to speak about the sizes of diamonds that are restricted from entry into the U.S. and the fact that this is being done so that diamond proceeds do not finance war.

Businesses should follow the steps for a red flag transaction as outlined in their AML programs. If you are a JVC member, please contact us so that we can help you evaluate the transaction. Potential violations can be reported to OFAC using their hotline at 1-800-540-6322. You may also wish to engage outside counsel.

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Legal and Business Resources

JVC’s focus on jewelry-specific legal issues include our specialized expertise on sanctions for the United States. Below are resources to help businesses navigate some of these restrictions on daily operations and transactions. Let us know how else we can help. We are here at and @jvclegal on social platforms.

Still have questions? If you are a JVC member, you can schedule a free 15-minute conversation with a person from our legal team!

Schedule Your Member Chat Here

  • US Customs and Border Protection’s guidance “Taking Additional Steps with Respect to the Russian Federation’s Harmful Activities” can be read here.
  • European Commission FAQ on G7 Diamond Restrictions can be read here.
  • Canada’s Minister of Foreign Affairs announced that Canada, alongside G7 partners, is imposing additional import restrictions on Russian diamonds under the Special Economic Measures (Russia) regulations. More can be read on this here.
  • RJC’s Guidance on the G7 Diamond Sanctions can be read and downloaded here.
  • On December 22nd, 2023, the Biden-Harris administration announced a new Executive Order taking additional steps with respect to the Russian Federation’s harmful activities. Full text here.
  • US Embassy’s G7 factsheet can be read here.
  • EU’s FAQ PDF of Russia sanctions can be read here.
  • JVC articles on Responsible Sourcing, including sanctions, can be read here.
  • On Thursday, February 11, 2021, the United States announced new sanctions on the country of Myanmar (Burma), issued in response to a military-led coup of the democratically elected government of that country.
  • The full list of persons and entities affected can be accessed here.
    • These entities cover much of Myanmar’s existing colored gemstone trade and are directly connected to the military leaders who undertook the coup.
  • JVC recommends that US businesses be familiar with and implement the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
    • The Guidance aims to help companies respect human rights, observe applicable rules of international humanitarian law in situations of armed conflict, avoid contributing conflict and cultivate transparent mineral supply chains and sustainable corporate engagement in the mineral sector.
    • Business can look to the RJC Code of Practices for more guidance on how to this applies in the context of the jewelry industry.
  • More information on why these sanctions were implemented can be read on the Biden-Harris administration fact sheet here.
  • US Department of Treasury’s press release from March 4th, 2024 on Zimbabwe sanctions can be read here.

The Clean Diamond Trade Act was implemented on July 29, 2003. The act requires that rough diamonds imported or exported from the United States be controlled through the Kimberley Process (USKPA). Rough diamonds may only be legally imported and exported from the U.S. via a USKPA authorized licensee. The goal of the USKPA is to restrict the trade of rough diamonds known as “conflict diamonds.”

Conflict diamonds are rough diamonds used by rebel movements or their allies to finance conflict aimed at undermining legitimate governments.

More information on the USKPA and to become an authorized licensee can be found here.

The United States government restricts involvement with certain foreign countries, persons and entities pursuant to several sanction programs. The Office of Financial Assets Control (OFAC), part of the U.S. Treasury Department, maintains lists of countries and entities that are subject to these sanctions.

It is very important that you check these lists and that you do not enter into prohibited business transactions with the countries, individuals or entities cited:

  • The Specially Designated Nationals List is a list of individuals and entities controlled by targeted countries, or designated under programs that are not country-specific. In general, no U.S. person may engage in any activity with anyone on the list. To access this list, go to: and click on “complete specially designated nationals list.” The alphabetical list is available in pdf format and is word searchable from the toolbar.
  • List of Sanctions Programs – OFAC administers several embargoes maintained by the U.S. against other countries. Exports to these countries or other business dealings may be prohibited. To access a list of these sanction programs, go to:

It is important that businesses become familiar with these lists, and with the sanctions programs administered by OFAC. While jewelry companies are not required by the U.S. Patriot Act to review the OFAC lists, a company will be subject to penalty if it engages in a prohibited transaction with a listed country, person or entity. Many businesses check the lists on a periodic basis as part of their anti-money laundering program. For more information about sanctions programs generally, visit the U.S. treasury resource center webpage at:


Almost all jewelry businesses in the United States must comply with Anti-Money Laundering laws and regulations. This includes foreign-based businesses who have a presence in the US. This set of laws is sometimes referred to as “AML”, “PATRIOT Act”, or “KYC/Know Your Customer” rules.

JVC recommends building extra levels of sanctions compliance on top of your functioning AML program.

More information on AML services JVC offers can be found here.

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