UK on third country processed Russian diamonds!

Sep 09, 2024

Diamond RussiaThis section explains the scope of the measures related to relevant Russian diamonds processed in third countries only, and the evidence traders need to provide to demonstrate compliance. It does not discuss other prohibitions (including other measures related to Russian diamonds). See the statutory guidance on Russia sanctions for this.

In response to Russia’s invasion of Ukraine, the UK government has imposed a range of sanctions measures, including trade, financial, transport and other sanctions, under The Russia (Sanctions) (EU Exit) Regulations 2019 (the Russia Regulations). The sanctions are aimed at encouraging Russia to cease actions which destabilise Ukraine, or undermine or threaten the territorial integrity, sovereignty, or independence of Ukraine.

The Russia (Sanctions (EU Exit) (Amendment) Regulations 2024 (the 2024 Regulations) amended the Russia Regulations and introduced a prohibition on the import of certain Russian diamonds processed in a third country or multiple third countries. This built on measures banning the direct import of Russian origin diamonds and diamond jewellery, which came into effect on 1 January 2024.

The ban on third country processed Russian diamonds is set out in regulations 46Z16Q and 46Z16R, inserted as part of Chapter 4JC into Part 5 of the Russia Regulations by the 2024 Regulations. Third country processing can be a means of concealing the Russian origin of diamonds, and this measure is targeted at reducing circumvention of sanctions on Russian diamonds.

The prohibition on the import of Russian diamonds processed in a third country was introduced, and came into effect, on 1 March 2024 for relevant diamonds equal to or larger than 1 carat in weight (0.2 grams or equivalent). The prohibition applies to relevant diamonds equal to or larger than 0.5 carats (0.1 grams or equivalent) from 1 September 2024.

Note: Earlier, the United States has authorized the import of certain Russian diamonds until September 1, 2025, according to the updated general license issued by the US Department of the Treasury.

In particular, the United States authorizes the import of Russian diamonds until September 1, 2025, “provided that the diamonds were physically located outside of the Russian Federation before, and were not exported or re-exported from the Russian Federation since: (1) March 1, 2024 for non-industrial diamonds with a weight of 1.0 carat or greater; or (2) September 1, 2024 for non-industrial diamonds with a weight of 0.5 carats or greater.”

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