RAPAPORT TRADE ALERT: US Imports of Diamonds and Diamond Jewelry Now Require New Certification Statements from Importers

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued new “grandfather” exclusion guidelines.

General License No. 103 allows for the importation of diamond jewelry and unsorted diamonds of either Russian or unknown origin purchased before, and physically located outside Russia prior to, the implementation of sanctions on March 1, 2024.

General License No. 104 applies the same rules to nonindustrial loose rough and polished diamonds of 1 carat or more. Diamonds of Russian or unknown origin between 0.50 and 1 carat may be imported into the US if they were both purchased and located outside Russia before September 1.

The following declaration must accompany any of these goods upon importation in order to demonstrate compliance with sanctions.

For nonindustrial diamonds of 1 carat and above:

“I certify that the nonindustrial 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.”

Or:

“I certify that the nonindustrial diamonds in this shipment qualify for General License 104, because the diamonds were physically located outside of the Russian Federation before March 1, 2024, and were not exported or reexported from the Russian Federation since March 1, 2024.”

For nonindustrial diamonds of 0.50 carats and above:

“I certify that the nonindustrial 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.”

Or:

“I certify that the nonindustrial diamonds in this shipment qualify for General License 104, because the diamonds were physically located outside of the Russian Federation before

September 1, 2024, and were not exported or reexported from the Russian Federation since September 1, 2024.”

For diamond jewelry and unsorted diamonds:

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

Or:

“I certify that the diamond jewelry in this shipment qualifies for General License 103 and that it was physically located outside of the Russian Federation prior to March 1, 2024, and not exported or reexported from the Russian Federation on or after March 1, 2024.”

Image: Rough diamonds. (Alrosa)