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Jewelers Vigilance Committee releases updated guidance on Russian diamond ban and sanctions

Jewelers Vigilance Committee On Friday, March 11, President Biden announced a ban on the importation of certain Russian Federation products, including diamonds. This action was taken in response to the continued aggression of the Russian Federation against Ukraine. Since that announcement, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued additional FAQ guidance on the importation ban that clarifies what U.S. jewelry businesses must do going forward.

The ban on importation of diamonds from Russia is limited to the U.S. harmonized tariff codes 7102.31.00 and 7102.39.00, which are the tariff codes for “unworked or simply sawn, cleaved or bruted” diamonds, or what the trade generally refers to as “rough diamonds”.  Under U.S. Customs regulations and interpretation based on the OFAC FAQs, rough diamonds from the Russian Federation which are cut and polished in a second country are “substantially transformed” by the cutting and polishing, becoming a product of that second country. Under this guidance, rough diamonds imported from Russia into a country that has not implemented sanctions or a ban and then cut and polished are currently legal to import into the U.S. as they will fall under a separate harmonized tariff code.

It is certainly possible that countries that have traditionally been cutting centers for rough diamonds may also implement a ban on importing Russian diamonds, further limiting their pathways into the U.S.  In addition, the U.S. government could decide to further limit imports of those products which originate in Russia and are substantially transformed elsewhere, or add additional harmonized tariff codes to the importation ban. JVC recommends that members proceed with extreme caution regarding diamond imports, as the risk of additional future limitations is high.

The full FAQ from OFAC is available here.

For those looking for additional guidance, check out the following upcoming webinars from JVC’s Law Firm Finder partner Dentons.

Dentons recognizes the breadth of issues you are faced with, which is why their global teams, together with Dentons Global Advisors an independent multidisciplinary business consultancy that has significant commercial, diplomatic, and non-legal expertise to address the rapidly evolving crisis in Ukraine and shifting geopolitics across the world, have joined together to provide you with:

  • A global hub on Dentons.com containing all the insights and latest news available from Dentons across multiple markets – on a range of issues including sanctions, immigration and employment issues, financing, and force majeure
  • The recording of last week’s webinar on sanctions
  • A global webinar program – which you can register to view here – that you are welcome to share with other colleagues in your organization or within your network. This program reflects the range of issues clients are grappling with at the moment. The webinars will all take place at 10am ET and will be recorded and posted on Dentons’ hub, should you be unable to attend ‘live’.

The program includes:

  •  Sanctions latest: global insights from sanctions experts
     Monday, March 14, 2022
  • Liquidity and restructuring options for businesses impacted by sanctions
     Tuesday, March 15, 2022
  • Managing employees through the crisis: latest insights from across Europe, Canada, UK and US
     Learn about the legal challenges being faced relocating employees, amending contracts, and similar
    Thursday, March 17, 2022
  • Supply chain and trade issues (not sanctions): case studies and practical insights
     Monday, March 21, 2022
  • Presenting Q1 earnings to the market and other stakeholders
     Dentons’ NYC-based SEC lawyers and Dentons Global Advisors shareholder communications professionals will discuss how companies are gearing up to present Q1 earnings to the market in this challenging time and will stress test many investor relations narratives.
    Tuesday, March 22, 2022
  • Consumer goods and retail: stock-take on current issues and solutions
     Wednesday, March 23, 2022

The post Jewelers Vigilance Committee releases updated guidance on Russian diamond ban and sanctions appeared first on Southern Jewelry News.



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