The sanctions apply to a processed diamond that is defined in regulation 46Z16Q of Chapter 4JC and relates to the following HS Codes

710210   Unsorted Diamonds

710239   Non-Industrial Diamonds, other than unworked or simply sawn, cleaved or bruted

ex 7102 31   Non-Industrial Diamonds, simply sawn, cleaved or bruted   

In addition, the processed diamond must meet the following criteria

• It originates in Russia
• It has been altered, transformed in any way, or subjected to any other type of operation or process in a third country (A third country is any country that is not the UK, Isle of Man or Russia)
• Is equal to or larger than 1 carat (0.2 grams, or equivalent) from 1^st March 2024, or is equal to or larger than 0.5 carats (0.1 grams, or equivalent) from 1^st September 2024

The update provides example scenarios relating to the applicability of the sanctions.

In line with other product-specific sanctions, such as the Iron and Steel restrictions, guidance is provided on the importance of demonstrating compliance.

Documentary evidence could include the individual weight of the diamond if a stone is larger than or equal to 1 carat (0.2 grams, or equivalent) from 1^st March 2024

If there are diamonds larger than or equal to 1 carat (or equivalent) from 1st March, then other evidence requested to be provided through documentation could include: 

• The country of origin of the diamonds processed in the third country (or third countries) 
• The date that the diamonds left their country of origin 
• The country(ies) and facility(ies) where processing has taken place 

The update provides examples of evidence that could be provided.

• The original Kimberley Process Certificate (KPC) (single or mixed origin) issued when shipped from the diamond’s origin country
• An invoice
• Certificate of Origin, issued by the Chamber of Commerce
• Bill of Lading
• A diamond origin report or other book or document relating to the goods   

This is not the limit of the examples that could be used. However, the notice confirms that evidence must be verifiable. 

Information regarding compliance with the prohibitions of stones of Russian origin processed in third countries larger than or equal to 0.5 carats (0.1 grams or equivalent), taking effect from 1^st September 2024, will follow in due course.

A license may apply in specific circumstances to permit the import into the UK of particular relevant third-country processed diamonds outside Russia before 1^st March, and then processed outside of Russia before being imported into the United Kingdom. Also, beginning with March 1^st for diamonds that have not been located in Russia at any time,   

In addition to the import of goods within this criteria, the license permits the provision of certain services and actions relating to their import. It may also be used in cases where a trader is unaware of the diamonds' origin but can prove that they have been outside Russia since 1^st March 2024.         

The General Trade License will be reviewed, and the Secretary of State has the power to vary, revoke or suspend this license at any time.

Regulation 76 of the Russia Regulation confirms the requirement for record keeping of each act carried out under the authority of a General Trade License.   

Traders wishing to use the license must email records.importlicences@businessandtrade.gov.uk with their company name, EORI, and the address where the records may be inspected no later than 30 days after the first act under the authority of this licence.  

 We recommend sending the email with a ‘read’ receipt confirmation, which can be kept on file.

The Customs Declaration must reference Document Code 9042 and Licence Number GBSAN0002 upon import. Declaration by Conduct or an Oral Declaration cannot be used to import controlled goods.

 https://www.gov.uk/government/publications/notice-to-importers-2953-russia-import-sanctions

https://www.gov.uk/government/publications/notice-to-importers-2953-russia-import-sanctions/guidance-on-third-country-processed-russian-diamonds-measures

If you are interested in exploring this topic further, you might find it worthwhile to consider the training courses and live clinics offered by Strong & Herd LLP: