Guidance for the trade
Notes prepared by the London Diamond Bourse on the rules that affect how our members buy, sell, import and export.
These notes are guidance, not legal advice. Sanctions and customs rules change, and only the published government guidance is authoritative.
What is covered
Russian diamonds and the G7 measures
What the third-country processing prohibition requires, which stones are caught, the evidence you must hold, and the General Trade Licence route.
Diamond terminology
What to call a diamond, a synthetic, an imitation and a treated stone, on every invoice, label and listing. Seven rules and the terms the Bourse will and will not accept.
Anti-money laundering and KYC
Which regime applies to you, the checks to make before you trade, what a High Value Dealer must register and do, the red flags, and how to report a suspicion.
Russian diamonds and the G7 measures
Importing polished diamonds into the United Kingdom under the third-country processing prohibition.
Section 01What the measures prohibit
The United Kingdom prohibits the import of non-industrial natural diamonds that were mined, extracted, produced or manufactured — wholly or in part — in Russia, even where the stone was cut or polished in another country afterwards. Processing in a third country does not remove the restriction.
Notice to importers 2953: Guidance on third country processed Russian diamonds measures. Published 1 March 2024, last updated 12 June 2026.
Section 02Which stones are caught
The prohibition came in over two stages, by weight:
- From 1 March 2024 — diamonds of 1.00 carat (0.2 g) and above
- From 1 September 2024 — diamonds of 0.50 carats (0.1 g) and above
Section 03The evidence you need to hold
You are expected to be able to show where the stones came from. The government names the documents it will look for.
Acceptable evidence includes the original Kimberley Process Certificate issued when the diamond was shipped from its country of origin, an invoice, a certificate of origin issued by a chamber of commerce, or a bill of lading. A supplier attestation may also be acceptable.
“I hereby declare that the non-industrial, natural diamonds in this shipment were not mined, extracted, produced, or manufactured wholly or in part in the Russian Federation.”
Section 04Suggested declaration
The London Diamond Bourse suggests the following declaration is included with your shipment, on a separate sheet attached to the invoice by the vendor.
The diamonds herein, HS code 7102 3900, are not subject to the restrictions of Regulation EU 833/2014 and the Russia (Sanctions) (EU Exit) Regulations 2019 (SI 2019/855). All diamonds are under 0.50 carats.
This shipment contains polished diamonds of 0.50 carats or greater. On behalf of [COMPANY OR INDIVIDUAL NAME — vendor], I hereby attest that this shipment does not contain any diamonds that originate in Russia or are from any person in Russia, including being mined, processed or produced in Russia. I confirm that the contents of this attestation are accurate and compliant with Regulation EU 833/2014 and the Russia (Sanctions) (EU Exit) Regulations 2019 (SI 2019/855).
Section 05Grandfathered diamonds
Diamonds that were already outside Russia before 1 March 2024 (1.00 carat and above) and 1 September 2024 (0.50 carats and above) are considered grandfathered diamonds, and are not subject to the sanctions. The government introduced a general trade licence to cover these goods.
Licence GBSAN0002, used with customs declaration code 9042. You do not apply for it. You do have a legal duty to notify the Secretary of State within 30 days of first acting under it, giving your name or organisation name, your EORI number and the address where the register may be inspected: records.importlicences@businessandtrade.gov.uk. Notify from your own registered address, not the Bourse’s. Read the licence.
This shipment is made using GB licence number GBSAN0002, in compliance with the Russia (Sanctions) (EU Exit) Regulations 2019 (SI 2019/855). These diamonds were outside the Russian Federation as of 1 September 2024.
Section 06Keeping records
As the recipient of a shipment, keep a record of the declarations you were given, the method of transport and all the relevant customs documents. Should you be asked later to show that reasonable steps were taken, this file can be produced in support.
The Department for Business and Trade cannot guarantee that any particular form of words will satisfy HMRC. Asked directly, the Department told the Bourse: “I’m afraid we are not able to provide guarantees on what will or will not be accepted at the border. I can, however, refer you back to the guidance, which states that a supplier attestation of compliance with this sanction may be acceptable, and to the other types of information and documentation it signposts.”
Section 07Exporting
When exporting, ask your logistics company to supply the documents required by the destination country. Requirements differ across the G7 and are not covered by the UK guidance above.
Diamond terminology
What to call a diamond, a synthetic, an imitation and a treated stone — on every invoice, label and listing.
A “diamond” is always natural. For anything grown in a laboratory or factory, the LDB’s preferred term is “synthetic diamond”.
Invoice, memo, parcel label, price list, catalogue, valuation, website, listing and social media post.
Section 01The seven rules
- “Diamond” on its own means natural.“Natural diamond” is fine where you need the distinction.
- Prefer “synthetic diamond” for synthetics.Qualifier immediately before “diamond”, in the same font, size and prominence, every time — not only in the small print.
- Never call a synthetic real, genuine or natural.Real, genuine, precious, authentic, natural and mined describe natural stones only.
- Name the material for imitations.“Imitation diamond”, “diamond simulant”, or the material itself — cubic zirconia, moissanite, YAG. Never a diamond of any kind.
- Disclose and name treatments.“Treated diamond”, followed by the treatment: HPHT colour treated, irradiated, laser-drilled, fracture-filled, coated.
- Keep goods separate.Separate lines, parcels and storage for natural and synthetic. Unscreened goods must not be described as natural.
- Growth method is extra, never instead.Write “synthetic diamond (CVD-grown)”, not “CVD diamond” or “HPHT diamond”.
Section 02What the words mean
| Diamond | A mineral created by nature. |
|---|---|
| Synthetic diamond | An artificial product with essentially the same composition, properties and structure as diamond, whatever the growth method. |
| Imitation or simulant | Looks like diamond without its composition, properties or structure — cubic zirconia, synthetic moissanite, glass. |
| Treated diamond | A diamond whose appearance has been altered by any process other than cutting and polishing. |
Section 03Terms at a glance
| Diamond | AcceptedNatural diamonds only |
| Natural diamond | AcceptedWhere the distinction from synthetics is needed |
| Synthetic diamond | PreferredLDB, WFDB & CIBJO best practice |
| Laboratory-grown, laboratory-created diamond | Not recommended |
| Lab-grown, lab-created, LGD | Not recommended |
| Man-made, created, grown, engineered, above-ground | Not recommended |
| Cultured, cultivated diamond | Not acceptableRefers only to organics, such as pearls |
| Eco, sustainable, ethical, conflict-free | Not acceptableAs a product description for a synthetic |
| Brand or trade name alone | Not acceptableFollow it with “synthetic diamond” |
| CVD diamond, HPHT diamond | Not acceptableUse “synthetic diamond (CVD-grown)” |
| Imitation diamond, diamond simulant | AcceptedFor simulants |
| Treated diamond | AcceptedName the treatment |
| Natural treated, treated natural diamond | Not acceptableUse “treated diamond” |
Goods received as “laboratory-grown” should be described as “synthetic diamond” on your own invoices and labels when you re-sell them.
Section 04Who this applies to
All LDB members, their employees, and anyone trading on the Bourse floor under a member’s introduction.
“Must” and “not acceptable” above reflect fair-description requirements under ISO 18323 and UK consumer protection law. The “synthetic” qualifier itself is LDB recommended best practice.
ISO 18323:2015 — Jewellery: consumer confidence in the diamond industry
CIBJO Diamond Blue Book
NAJ Code of Practice: Diamond Terminology Guideline, v2 (2023)
Anti-money laundering and KYC
What the law requires of a diamond and jewellery business, what it requires of you personally, and what to do when something does not look right.
Cash of £10,000 or more, in one payment or linked ones, makes you a High Value Dealer. Register with HMRC first.
Screen against UK sanctions, never handle criminal property, and know who you trade with — however they pay.
Section 01Which regime applies to you
| MLR 2017: High Value DealerCash of £10,000 or more, single or linked — including cash paid into your bank, or to a third party for you. | Register with HMRC before trading. Full AML programme. |
| MLR 2017: Art Market ParticipantWorks of art at £10,000 or more, by any payment method. | Register with HMRC. Customer due diligence on buyers and sellers. |
| POCA 2002Everyone. | Never deal in criminal property. Report suspicion to the NCA. |
| UK sanctions (SAMLA 2018)Everyone. | No dealings with designated persons or prohibited goods. Report breaches to OFSI. |
From 30 June 2026 the threshold is £10,000, previously €10,000. Any policy still written in euros, or still referring to the old £7,000 bank buffer, needs updating.
Section 02KYC for every counterparty
Before you trade, for every counterparty, whatever the payment method.
- Identify the customer.Individuals: name, address and date of birth, against photo ID and proof of address. Companies: name, number, address, directors and owners above 25 per cent, through Companies House or the overseas equivalent.
- Understand the business.Record their trade, their expected volumes and the purpose of the relationship.
- Screen.Customer, directors and beneficial owners against the UK Sanctions List, plus PEP checks. Record the result and the date.
- Assess the risk.Low, medium or high, with the reason recorded.
- Apply enhanced due diligence where the risk is high.PEPs and their associates, FATF “call for action” countries, unusually complex or large deals, and any red flag. Needs senior approval, source of funds and wealth, and closer monitoring.
- Monitor.Refresh KYC every two years for low risk, annually for high risk, or at once if something changes.
- Keep records for five yearsfrom the end of the relationship, or from the one-off transaction.
A politically exposed person is not a reason to refuse business. Record the checks and the decision. Domestic PEPs are lower risk than foreign ones, unless other factors apply.
Section 03If you are a High Value Dealer
- Register with HMRC first.Allow 45 days. Each entity registers separately, there is an annual fee, and changes must be reported.
- Business-wide risk assessment.Customers, countries, goods, channels and payment methods.
- Appoint a responsible officer and an MLRO.Tell HMRC who they are.
- Written policies and controls.Customer due diligence, risk, monitoring, reporting, records and communication.
- Screen and train staff.Record attendance and refresh it regularly.
- Audit independently.For smaller firms, at least an annual check.
Have a written policy refusing cash of £10,000 or more, tell staff and customers, and log smaller cash payments — so that linked payments and “smurfing”, splitting cash to stay under the limit, show up.
Section 04Red flags in the diamond trade
Stop and check.
- Payment from, or refund to, a third party or an unconnected country.
- Split invoices or instalments to stay under £10,000. Cash, cryptoassets or gold as payment.
- Prices well above or below market with no commercial reason.
- Rough without a valid Kimberley Process certificate, or from a country with no known production.
- Missing or altered System of Warranties statements, or vague origin on polished goods.
- Any link to Russian production or to Russian-connected companies.
- Memo goods never returned or paid for. Circular trades between the same parties.
- Reluctance to give ID or ownership details. Complex structures with no clear purpose.
Section 05Reporting a suspicion
No transaction is too small.
- Staff report any suspicion to the MLRO, whatever the amount or the payment method.
- The MLRO decides whether to file a Suspicious Activity Report with the NCA online.
- If the deal has not completed, request a Defence Against Money Laundering and wait for consent or the statutory period.
- Never tell the customer. Tipping off is a criminal offence.
- Report suspected sanctions breaches to OFSI, and freeze the person’s funds or goods.
Section 06What it costs to get wrong
Breaches of the Money Laundering Regulations carry an unlimited HMRC civil penalty, or up to two years’ imprisonment and an unlimited fine. Money laundering under POCA carries up to fourteen years.
Banks close accounts they see as a risk. Documented AML procedures are a member’s best defence against losing banking.
Section 07Abbreviations
We’re here to help
If you are unsure, or experiencing difficulties, let us know — we are here to support and advise where we can. The London Diamond Bourse advocates on behalf of the UK trade, and if you are experiencing difficulties we can advocate on your behalf.
4th March 2024
Dear Members & industry colleagues,
The UK Government has published their Guidance regarding the Import of third Country Processed Russian Diamonds. Read Here
In order to continue to Import Polished Diamonds to the UK we suggest the following be added on a separate sheet of paper attached to the invoice by the vendor.
- Statement regarding Diamonds Under 1.00 Cts.
The Diamonds herein HS Code: 7102 3900 are not subject to the restrictions of Regulation EU 833/2014 & UK 855/2019, The Russia (Sanctions) (EU Exit) Regulations 2019. All Diamonds are under 1.00ct.
- Statement regarding Diamonds equal or larger than 1ct.
This shipment contains:
Polished diamonds that are equal or greater than 1.00ct.
On behalf of [COMPANY NAME OR INDIVIDUAL NAME- (Vendor)], I hereby attest that this shipment does not contain any diamonds that originate in Russia or are from any person in Russia, including being mined, processed, or produced in Russia. I confirm that the contents of this attestation are accurate and are compliant with Regulation EU 833/2014 & UK 855/2019, The Russia (Sanctions) (EU Exit) Regulations 2019.
We would recommend that you inform the signatory of the above declaration that they may be called upon to verify the statement made.
As the recipient of the shipment. We would recommend that in respect of either of the statements made above, and to satisfy that reasonable steps have been taken to give a true statement, that you keep a record of these declarations, transportation method and all relevant customs documents, should you, at a later date, be required to produce them.
The above is given as advice only, as the Department of Trade cannot guarantee that this will satisfy HMRC. This is their response to our request -“I’m afraid we are not able to provide guarantees on what will / will not be accepted at the border. I can, however, refer you back to the guidance which states “A supplier attestation of compliance with this sanction may be acceptable”, and to the other types of information and documentation it signposts.”
LDB- Refer you to the link above.
Alternative:
PLEASE READ THE BELOW:
GENERAL TRADE LICENCE:
The UK Gov has also given us an option to import diamonds that were outside of the Russian Federation as of 1st March 2024.
(As this would apply to most of the Polished diamonds, at today’s date, that you are importing, we would recommend the use of this license- We surmise that dates on the reports would act as proof of being outside of the Russian Federation)
You do not have to apply for this licence – just use the codes below.
You DO have a legal obligation to:
Notify the Secretary of State for the Department for Business and Trade, providing your name (or organisation name), EORI number and the address at which the register or record may be inspected, no later than 30 days after first acting under the authority of this licence. This only needs to be done once, by e mailing : records.importlicences@businessandtrade.gov.uk (Please note you may not use the LDB for that address – use your legal registered address)
Use of this licence entails a customs declaration, using code 9042 and licence number GBSAN0002.
Instruct your logistics/clearing company to import under that licence.
We would suggest:
Statement from Exporter: On invoice or attached.
“This shipment is made USING GB Licence number GBSAN0002.
In compliance with UK 855/2019, The Russia (Sanctions) (EU Exit) Regulations 2019.
These diamonds were outside of the Russian Federation as of 1st March 2024.”
Exports:
When exporting – please ask the logistics company to supply you with the relevant documents that you need for the country that you are sending to.
We await further guidance on grandfathering; how we can manage our private purchases, and guidance apropos stock held previously to the most recent imposed restrictions when exporting to other G7 countries. Once there is clarity on this issue, we will update members.
We would like to thanks the team at the Department of Business and Trade for consulting us, as well as all their work and best efforts.
Your Sincerely,
David Troostwyk
President
London Diamond Bourseclosed at this time.