EU Diamond Sanctions Compliance Checklist

> Important disclaimer: This checklist provides general information and is not legal, customs or sanctions-compliance advice. EU restrictions and national import procedures can change. Businesses should check the current legislation and obtain guidance from the relevant customs authority, competent national authority or qualified professional before acting on a shipment or transaction.

Quick answer

EU diamond sanctions compliance begins by identifying the goods, checking whether they fall within the restricted product categories and weight thresholds, investigating mining origin and transit, verifying suppliers and counterparties, and retaining the evidence supporting the transaction.

Importers have formal customs and traceability responsibilities. Wholesalers and retailers may have different obligations, but they should still maintain accurate supplier, inventory and marketing records. A grading report can identify a diamond’s gemological characteristics, but it does not by itself establish mining origin or sanctions compliance.

Current EU diamond-sanctions timeline

The principal diamond restrictions appear in Article 3p of Council Regulation (EU) No 833/2014.

The April 2026 change appears in Council Regulation (EU) 2026/506.

The restrictions affecting jewellery incorporating Russian diamonds processed in third countries have followed a different timetable from loose diamonds. The previously planned application date was postponed. Businesses dealing with jewellery imported from outside the EU must therefore check the latest version of Article 3p instead of assuming that every loose-diamond rule applies identically to finished jewellery.

How to use this checklist

Not every item below applies to every business or transaction.

Use the following status labels:

• Legal check: May be necessary to determine whether a transaction is prohibited or subject to documentary requirements.
• Importer requirement: Relevant to the party responsible for bringing goods into the EU customs territory.
• Recommended control: A risk-management practice that helps protect records and customer claims but should not be presented as a universal statutory obligation.

Document who performed each applicable check, when it was performed and which evidence was reviewed.

1. Identify your role

Status: Legal check

Before reviewing the diamonds, establish the business’s role in the transaction.

• Are you importing the goods into the EU?
• Are you acting as a customs representative?
• Are you buying goods already released for free circulation in the EU?
• Are you supplying another EU business?
• Are you exporting and expecting the goods to return?
• Are the diamonds held on consignment?
• Are they customer-owned, estate or buyback goods?
• Has responsibility for customs declarations been documented?
• Does the person completing the review have access to the complete transaction file?

A retailer buying an already imported diamond from an EU wholesaler does not automatically become responsible for the original import declaration. The retailer should still retain enough information to identify the supplier, transaction and diamond.

2. Classify the goods correctly

Status: Legal check

• Are the diamonds natural or synthetic?
• Are they rough, polished or set in jewellery?
• Are they industrial or non-industrial?
• What is the correct Combined Nomenclature code?
• What is the weight of each relevant diamond?
• Does the shipment contain multiple product categories?
• Does the packing list clearly identify goods at or above the applicable threshold?
• Has the classification been checked rather than copied without review?

Relevant categories under Annex XXXVIIIA include:

• CN 7102 10: unsorted diamonds.
• CN 7102 31: non-industrial rough diamonds.
• CN 7102 39: non-industrial polished natural diamonds.
• CN 7104 21: rough synthetic or reconstructed diamonds.
• CN 7104 91: polished synthetic or reconstructed diamonds.
• Certain jewellery, precious-metal articles and watches incorporating diamonds.

The correct customs treatment depends on the actual goods. A commercial description such as “diamond jewellery” or “certified stone” is not a substitute for proper classification.

3. Check direct Russian origin, export and transit

Status: Legal check

• Were the goods mined, manufactured or produced in Russia?
• Were the goods exported from Russia?
• Did the goods transit through Russia?
• Is the supplier relying only on the country of sale?
• Is the polishing country being confused with mining origin?
• Is Antwerp sourcing being confused with geological origin?
• Are transport documents available to review the shipment route?
• Are any material gaps in the route unexplained?

Since 1 January 2024, Article 3p has prohibited the purchase, import or transfer of listed diamonds and diamond-containing products when they originate in Russia, were exported from Russia or transited through Russia, subject to the precise scope and exceptions in the Regulation.

4. Check third-country processing

Status: Legal check

A diamond does not become non-Russian merely because it was cut or polished in another country.

• Is the mining or production origin known?
• Was a natural diamond mined in Russia and later polished elsewhere?
• Was a synthetic diamond produced in Russia and later processed elsewhere?
• Does each relevant diamond meet the applicable weight threshold?
• Does the product fall within Part A, B or C of Annex XXXVIIIA?
• Has the current treatment of finished jewellery been checked separately?
• Are supplier statements supported by commercial or traceability records?
• Has any unexplained change in origin description been investigated?

From 1 September 2024, the relevant third-country processing restrictions apply to specified natural and synthetic diamonds in Parts A and B at 0.50 carat or 0.10 gram per diamond. Different provisions and timing can apply to finished jewellery in Part C.

5. Verify the weight threshold

Status: Legal check

• Is the weight recorded for each relevant diamond rather than only as parcel total?
• Are stones of 0.50 carat or above clearly identifiable?
• For synthetic diamonds, has the gram-to-carat relationship been handled correctly?
• Is the weight being assessed at the relevant point of importation?
• Does the shipment contain stones on both sides of the threshold?
• Can the packing list be reconciled with the invoice and customs entry?

The commonly referenced threshold is 0.50 carat per diamond. Synthetic diamonds may also be classified using the corresponding 0.10-gram threshold.

Do not state that diamonds below 0.50 carat are exempt from every EU, customs, sanctions or recordkeeping requirement. Their treatment may differ, but other laws and commercial-documentation requirements can still apply.

6. Complete polished natural-diamond traceability checks

Status: Importer requirement

For relevant polished natural diamonds under CN code 7102 39 00:

• Has the current Due Diligence Statement form been obtained?
• Does the statement correspond to the correct shipment?
• Does it confirm that the relevant diamonds were not mined, processed or produced in Russia?
• Were reasonable verification steps completed before signing?
• Is supplier-origin information available?
• Can the origin position be connected to the invoice and packing list?
• Are transport and route records available?
• Are grading-report numbers linked where useful for identification?
• Has the statement been submitted using the procedure required by the competent authority?
• Has the signed statement been retained with its supporting evidence?

The current amended EU rule applies from 24 April 2026. AWDC’s operational process for imports through Antwerp began on 1 January 2026. Businesses using the Antwerp Diamond Office should continue following its current administrative instructions.

For the complete procedure, use the separate EU Diamond Due Diligence Statement guide.

7. Check rough-diamond documentation

Status: Importer requirement

The Kimberley Process Certification Scheme applies to international trade in rough diamonds. It is implemented in the EU through Council Regulation (EC) No 2368/2002.

• Is the shipment genuinely rough rather than polished?
• Is a valid Kimberley Process certificate present?
• Does the certificate correspond to the parcel and shipment?
• Are the seal, weight, value and parcel details consistent?
• Is the exporting country a Kimberley Process participant?
• Does a mixed-origin certificate identify all required mining countries?
• Is supporting evidence available for the origins listed?
• Has the shipment been routed through an authorised EU authority?
• Is a G7 reference available where the rough goods underwent qualifying verification?
• Have discrepancies been escalated before release?

The Kimberley Process regulates rough-diamond trade. It is not a gemological grading system for polished diamonds.

For mixed parcels, link to the separate mixed-origin Kimberley Process certificate guide.

8. Review the supplier

Status: Recommended control and potential legal check

• Is the supplier’s legal identity verified?
• Is its business address recorded?
• Are registration and tax details available where appropriate?
• Is the payment account consistent with the contracting party?
• Does the supplier explain how it checks diamond origin?
• Can it provide written origin information where relevant?
• Can it connect diamonds to invoices and grading reports?
• Does it distinguish mining origin from polishing country?
• Does it identify legacy and grandfathered goods separately?
• Does it preserve different documentation histories?
• Have unusual or inconsistent answers been investigated?
• Is the supplier review periodically refreshed?

A polished website, Antwerp address or laboratory-report number does not replace supplier due diligence.

9. Screen counterparties and ownership

Status: Legal check

Diamond-specific product controls do not replace the EU’s broader financial-sanctions requirements.

• Have the buyer, seller, consignee and other relevant parties been screened?
• Have relevant beneficial owners or controlling persons been considered?
• Have freight forwarders, brokers and payment recipients been reviewed where appropriate?
• Is payment being requested by an unrelated third party?
• Is an intermediary obscuring the real supplier or customer?
• Are any parties located in unexpectedly high-risk jurisdictions?
• Have potential matches been escalated instead of automatically approved?
• Is evidence of the screening retained?

Use the current EU sanctions sources and obtain professional advice for possible name matches, ownership or control questions. Do not rely on a one-time screenshot of an outdated sanctions list.

10. Check for circumvention warning signs

Status: Legal check

• Has the stated origin changed without a clear explanation?
• Is a new intermediary being used without commercial justification?
• Does the shipment route appear unnecessarily complex?
• Are product descriptions vague or inconsistent?
• Is the supplier unwilling to identify the mining or production origin?
• Are documents missing for stones at or above the relevant threshold?
• Do weights differ across the invoice, grading report and packing list?
• Is the payment destination unrelated to the supplier?
• Has one shipment been split in a way that appears designed to avoid controls?
• Is there pressure to complete the transaction before documents are reviewed?
• Does the supplier ask the buyer to use an inaccurate customs description?

A warning sign does not automatically prove a violation. It should trigger further verification and, where necessary, escalation.

11. Verify transaction and transport documents

Status: Importer requirement or recommended control

• Are the buyer and seller correctly identified?
• Is the invoice number recorded?
• Are the product descriptions accurate?
• Are the CN codes included where required?
• Are total and individual weights consistent?
• Are parcel counts consistent?
• Is the value recorded accurately?
• Are the export and import locations identified?
• Is the transport route documented?
• Is the consignee correct?
• Are grading reports connected to the relevant stock items?
• Are declarations signed by an authorised person?
• Can every important document be retrieved from a central system?

Do not keep the only copy of important compliance evidence in an individual employee’s email account.

12. Handle G7 and GF references correctly

Status: Legal check where applicable

• Does a claimed G7 number relate to qualifying verified rough natural diamonds?
• Has the reference been recorded accurately?
• Is the business incorrectly describing a polished diamond as “G7 certified” without explaining the upstream context?
• Does a claimed GF reference relate to qualifying grandfathered goods?
• Is evidence supporting the grandfathering status available?
• Has “old stock” been incorrectly treated as automatically grandfathered?
• Are returned or re-imported goods connected to the correct reference?

G7, GF, DDS and Kimberley Process documentation serve different purposes. They must not be treated as interchangeable.

Use the separate G7 certificate versus GF number guide for the detailed explanation.

13. Review legacy, grandfathered and returning goods

Status: Legal check

• When did the business obtain the goods?
• Where were the goods physically located before the relevant restriction became applicable?
• Are dated invoices, inventory records or customs documents available?
• Was a required stock declaration or registration completed?
• Are the goods being exported temporarily?
• Are they expected to return to the EU?
• Were they placed under the correct customs procedure?
• Can the same goods be identified on re-entry?
• Has eligibility for an exception been checked against the current Regulation?
• Has professional guidance been obtained for unclear cases?

A diamond’s age alone does not prove that it qualifies for grandfathering. The business must be able to support the relevant facts and satisfy the conditions of the applicable exception.

14. Keep inventory categories distinguishable

Status: Recommended control

• Is newly documented stock identifiable?
• Is legacy inventory separately coded?
• Are grandfathered goods linked to their evidence?
• Are buyback and estate diamonds recorded through a separate intake process?
• Are customer-owned diamonds clearly marked?
• Are diamonds with incomplete origin records flagged?
• Are goods with different documentation histories kept distinguishable?
• Does the stock system preserve report, invoice and supplier references?
• Can sold goods still be connected to their historical records?
• Are document updates recorded without overwriting the audit trail?

Physical separation is not always required. The essential control is that goods with different documentation histories do not become indistinguishable.

For a detailed treatment, link to Diamond Aggregation and EU Rules.

15. Separate grading from provenance

Status: Recommended control

• Is the grading-report number verified with the issuing laboratory?
• Does the report match the diamond?
• Is the report linked to the correct invoice and stock number?
• Are staff trained not to describe grading as origin certification?
• Are mining-origin records stored separately from gemological reports?
• Are customer explanations accurate?

A GIA, IGI or HRD report can describe gemological characteristics and help identify a diamond. It does not automatically prove:

• The mining country.
• The entire supply-chain history.
• Sanctions compliance.
• Market value.
• Ethical performance.
• Kimberley Process compliance for a polished stone.

For further explanation, link to the Diamond Grading Report Guide and Diamond Origin Report Guide.

16. Audit marketing and customer claims

Status: Recommended control and consumer-law risk check

• Can “natural diamond” be supported?
• Can a stated mining origin be supported?
• Can “sourced through Antwerp” be documented?
• Is the polishing country accurately described?
• Can a traceability claim be matched to actual records?
• Has “fully traceable” been used only where the complete claim is supportable?
• Are “ethical” or “conflict-free” claims defined and substantiated?
• Does marketing avoid treating grading reports as origin certificates?
• Do product pages avoid guarantees that exceed the evidence?
• Are staff using the same approved explanations as the website?

Precise language is safer than absolute language. For example, “sourced through Antwerp with available supplier and origin documentation” is narrower than claiming complete mine-to-market traceability.

17. Prepare for checks and document requests

Status: Importer requirement or recommended control

• Is the responsible person identified?
• Can the complete shipment file be retrieved quickly?
• Can the DDS be connected to its supporting evidence?
• Are supplier declarations available?
• Are transport and customs documents retained?
• Can mining-origin information be retrieved?
• Are discrepancies and decisions documented?
• Is the retention period recorded?
• Are documents stored securely with appropriate access controls?
• Has the business tested whether an old file can actually be retrieved?

AWDC states that businesses using the relevant Antwerp procedure should retain documentation for five years. Do not present this as a universal retention period for every business record without checking the rules applicable to the specific operator and transaction.

AWDC also reported that Belgian FPS Economy spot checks on in-scope natural polished-diamond imports began in May 2026. See the AWDC spot-check update.

18. Assign responsibility and escalation

Status: Recommended control

• Is one person responsible for sanctions-related document control?
• Is a backup person assigned?
• Do purchasing staff know which documents to request?
• Do sales staff understand grading versus mining origin?
• Do logistics staff know when customs guidance is required?
• Are unclear cases paused rather than guessed?
• Is there an escalation path to management?
• Does the business know when to contact customs, AWDC, Diamond Office or a professional adviser?
• Are material policy changes communicated to staff?
• Is completion of the review documented?

The objective is not to turn every employee into a sanctions specialist. It is to make sure staff recognise when a transaction should not proceed without further review.

Condensed compliance record

Use this table for each relevant shipment or transaction:

Frequently asked questions

Final guidance

An effective diamond-sanctions process connects five things:

1. The correct product classification.
2. The diamond’s weight and identity.
3. Its available origin and processing information.
4. The supplier, transaction and transport records.
5. The decision made by the business.

The checklist is a control tool, not a guarantee. Each shipment must be reviewed according to the current law, the business’s role and the facts of the transaction.

Dalila Diamonds can assist trade buyers with natural-diamond sourcing, grading-report references, commercial documentation and available origin information. Buyers requiring customs or legal advice should consult the appropriate authority or qualified professional.

10. Required Internal Links

Also link to this checklist from:

• The planned EU compliance hub.
• The DDS guide.
• The Diamond Office import guide.
• The mining-origin regulation guide.
• The aggregation guide.
• The G7/GF guide.
• Relevant wholesale sourcing pages.