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Cease all Direct Dealings with Alrosa, Warns JVC

April 12, 22 by John Jeffay

(IDEX Online) - Businesses in the US must cease all dealings with Alrosa, says the Jewelers Vigilance Committee (JVC), including any memo/consignment agreements.

It issued updated guidance to members following the US Treasury Department's announcement on 7 April of further restrictions on the miner, which is one-third owned by the Russian government.

Alrosa is now on its Specially Designated Nationals (SDN) list, blocking it from the US banking system and banning it from trade with individuals or companies in the USA.

"In practical terms, if a US business had not already stopped doing direct business with Alrosa due to the previous sanction limitations, they absolutely must now cease doing so," says the New York-based JVC, which provides legal education and compliance guidance to the jewelry industry.
 
"If a US business has goods or funds in-house that Alrosa may have an ongoing interest in (due to a memo/consignment agreement or other contract), those assets are now frozen and the business should seek counsel to determine how to proceed."

The JVC warns members that evasion of sanctions is a crime and a serious threat to national security and foreign relations.

"The safest course of action for all US businesses is to tell all suppliers that they will no longer purchase any goods that originated from Alrosa. 

"It is not yet clear how OFAC or US Customs will interpret this new designation, but if a US business continues to deal in these goods, even indirectly, they are at risk for encountering issues upon importation or the freezing of assets.

"In addition, US banks are also required to comply with these sanctions and will likely be asking jewelry business customers for information ensuring that they are in compliance."

Pic courtesy Alrosa

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