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Legal

Sanctions Policy

The sanctions regimes we comply with and how we apply them.

Effective 6 August 2026

Template document

This is a good-faith template written for a business of this type. It has not been reviewed by a qualified lawyer in any jurisdiction. Have it reviewed against the law where you operate and where you sell before relying on it commercially.

01Regimes

We comply with United Nations Security Council sanctions and UAE sanctions law. Because our buyers, banks and shipping partners are subject to them, we also apply the sanctions of the European Union, the United Kingdom and the United States (OFAC), including ownership-based designations.

02Application

  • No dealings with designated persons, or entities they own or control.
  • No transactions involving comprehensively sanctioned countries or territories.
  • Origin evidence for diamonds and metals subject to origin-based import bans, such as G7 restrictions on Russian-origin diamonds.
  • Screening of vessels, carriers and ports used for our shipments.

03Breaches

A potential sanctions match stops the transaction until the compliance officer has resolved it. We report confirmed breaches to the relevant authority.