OFAC moves the grandfathered deadline a year, to 1 September 2027
General License No. 104B extends by one year the window for Russian-origin diamonds bought before sanctions. Stones over a carat must have left Russia before 1 March 2024; half to one carat before 1 September 2024.
§1A deadline moved, and a licence numbered twice over.
The United States Treasury's Office of Foreign Assets Control issued General License No. 104B on 27 August, moving to 1 September 2027 a deadline that had stood at 1 September 2026. The licence covers loose, nonindustrial Russian-origin diamonds that were bought before the sanctions took effect and that had not entered the American market by the cutoffs the licence names. Stones of one carat and above must have left Russia before 1 March 2024. Stones between half a carat and one carat must have left before 1 September 2024. General License No. 103, which governs imports of diamond jewellery, is unchanged. This desk could not extract the licence text from OFAC's own recent-actions listing, which renders its results dynamically and returned no diamond entry to a plain fetch, and carries the detail from Rapaport's report of the release, which the bureau independently confirmed against the page's own publication metadata.
§2What three and a half years of shelf life means.
The arithmetic of a grandfathering clause is the arithmetic of how long goods can sit. A one-carat stone that qualifies under this licence left Russia before 1 March 2024, so by the new deadline it will have been outside Russia for at least 1,279 days, three and a half years. A half-carat stone left before 1 September 2024 and will have been out at least 1,095 days, three years to the day. The extension itself is 365 days. What has been extended, in other words, is not a trading window on new goods but the shelf life of a specific and closed population of stones that was already fixed in size on two dates in 2024 and has been shrinking ever since, as parcels clear or are written down.
Three and a half years, and the parcels still cannot land.
§3Nobody has published the size of it.
Nobody has published how many carats are in that population, and the absence is the story's limit. Neither the licence as reported nor any trade body this desk reached puts a weight, a value or a count on the goods still waiting. Without it, a one-year extension cannot be priced. It can be read directionally: an authority that thought the remaining volume was trivial would let the deadline pass, and an authority that thought the market could absorb it at once would not have extended it three times. The instrument's own history is the only quantity available. A licence numbered 104B is the second amendment to a licence, and each amendment has bought the same population more time rather than releasing it.
§4Documented goods cost money to keep documented.
There is a second reading, and it is about where those stones are rather than when they may move. A parcel grandfathered under 104B is legal in the United States and, under the Group of Seven's separate traceability regime, is documented as pre-sanction goods rather than as ordinary rough. That documentation follows the stone, and it is expensive to maintain across three and a half years of storage, insurance and financing on inventory nobody has sold. This desk has reported through August on the cost of holding rough that cannot be moved, and on Antwerp's July imports falling to 1,590,026 carats, the thinnest month in the fifty-five that its own body publishes. A pipeline that thin is a pipeline in which parked goods are a larger share of everything.
An extension is being read in parts of the trade as a softening, and it is closer to the opposite. Nothing in 104B lets a single new Russian stone in. It lets a fixed and ageing pile of stones that were already bought, already shipped and already documented stay eligible for another year, and it does so for the third time. If those goods were saleable at a price the holders would accept, three years and six months is long enough for them to have gone.
A dealer looking at this notice should read it as the regulator confirming the overhang still exists, on the regulator's own evidence, rather than as a door opening. The stones are not stuck because of the deadline. The deadline exists because the stones are stuck.
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