Experts see a persistent gap between diamond sanctions design and enforcement

Since early 2024, diamonds have been drawn into one of the most extensive sanctions regimes ever aimed at a single economy, as the G7, the European Union and the United Kingdom progressively restricted the import of Russian-origin stones following Russia’s full-scale invasion of Ukraine. Now a three-round modified Delphi study, published in the journal Crime Science, has asked a deceptively simple question about those measures: can they actually be enforced? The answer from an international panel of experts is a qualified no. The panel converged on the view that a persistent gap separates what the sanctions require on paper from what frontline authorities and supply-chain actors can realistically detect, evidence and act upon.

The study, conducted by Lucy Mellows and Kartikeya Tripathi, recruited experts from academia, government and enforcement, non-governmental organisations and the diamond industry. Participants needed at least ten years of relevant professional experience in fields such as sanctions or customs enforcement, anti-money-laundering compliance, diamond-sector trade, or academic research on sanctions and supply-chain integrity. Thirty-two participants completed the first round, thirty returned for the second and nineteen for the third, an overall retention rate of fifty-nine percent that the authors note falls within the range typically reported for multi-round Delphi studies.

The design was deliberately bottom-up. The first round posed four open-ended prompts, covering enforcement barriers, unintended consequences, transparency innovations and stakeholder responsibilities, and the responses were analysed through inductive thematic analysis grounded in participants’ own language. The recurring themes were then converted into six Likert-scaled constructs rated in the later rounds. Consensus was pre-specified as at least seventy-five percent of ratings falling in the top two response categories combined with an interquartile range of no more than one, and stability across rounds was defined as an unchanged median with a mean shift of no more than fifteen percent. Items that failed to reach consensus but remained stable are described as showing stable divergence rather than outright rejection.

Four of the six constructs cleared the consensus threshold. Political will and governance attracted the strongest and tightest agreement, with a median of five, an interquartile range of zero and eighty-nine percent of ratings in the top two categories. Enforcement capacity reached consensus with a median of four and eighty-one percent agreement, as did legal and policy innovations at seventy-eight percent. Traceability mechanisms met the threshold exactly, at seventy-five percent. Two constructs fell short: the feasibility of cultural change in the industry, at seventy percent, and the effectiveness of technological fixes, at sixty-three percent. Both divergences proved stable across rounds, meaning that revisiting the items in light of anonymised group feedback did not move the panel toward agreement.

The reasoning behind the ratings is where the study becomes most revealing. Participants located the enforceability constraint upstream of any technical instrument, in the political economy of the regime itself. One participant characterised the regime’s centre of gravity as symbolic rather than operational, saying the political win is in the announcement while enforcement is treated as a secondary concern. On enforcement capacity, experts agreed that stricter enforcement, secondary sanctions, fines and clearer legislative guidance can deter evasion, but many qualified this by citing the operational burden that low origin knowability places on frontline authorities. Because the geological source of any diamond is extremely difficult to determine, as one participant put it, efforts to interdict evasion become in practical terms effectively impossible.

That impasse stems from the physical properties of the commodity itself. Cut-and-polished diamonds are often mixed from various sources, and once rough stones are processed and re-exported through global cutting hubs, particularly in India and the UAE, their geographic provenance cannot be determined through inspection alone. Customs determinations of origin rest on documentary and procedural evidence rather than any physical property of the good, so where documentation can be fabricated or third-country processing legally transforms origin, authorities must contest the paper record without an independent physical anchor. The Kimberley Process, the existing governance system for rough diamonds, does not track stones through cutting and polishing, precisely the stage at which origin knowability collapses, leaving weak evidentiary signals at borders.

The panel’s scepticism about technological fixes centred on a familiar weakness: such systems depend on the integrity of the data they accept. As one participant warned, blockchain can ensure that records are not changed, but it does not preclude false records from being entered in the first place, a dynamic the study describes as the risk of digitising the lie. Participants also distinguished between the compliance and marketing functions of traceability tools, noting that blockchain-based platforms can serve as storytelling devices that signal responsibility to consumers and investors even where their evidentiary value for sanctions enforcement is limited. On industry culture, participants agreed that transparency matters but diverged sharply on whether cultural change is achievable, with several observing that transparency initiatives could professionalise some actors while pushing others further underground.

Beyond the six rated constructs, two cross-cutting qualitative themes emerged. The first was the absence of an institutionalised enforcement voice in the design of the measures: participants with frontline experience perceived that operational enforceability had not been adequately represented during drafting. The second was the marginalisation of non-governmental organisations, whose monitoring and origin-tracing knowledge was seen as underused within the formal regime. From these findings the authors derive a three-pillar enforceability-first roadmap: embedding frontline operational input at the design stage, provisionally through a standing sanctions operations cell staffed by customs and border personnel; using civil-recovery pathways under the Proceeds of Crime Act 2002 as a complement to, not a substitute for, criminal enforcement; and treating traceability as a governed system with civic oversight rather than a purely technological solution.

The authors are careful about the limits of what the study shows. The panel was imbalanced, with academics substantially outnumbering industry, government and NGO participants, and attrition from thirty-two to nineteen raises the possibility that those who remained differ systematically from those who left. Recruitment through professional networks and snowball sampling introduces self-selection bias, and the findings reflect expert perception rather than measured breach rates. Generalisability beyond the UK, EU and G7 diamond context is presented as a conceptual argument rather than an empirical demonstration. The study is explicitly framed as an exploratory expert-consensus assessment, not a validated measure of enforcement failure.

Even so, the authors argue the insight travels. Any commodity whose origin is difficult to establish once it has been processed, mixed or re-exported, such as certain refined metals or some agricultural products, will present a similar enforceability profile: a clear legal prohibition undercut by low knowability at the frontline. The panel’s central conclusion, that technological and cultural remedies cannot substitute for systemic governance and frontline capacity, reframes the policy problem from the design of diamond sanctions to their enforceability, and suggests that future regimes for hard-to-verify commodities should be built with the operational realities of enforcement built in from the start rather than bolted on afterwards.

Subject of Research: Expert assessment of the enforceability of sanctions on Russian-origin diamonds

Article Title: The design-enforcement gap in diamond sanctions: a three-round modified Delphi study of enforceability

Article References: Mellows, L., & Tripathi, K. (2026). The design-enforcement gap in diamond sanctions: a three-round modified Delphi study of enforceability. Crime Science, 15(1), Article 34. https://doi.org/10.1186/s40163-026-00301-0

Image Credits: AI Generated

DOI: 10.1186/s40163-026-00301-0

Keywords: diamond sanctions, Russia sanctions, Delphi study, enforceability, traceability, Kimberley Process, customs enforcement, supply chain, G7, Crime Science, sanctions evasion, civil recovery