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Loren Yager,
General Accounting Office
Adapted from Significant Challenges Remain in Deterring Trade in Conflict
Diamonds
February 13, 2002
Conflict Diamonds
Summary
The nature of diamonds
and the operations of the international diamond industry create
opportunities for illicit trade, including trade in conflict diamonds.
Diamonds are mined in remote areas around the world and are virtually
untraceable back to their original source--two factors that make
monitoring diamond flows difficult. Diamonds are also a high-value
commodity that is easily concealed and transported. These conditions allow
diamonds to be used in lieu of currency in arms deals, money laundering,
and other crime. Lack of transparency in industry operations also
facilitates illegal activity. The movement of diamonds from mine to
consumer has no set patterns, diamonds can change hands numerous times,
and industry participants often operate on the basis of trust, with
relatively limited documentation. All of these practices reduce
information about diamond transactions. The lack of industry information
is exacerbated by poor data reporting at the country level, where import,
export, and production statistics often contain glaring inconsistencies.
U.S. control over diamond
imports is based on its general control system for most commodities. This
control system requires that diamond import documentation include the
country of last export--which U.S. import requirements consider the
country of origin. Because the current import control system does not
require certification from the country of extraction--just from the
country of last export--it is not effective in identifying diamonds that
might come from conflict sources. Beginning in 1998, rough diamond imports
from Angola and Sierra Leone not bearing the official government
certificate of origin as well as all rough diamonds from Liberia were
banned from the United States. 2U.S. Customs requires that all shipments
from Angola and Sierra Leone have a certificate of origin or other
documentation that demonstrates to Customs authorities that the diamonds
were legally imported with the approval of the exporting country
governments. However, without an effective international system that can
trace the original source of rough diamonds, the United States cannot
ensure that conflict diamonds do not enter the country.
The Kimberley Process
proposal for an international diamond certification scheme lacks some key
elements of accountability. We evaluated the scheme using aspects of
established criteria for accountability--control environment, risk
assessment, control activities, information and communications, and
monitoring. 4 While we do not expect the Kimberley proposal to fully
address all these elements, this examination provides insights into its
ability to deter trade in conflict diamonds. Our assessment of the scheme
showed that it incorporates some elements, such as requiring that
Kimberley Process Certificates that designate country of origin for
unmixed shipments accompany each shipment of rough diamond exports. But
some important elements are lacking, and others are listed only as
optional or recommended. For example, the scheme is not based on a risk
assessment--an essential element. As a result, some activities that would
be deemed high-risk by industry experts as well as Kimberley participants,
such as the flow of diamonds from the mine or field to the first export,
are subject only to "recommended" elements. Additionally, the
period after rough diamonds enter a foreign port to a final point of sale
will be covered by an industry system in which participation is voluntary
and monitoring and enforcement are self-regulated. Other issues relating
to accountability are also being discussed by four Kimberley working
groups: the establishment of a secretariat; compliance with World Trade
Organization rules; sharing of statistics; and monitoring needs. Although
the Kimberley Process participants have achieved significant cooperation
among industry, nongovernmental organizations, and governments to address
trade in conflict diamonds, our work suggests that the participants face
considerable challenges in establishing a system that will effectively
deter this trade.
Background
Conflict diamonds are
primarily associated with four countries: Sierra Leone, Liberia, Angola,
and the Democratic Republic of the Congo. In all four countries, the
production and/or trade of diamonds have played a role in fueling domestic
conflict, or, as is the case with Liberia, fueling conflict in neighboring
Sierra Leone through the Revolutionary United Front (RUF). Today, Sierra
Leone is experiencing relative peace with the aid of the United Nations
and other efforts. Nonetheless, diamond mining remains one of the only
viable economic opportunities for ex-combatants, and thus experts believe
the ability to adequately manage this resource will be important for
efforts at establishing long-lasting peace. In Angola, the National Union
for the Total Independence of Angola (UNITA) retains control of some
diamond production areas, as well as unknown quantities of stockpiled
diamonds. And in the Democratic Republic of the Congo, diamonds continue
to serve as a source of revenue for armed militias fighting in the north
of the country. To date, United Nations sanctions have been targeted
solely at rough diamond exports from the RUF in Sierra Leone; Liberia; and
UNITA in Angola. Also, both the governments of Sierra Leone and Angola
have national diamond certification schemes in which certificates of
origin are issued and accompany rough diamonds from their first export to
their first import into a foreign country.
Structure of Diamond
Industry
The international diamond
industry comprises three sectors: mining, rough diamond trading and
sorting, and cutting and polishing. This industry structure includes both
large and well-organized components as well as small, uncontrolled
operations. For example, due to the substantial capital required for deep
mining, just four companies mine 76 percent of the world supply of rough
diamonds. Yet, across Africa, countless individual diggers mine widely
scattered alluvial fields for diamonds. Similarly, while De Beers controls
a large percentage of diamond shipments to key trading centers, U.N. data
suggest that more than 100 countries worldwide participate in rough
diamond exporting. In terms of cutting and polishing, markets have largely
evolved to reflect labor costs, with 9 out of 10 rough diamonds cut and
polished in India. However, mining countries such as Russia, South Africa,
Botswana, and Namibia are trying to expand their cutting and polishing
activities to supplement mining revenues.
The Kimberley Process
In May 2000, African
diamond producing countries initiated the Kimberley Process in Kimberley,
South Africa, to discuss the conflict diamond trade. Participants now
include states and countries of the European Union involved in the
production, export, and import of rough diamonds; as well as
representatives from the diamond industry, notably the World Diamond
Council, and nongovernmental organizations. The goal is to create and
implement an international certification scheme for rough diamonds, based
primarily on national certification schemes and internationally agreed
minimum standards for the basic requirements of a certificate of origin.
The scheme's objectives are to (1) stem the flow of rough diamonds used by
rebels to finance armed conflict aimed at overthrowing legitimate
governments; and (2) protect the legitimate diamond industry, upon which
some countries depend for their economic and social development. U.N.
General Assembly Resolution 55/56, adopted on December 1, 2000, requested
that countries participating in the Kimberley Process present to the
General Assembly a report on progress developing detailed proposals for a
simple and workable international certification scheme for rough diamonds.
According to the South
Africa Department of Foreign Affairs, the Kimberley Process submitted a
report to the U.N. General Assembly in late 2001. 10 The report was
accompanied by a proposal for an international certification scheme for
rough diamonds dated November 28, 2001, which was to provide the basic
elements envisaged for the certification scheme. Participants asked that
the certification scheme be established through an international
understanding as soon as possible, recognizing the urgency of the
situation from a humanitarian and security standpoint. The report also
requested an extension of the Kimberley Process mandate to the end of 2002
to enable finalization of the international understanding. Those in a
position to issue the Kimberley Process Certificate were to do so
immediately. All others were encouraged to do so by June 1, 2002. Further,
it was the intention of participants to start full implementation of the
scheme by the end of 2002. Finally, a draft resolution seeking an
international endorsement of the scheme will be submitted to the U.N.
General Assembly for consideration, possibly as soon as late
February.
U.S. Participation in
the Kimberley Process
In May 2000, the U.S.
government established an interagency working group to provide input to
and representation at the Kimberley Process meetings. The working group is
headed by the Department of State; other participants include the
Departments of Commerce, Justice, and Treasury, U.S. Customs Service,
Federal Trade Commission, Office of U.S. Trade Representative, U.S. Agency
for International Development, National Security Council, Central
Intelligence Agency, and the Office of Science and Technology. The United
States is currently chairing the Kimberley Process working group on World
Trade Organization compliance issues.
Nature of Diamonds and
Non-Transparent Industry Operations Create Opportunities for Illicit Trade
The illicit diamond
trade, including that in conflict diamonds, is facilitated by the nature
of diamonds and the lack of transparency in industry operations. Although
industry and nongovernmental organizations have made estimates of both the
illicit and conflict diamond trades, the criminal nature of the activity
precludes determination of the actual extent of the problem. Conflict
diamond estimates vary from about 3 to 15 percent of the rough diamond
trade and are often based on historical production capacities for rebel-
held areas. Some industry experts dispute the larger percentage, believing
it includes non-conflict illicit trade.
The Nature of Diamonds
Facilitates Illegal Trade
The nature of diamonds
makes them attractive to criminal elements. Diamonds are found in remote
areas of the world and can be extracted both through capital-intensive
deep mining techniques as well as from alluvial sources using rudimentary
technology. Individual diggers across west and central Africa mine
alluvial fields that are widely scattered and difficult to monitor, a
problem made worse by porous borders and corruption. Diamonds are easy to
conceal and smuggle across borders, and smuggling routes are well
established by those who have done so for decades to evade taxes. Though
it may be possible for experts to identify the source of an unmixed parcel
of rough diamonds, once diamonds from various sources are mixed, they
become virtually untraceable. Identifying the origin of alluvial diamonds
is complicated by the fact that the river systems depositing those
diamonds run across government- and rebel-held areas as well as national
borders. Although rough diamonds can be marked, once they are cut and
polished, any form of identification is erased. All of these factors,
combined with inadequate customs and policing worldwide, make diamonds
attractive to criminal elements who may use them to trade arms, support
insurgencies, and plausibly engage in terrorism. Likewise, diamonds can be
used as a means of currency in connection with drug deals, money
laundering, and other crime or as a store of wealth for those wishing to
hide assets outside the banking sector where they can be detected and
seized.
Industry's Lack of
Transparency Also Facilitates Illicit Trade
The flow of diamonds from
mine to consumer, referred to as the "diamond pipeline," has no
set patterns. Diamonds can change hands numerous times as shown by the
fact that the value of world rough diamond exports is three times as large
as the value of world rough diamond production. According to industry
experts, diamonds are sold back and forth and mixed and re-mixed making
tracking a particular shipment through the pipeline and across borders an
arduous if not impossible task. Diamonds can be traded in smaller markets
and diverted through alternative routes either to disguise origin or in
response to low taxes and less burdensome regulations. Thus, the mobility
of the trade has also acted as a disincentive for individual governments
to implement stricter controls.
Limited transparency in
diamond flows is reflected in inconsistent and insufficient data. U.N.
data show large discrepancies between export and import data. For example,
while Belgium reported selling $355 million worth of rough diamonds to the
United States in 2000, the United States reported buying only $192 million
worth of rough diamonds from Belgium. U.N. data also suggest that reported
world imports of rough diamonds from many countries far exceed those
countries' production. For instance, the Central African Republic's
production of rough diamonds was worth $72 million in 2000, while global
imports from that country totaled $168 million, and the Democratic
Republic of the Congo's production was worth $585 million in 2000, while
global imports from that country totaled $729 million. Similarly, global
imports of rough diamonds from the United Arab Emirates totaled $177
million in 2000, while that country neither mines rough diamonds nor
reports having imported rough diamonds from producing countries.
These data
inconsistencies can be attributed to a wide variety of factors including:
· differences in how customs officials appraise shipments so that export
values differ from import values;
· industry practices
such as selling goods on consignment or unloading stockpiles so that trade
data differ from production capacities;
· false declarations by
importers on where they obtained their shipment, leading to data
indicating a country's exports exceed its production; or
· smuggling.
Unfortunately, diamond
trade data limitations have been difficult to rectify given that the
industry has historically avoided close scrutiny. According to industry
experts and government officials, U.S. and international diamond firms do
not share trade information freely and business may be conducted on the
basis of a handshake, with limited documentation. Furthermore, information
problems resulting from industry's lack of transparency are made worse by
poor data reporting from many mining and trading nations.
Another factor with the
potential to limit transparency in the international diamond industry is
the current trend toward merging mining with cutting and polishing
activities at the country level. In response to reduced demand and
declining rough diamond prices, a number of mining countries are
encouraging domestic cutting and polishing. However, when diamonds are cut
and polished in mining countries, the source of the rough diamonds used
cannot be verified.
The United States
Cannot Detect Conflict Diamonds With Present Import Controls
Under its current import
control system, the United States cannot determine the true origin of
diamond imports nor ensure that conflict diamonds do not enter the
country. In 1998, the United States began to enhance controls to prevent
conflict diamonds from entering the country from U.N. and U.S. sanctioned
sources. Since 1998, there have been six diamond-related investigations.
However, none of these cases resulted in federal prosecutions relating to
diamond smuggling. Without an effective international system to identify
the origin of rough diamonds, the United States remains vulnerable to
diamonds from conflict sources sent to second countries and then shipped
to the United States.
Diamond Imports
Subject to General Import Controls;
Limited Controls Added to Implement U.N. Sanctions
Diamond imports are
subject to the same import controls used for most commodities.
Documentation accompanying diamond shipments entering the United States
must include a commercial invoice, country of last export, total weight,
and value. However, the regulations do not require exporters to specify
the country of extraction nor the place of first export. For example,
rough diamonds could be mined in one country and traded several times
before reaching their final destination. The ability to determine the true
source of origin is further impeded because U.S. import shipments can
contain diamonds mixed together from numerous countries. Under the current
system, Customs would only have documentation citing the last export
country.
Until 1998, the United
States did not consider conflict diamonds a commodity of focus. But
beginning in 1998, the United States put into place import controls to
target diamonds documented as originating from the National Union for the
Total Independence of Angola, the Revolutionary United Front in Sierra
Leone, and Liberia-- all of which are subject to U.N. sanctions. Rough
diamonds from Liberia have been banned indefinitely from the United
States. U.S. Customs requires that all shipments from Angola and Sierra
Leone have a certificate of origin or other documentation that
demonstrates to U.S. Customs authorities that they were legally imported
with the approval of the exporting country governments. However, the
controls do not prevent diamonds from these conflict sources from being
shipped to a second country and mixed within shipments destined for the
United States.
In fiscal year 2000,
about $816 million of rough diamonds from 53 countries officially entered
the United States through 19 different ports of entry. According to
Customs officials, 35 random physical inspections of rough diamond mixed
shipments have been performed since 1998. Of these, five cases were found
to have minor discrepancies primarily because of incorrect documentation
or the diamonds were misdelivered.
Customs officials stated
that it is virtually impossible to determine the original source of rough
diamonds based on physical inspection; thus U.S. Customs officials must
rely on the accuracy of the source cited in accompanying import
documentation.
Current Kimberley
Certification Scheme Lacks Key Aspects of Accountability
The Kimberley Process
working document describing the essential elements of an international
diamond certification scheme does not contain the necessary accountability
to provide reasonable assurance that the scheme will be effective in
deterring the flow of conflict diamonds. Without effective accountability,
the certification scheme may provide the appearance of control while still
allowing conflict diamonds to enter the legitimate diamond trade and, as a
result, continue to fuel conflict.
The Kimberley scheme
primarily provides a description of what participants should do as well as
"recommendations" and "options." The document
describing the scheme is divided into sections covering definitions, the
Kimberley Process certificate, undertakings concerning international
trade, internal controls at the national and industry levels, cooperation
and transparency, and administrative matters. Elements of internal
controls are addressed throughout the document, such as the requirement
that the Kimberley Process certificates, designating the country of origin
for unmixed parcels, accompany each shipment of rough diamonds and that
the certificates be readily accessible for a period of no less than 3
years. However, the scheme lacks key aspects of effective controls, and
some "controls" are considered "recommended" or
"optional." Some of the areas needing further attention include
issues on which agreement has not yet been reached. Working groups have
been assigned to address these issues, which include the possible
establishment of a secretariat, compliance with World Trade Organization
rules, 13sharing of statistics, and the level of monitoring needed.
To assess the current
scheme, we looked at evaluations of other international certification
schemes and other sources for criteria that can be used to evaluate the
Kimberley certification system. We believe the best criteria available are
based on standards for internal control that have been developed for
organizations. 14 The Kimberley Process participants recognize the
importance of internal controls, and the 15 U.S. government, industry, and
the international entities such as the World Bank have accepted these
standards. While the Kimberley Process is not an organization, the
criteria provide useful insights into the ability of the Kimberley Process
to achieve basic objectives of accountability and transparency. The
guidelines include five control elements--control environment, risk
assessment, control activities, information and communications, and
monitoring. I will discuss each element and some of the key aspects
lacking in the current Kimberley scheme.
Control Environment: A
control environment is one with a structure, discipline, and climate
conducive to sound controls and conscientious management. The Kimberley
scheme faces serious challenges in meeting these criteria. · Kimberley
participants have been unable to agree on the form of administrative
support at the international level, whether it is a secretariat or some
other mechanism. According to the Kimberley document, institutional
arrangements, or the administrative support for the scheme, will be
discussed at a future plenary meeting, and no commitments have been made
with regard to staffing or funding. 16 · Individual participants are
required to set up a system of national internal controls and effective
enforcement and penalties. It is unclear how and when the capabilities of
different participants to do so will be assessed and, where needed,
assistance provided. If countries fail to comply with the essential
elements of the scheme, then according to the scheme, they can be excluded
from trading with participants. However, whether this provision complies
with trade agreements such as those under the World Trade Organization has
been a point of contention since early in the process and remains under
discussion by one of the working groups.
· Political willingness
as well as industry commitment to support and implement Kimberley vary.
Membership is voluntary, and despite efforts to recruit more members, some
key countries have not participated in the Kimberley Process. Further, the
United Nations discontinued its "name and shame" policy
concerning trade in conflict diamonds because of the lack of clear and
consistently applied investigative standards. How the United Nations
responds to the Kimberley document and what form the final document will
take (an agreement, memorandum of understanding, or some other form) are
not known.
Risk Assessment: A risk
assessment is a mechanism for properly identifying, analyzing,
prioritizing, and managing risks to meet objectives. The Kimberley Process
does not include a formal risk assessment and thus participants cannot be
assured that appropriate controls are in place. Three potential high-risk
areas not adequately addressed in the Kimberley scheme include the
following.
· Industry experts and
Kimberley participants agree that unless the segment of the diamond
pipeline from when the diamond is first discovered in the alluvial field
or mine to the point it is first exported is subject to controls, conflict
diamonds may enter the legitimate trade. The scheme does little to address
this issue, offering only recommendations encouraging participants to
license diamond miners and maintain effective security.
· Industry and others
hold stockpiles of diamonds with undocumented sources and the number of
diamonds held in stockpiles may be considerable. Since the Kimberley
scheme requires information on origin, it is unclear how these diamonds
will be addressed. Apparently, any conflict diamond could be claimed as a
stockpiled diamond at the scheme's initiation.
· The period after rough
diamonds enter a foreign port until their point of sale as rough diamonds,
polished diamonds, and jewelry will be covered by an industry system
called a chain of warranties in which participation is voluntary and
monitoring and enforcement are self-regulated. 17
Control Activities:
Control activities consist of policies, procedures, techniques, and
mechanisms that ensure that management directives are being carried out in
an effective and efficient manner to achieve control objectives. The
Kimberley scheme's inconsistent attention to control activities raises
concerns, such as the following.
· While some internal
controls are delineated, others are recommended or considered optional
without clear justification, and many controls are to be developed at the
national level where capabilities and political will differ. · The
industry chain of warranties is based on voluntary participation and self-
regulation. Although the scheme requires that all sales invoices of
participating industry be inspected by independent auditors to ensure that
the diamonds come from non-conflict sources, an audit trail is problematic
in an industry where diamonds are sorted and mixed many times.
Information and
Communications: An information and communication mechanism is needed for
recording and communicating relevant and reliable information to those who
need it in a form and time frame that enable them to carry out their
internal control responsibilities. Two concerns regarding the Kimberley
scheme's mechanism for information and communication are as follows.
· Although the Kimberley
Process has identified information to be communicated among participants,
it has not fully worked out the details of what, how, and when the
information will be shared and used. Participants had a great deal of
difficulty reaching agreement on sharing statistical data, and a number of
issues remain open. The working document states that the content,
frequency, timing, format, and methods of handling and exchanging
statistical data are to be developed by an ad hoc working group and
adopted at a plenary meeting.
· The European Union
will function as one trading partner under the Kimberley scheme. It
remains unclear how its data will be compiled and shared in a timely
manner.
Monitoring: A monitoring
mechanism consists of continuous monitoring and evaluation to assess the
quality of performance over time in achieving the objectives and ensuring
that the findings of audits and other reviews are promptly resolved.
Participants had a great deal of difficulty reaching agreement on the need
for monitoring. Concerns were raised about sovereignty. A working group is
currently addressing this element. The Kimberley scheme's monitoring
mechanisms lack details and rely heavily on voluntary participation and
self-assessments. For example,
· Monitoring is based on
participants' reporting of other participants' transgressions to initiate
a verification mission. A participant can inform another participant
through the Chair if it believes the laws, regulations, rules, procedures,
or practices of that other participant do not ensure the absence of
conflict diamonds in the exports of that other participant.
· Review missions are to
be conducted with the consent of the participant concerned and can include
no more than three representatives of other participant members.
Membership and terms of reference of the review missions have not yet been
determined. The scheme does not discuss a mechanism for ensuring that the
findings of the review missions are promptly resolved.
· No guidelines have
been established for developing required self-assessments.
· No system has been
proposed for monitoring the industry system of warranties.
· No external audit of
the scheme's administration is discussed.
While we do not expect the Kimberley Process proposal to completely address all aspects of accountability, we hope our analysis will be useful in enhancing the scheme's ability to deter the conflict diamond trade. Further, we acknowledge that while the Kimberley Process has brought together industry, nongovernmental organizations, and governments to address a serious humanitarian issue, the participants face significant challenges in deterring the trade in conflict diamonds.
Notes
2 - The United Nations
Security Council has imposed international sanctions on rough diamond
imports from the National Union for the Total Independence of Angola, the
Revolutionary United Front in Sierra Leone, and Liberia.
3 - Executive Order 13213
dated May 22, 2001, banned all rough diamond shipments from Liberia for an
indefinite period.
4 - The U.S. government,
industry, and international entities such as the World Bank accept these
internal control standards applied to organizations. See Standards for
Internal Control in the Federal Government, (GAO/AIMD-00-21.3.1, Nov.
1999), and Internal Control--Integrated Framework (1985), published by the
Committee of Sponsoring Organizations of the Treadway Commission and used
by the World Bank.
5 - Adjacent countries,
such as Congo-Brazzaville, Guinea, Cote d'Ivoire, and the Gambia, have all
been listed in U.N. reports as countries through which conflict diamonds
are smuggled. People named in U.N. reports for their involvement in
trading conflict diamonds have been citizens of the Middle East, Europe,
and the United States. Also, recent media reports have focused on the
possible use of diamonds by terrorists to fund their activities.
6 - These four companies
are De Beers Consolidated Mines Ltd., Alrosa Ltd., Rio Tinto, and BHP
Billiton.
7 - Alluvial fields are
surface areas containing secondary deposits of weathered volcanic rock
called kimberlite deposited by river systems.
8 - The World Diamond
Council is an industry association comprising the World Federation of
Diamond Bourses and the International Diamond Manufacturers Association,
which formed this body expressly to address conflict diamonds.
9 - National
certifications schemes have been set up in Angola, Sierra Leone, and
Guinea. The High Diamond Council in Antwerp provides technical assistance.
10 - The report has to be
translated into the working languages of the United Nations before it can
be distributed. This work is almost complete, and the report is expected
to be distributed to U.N. members in New York very shortly.
11 - According to U.S.
Customs officials, these inspections were suspended after September 11,
2001, because the agencies' primary focus has shifted to security and
anti-terrorism efforts.
12 - Essential Elements
of an International Scheme of Certification for Rough Diamonds, With a
View to Breaking the Link Between Armed Conflict and the Trade in Rough
Diamonds (Nov. 29, 2001).
13 - Under the Kimberley
scheme, participants are to ensure that no shipment of rough diamonds is
imported from or exported to a non-participant. However, article XI of the
General Agreement on Tariffs and Trade (GATT), 1994, obligates countries
to refrain from imposing quantitative restrictions or similar measures on
the importation of products from other countries. Two possible exemptions
under GATT are being discussed--article XX provides general exemptions and
article XXI provides a security exemption.
14 - See Standards for
Internal Control in the Federal Government, (GAO/AIMD-00-21.3.1, Nov. 12,
1999), and Internal Control--Integrated Framework, published by the
Committee of Sponsoring Organizations of the Treadway Commission.
15 - According to the
November 2001 Kimberley Ministerial statement, "an internal
certification scheme will only be credible if all participants have
established effective internal systems of control designed to eliminate
the presence of conflict diamonds in the chain of producing, exporting,
and importing rough diamonds within their territories..."
16 - Researchers
reviewing multilateral environmental agreements have noted that
institutional arrangements have come to be seen as crucial to their
effectiveness and that the lack of institutions limits the capacity to
monitor states' implementation of and compliance with treaty requirements
or to take action when noncompliance is ascertained.
17 - According to industry officials, the World Diamond Council will strongly recommend that its member organizations require their individual members to make the following statement on all invoices for the sale of rough diamonds, polished diamonds, and jewelry containing diamonds. "The diamonds herein invoiced have been purchased from legitimate sources not involved in funding conflict and in compliance with United Nations resolutions. The seller hereby guarantees that these diamonds are conflict free, based on personal knowledge and/or written guarantees provided by the supplier of these diamonds."
This document is not necessarily endorsed by the Almanac of Policy Issues. It is being preserved in the Policy Archive for historic reasons.