ANDREW B. TUCKER
CORPORATE COUNSEL & COMPLIANCE MANAGER
Phone: 865.692.2716
Fax: 865.692.6020
E-Mail: andrew.tucker@jtv.com
November 28, 2022
Re: United States Imposed Russian Sanctions
Dear Valued Trade Partner,
The U.S. State Department recently held an interagency discussion with leading retailers, manufacturers
and laboratories concerning implementation of Russian-focused sanctions and related due diligence.
Correspondingly, JTV would like to highlight and remind you of sanctions the U.S. government has
imposed on Russian persons and goods on account of the Russian Federation’s invasion of Ukraine.
The U.S. Department of Treasury has added numerous Russian individuals and entities to its Specially
Designated Nationals and Blocked Persons List (the “SDN List”). For example, several major Russian and
Russian affiliated financial institutions have been added to the SDN List or otherwise sanctioned, including, but not limited to, State Corporation Bank for Development and Foreign Economic Affairs
Vnesheconombank (VEB), VEB Asia Limited (located in Hong Kong), VTB Bank Public Joint Stock
Company, Public Joint Stock Company Bank Financial Corporation Otkritie, Promsvyazbank Public Joint
Stock Company, Sovcombank Open Joint Stock Company, Joint Stock Commercial Bank Novikombank,
and a multitude of their subsidiaries and affiliates (collectively, “Sanctioned Financial Institutions”). Of
particular note with respect to diamonds, the U.S. Department of Treasury has also listed several Russian
diamond mining companies on the SDN List, including AK Alrosa PAO, Alrosa Group, and Public Joint
Stock Company Alrosa (collectively, “Alrosa”).
Additionally, the United States has enacted an importation ban on diamonds and gold of Russian Federation origin (see footnote). For more detailed information on the United States’ broad and evolving sanctions regime related to Russia (the “Russian Sanctions Regime”), please visit the U.S. Department of Treasury’s Russian Harmful Foreign Activities Sanctions webpage at https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions.
In addition to the Russian Sanctions Regime, you are bound by JTV’s Terms and Conditions (the “JTV
Terms”) by accepting JTV Purchase Orders or listing products on JTV Partner Central. Under the JTV
Terms, you are certifying, representing, and warranting to JTV, among other things, that you and the
products you sell to JTV have no direct or indirect connection to persons designated on United States or
international sanctions lists such as the SDN List and that JTV’s possession or sale of your products will not violate any laws applicable to JTV. Given the Russian Sanctions Regime and pursuant to the JTV
Terms, JTV strictly prohibits being offered for sale, or sold, any products (i) that have a direct or indirect
connection to Sanctioned Financial Institutions, Alrosa, or other individuals or entities sanctioned under
the Russian Sanctions Regime, including any persons owned or controlled by persons sanctioned under the Russian Sanctions Regime, (ii) that are or incorporate diamonds and/or gold of Russian Federation origin, or (iii) that otherwise violate the Russian Sanctions Regime and/or the JTV Terms for any reason
whatsoever.
JTV further asks that you undertake enhanced due diligence measures to ensure that you and the products you offer for sale to JTV are in full compliance with the Russian Sanctions Regime and the JTV Terms. Such enhanced due diligence measures may include, but are not limited to, mine to market analyses, segregation of products, payment and invoice analyses, further inquiries to your suppliers, and further certification from your suppliers.
Please note that, by accepting JTV Purchase Orders, listing products on JTV Partner Central, and/or otherwise selling or offering products for sale to JTV, you are representing, certifying, and warranting to JTV that you and your products are in full compliance with the Russian Sanctions Regime and the JTV Terms, including specifically that the products (i) have no direct or indirect connection to Sanctioned Financial Institutions, Alrosa, or any other individual or entity sanctioned under the Russian Sanctions Regime, including any persons owned or controlled by persons sanctioned under the Russian Sanctions Regime, and (ii) are not and do not incorporate diamonds or gold of Russian Federation origin. Specifically, if you have any doubt as to whether a product violates the Russian Sanctions Regime or the JTV Terms, you must not offer such product for sale to JTV. You must further be prepared to provide JTV with documentation supporting the above representations, certifications, and warranties at JTV’s request and should retain all such documentation for at least 5 years. Such documentation may include, at a minimum, documents like invoices, importation documentation, and/or supplier certifications clearly demonstrating the accuracy of the above representations, certifications, and warranties.
Thank you for your partnership in bringing JTV’s customers the highest quality products at the best possible value. If you have any questions or concerns regarding the above, please do not hesitate to contact me.
Sincerely,
Andrew B. Tucker
Corporate Counsel & Compliance Manage