Features

Camille Cleveland – Blue Nile

GCs and Diamonds: The more multifaceted, the better

Camille Cleveland knows diamonds aren’t just beautiful—they’re entangled within a complex web of local and global rules and policies. As the general counsel of Blue Nile, one of the largest online diamond and fine jewelry retailers, she needs to stay abreast of sometimes rapidly changing regulations, especially those set forth by the Office of Foreign Assets Control.

According to her, Blue Nile offers over 650,000 high-quality, conflict-free, Gemological Institute of America-graded diamonds alongside other fine jewelry. The conflict-free part is extremely important not just to Blue Nile and its customers but also to the OFAC.

Nearly 15 years ago, when the ethical issues of diamond mining in Africa came to light, many—if not all—diamond suppliers, sellers and other vendors switched to other areas and miners. One of those was Russia’s leading mining and distribution company Alrosa, responsible for 90 percent of the country’s diamond mining capacity.

This became problematic after Feb. 24, 2022, when Russia escalated the war—begun in 2014—through its invasion and occupation of Ukraine. While Blue Nile never purchased diamonds from Russia, Cleveland had to triple-check that none of its diamond vendors did.

That’s because, in response to Russia’s actions, the U.S. Department of the Treasury’s OFAC acted swiftly and, that same day, announced sanctions against the country. In April 2022, it released sanctions specifically barring any financial or business dealings with Alrosa.

“I wasn’t working alone on Blue Nile’s and its vendors’ compliance with these federal sanctions,” Cleveland says. “It was—and continues to be—an industry-wide, global effort.”

The clarity of diamonds and compliance

To adhere to changing OFAC regulations, Cleveland and others at Blue Nile worked closely with the Jewelers Vigilance Council, a trade organization in the diamond industry. Of course, Blue Nile already had policies and procedures in place that could be applied in this situation, such as its anti-money laundering policy.

In 2022, Cleveland had to tackle these sanctions several times and untangle the complicated, global legal web surrounding the retail world of diamonds. When OFAC released the sanctions against Alrosa, Bain Capital owned Blue Nile. Four months later, Signet Jewelers purchased the company and had its own set of vendor compliance rules in addition to OFAC’s. For nine months following the acquisition, Signet was deeply involved in ensuring that everyone at Blue Nile, from staff to vendors, was compliant with all regulations.

“My legal team and I worked hard to keep all our members updated, offered legal advice and implemented compliance at the company level,” Cleveland says. “I was brought on to not just handle legal issues but function as a business partner, and that’s exactly what I continue doing during this time.”

Matters are still complicated, and Cleveland remains vigilant. When speaking with Vanguard in April 2023, she mentioned that a new set of stricter, more restrictive sanctions was most likely coming and that OFAC was trying to address an existing loophole. She explains that while OFAC banned the importation of Russian-origin diamonds, it determines the origin of diamonds as the place where the gem is cut and polished. This means the diamonds mined in Russia—usually sent to India—are considered to be of Indian origin.

“Of course, this is a tiny part of the compliance and privacy matters my team handles for the company, but it’s a vignette of the type of issues we handle daily,” Cleveland says.

The center stone of compliance

Building out the compliance department was one of Cleveland’s first tasks when hired in March 2020. She overhauled it almost immediately to ensure that human resources and trade compliance were in good shape.

She and her team also updated the employee handbook. While the existing version was relevant, she wanted to take a more holistic approach to employee-employer relations. She, her team and outside counsel occasionally worked together to revise, replace or add essential information, such as confidentiality stipulations regarding severance, employee engagement and noncompete and nondisclosure clauses.

She and her team also reworked the employment manual for Blue Nile’s Ireland and China operations.

“Blue Nile’s compliance program was nascent when I joined, so I worked fast and drew upon my nearly 30 years of experience setting up robust programs,” Cleveland says.

A significant part of compliance at the mainly online retailer is privacy. Blue Nile must follow the European Union’s General Data Protection Legislation, which became effective in May 2018 and is constantly updated, as well as regulations across states. This includes the California Consumer Privacy Act, which became effective in January 2023, with new rules released in March.

She implements the most restrictive best practices to ensure the company is covered.

“The legal team makes certain Blue Nile adheres to the rapidly evolving laws, so it can keep growing and offering customers the best diamonds and fine jewelry,” Cleveland says.

A polished career

While diamonds may be a new addition to her career portfolio, Cleveland has decades of broad legal experience as a general counsel.

She’s helped many companies—Big Boy Restaurants, Ticketmaster, Papyrus and A Place for Mom—navigate bankruptcies, mergers and acquisitions, and many legal matters. She assisted Blue Boy Restaurants with a major restructuring, Papyrus with its acquisition of American Greetings and worked on three other significant M&A deals throughout her career.

She applied that knowledge and expertise during Signet’s $360 million acquisition of Blue Nile in August 2022. She’s implementing and integrating Signet’s operations, rules, policies and procedures.

“We’re trading institutional knowledge,” she says.

She adds that she’s been lucky to have such a diverse career and partly credits that to the wonderful people she’s known. She’s always been looking at what’s next, which is how she ended up at Blue Nile.

“Joining Blue Nile has been a wonderful opportunity to apply my legal skills—and, after all, who doesn’t love diamonds?” Cleveland tells Vanguard with a laugh.

View this feature in the Vanguard Summer III 2023 Edition here.

Published on: July 6, 2023

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