Compliance Cozy Chats - The 3C's Series

We are launching a Podcast where we will interview someone within our industry on topics which may be relevant to some or, potentially, to all of you. This will be a dynamic project and we will feed off your subject requests and value feedback as we progress the initiative.

Global Precious Metals Code

A reminder that all members are required to attest to the Global Precious Metals Code in 2023. For ease of reference, a pro-forma attestation can be found in Annex 5 of version 2 of the Code.


In Singapore, the Monetary Authority of Singapore (MAS) published a consultation paper on a proposed code of conduct for environmental, social and governance to raise standards and disclosures of ESG rating in Singapore. The consultation runs until Tuesday, 22 August.


Further to our update in the 108th edition of the Alchemist, the UK Parliament passed the bill to extend the UK REACH submission deadlines on Wednesday, 19 July 2023.

This will extend the statutory deadlines for transitional registrations to 27 October 2026, 2028 and 2030 respectively.

EU Benchmark Regulation (BMR)

BMR allows supervised entities in the EU to use non-EU benchmarks in the following three cases only: recognition, endorsement, and equivalence.

BMR rules are currently suspended to allow EU supervised entities to continue to use non-EU benchmarks until 31 December 2023, irrespective of whether they are on the European Securities and Market Authority (ESMA) register.

On 14 July, the European Commission extended this suspension until 31 December 2025.

Germany Supply Chain Legislation

The Supply Chain Act came into force in Germany on 1 January 2023. Many companies will have to make adjustments in the area of due diligence, risk management, and supply chain considerations. We made reference to this in our June Regulatory Newsletter.

If you would like to discuss any of the above points - or, for that matter, any other regulatory issue - please feel free to reach out to me at or

I look forward to meeting with many of you over the summer, and at our Global Precious Metals Conference in Barcelona.

Best Wishes,

Graham Jelf,
Compliance Officer