Responsible Sourcing Newsletter: March 2025

The Year Ahead: Focus on Responsible Sourcing Building Blocks

The start of each year is a time of reflection at LBMA, a time to take stock of critical conversations and emerging trends and shifts in the Responsible Sourcing landscape - and to consider how best to respond to them.

The self-reflection and drive for continuous improvement can take many forms. Sometimes it demands radical change and new requirements, other times it requires a holistic review to examine how current processes can be improved.

And so in reviewing the programme of work for 2025, we decided a focus on foundational “building blocks” as the best way to strengthen the integrity and functioning of the Responsible Sourcing Programme (RSP). This process is guided by our own internal considerations, as well as feedback from valued external stakeholders we received over the course of last year.

These building blocks mostly relate to improvements in mandatory disclosure of information by refiners, recycled gold definitions and classifications, and assurance provider consistency. Once completed, the work will feed into the drafting of version 10 of the Responsible Gold Guidance (RGG).

What do these building blocks look like in more tangible terms?

• Assurance Provider Programme review: To support our work on enhancing consistency amongst assurance providers, we are undertaking a review of the assurance process, from our pre-assurance engagement with Refiners and assurance providers, through to the final review of submitted deliverables, as well as the development of training resources.
• Mandatory Refiners’ Disclosure: Last November, LBMA and other aligned industry schemes participated in a discussion surrounding the public reporting of “red flag” suppliers and locations, as outlined in “Footnote 59” of the OECD Guidance. Moderated by the OECD, this process is primarily comprised of industry schemes and NGOs. A second meeting is slated for the OECD Responsible Minerals Forum in May. Over the course of the year LBMA intends to find agreement among Refiners on disclosing this information and supporting greater transparency.
• Review of definitions: Following on from a process that began in 2024, we are revisiting certain definitions within the RGG to ensure they remain fit for purpose. To date, this process has mostly focussed on material classifications, including capturing investment gold in the country of origin data and updating our definitions of recycled materials.
• ASM: When the ASM Toolkit was launched in 2023, the timelines and benchmarks for progressive improvement requirements were not defined. LBMA hopes to find agreement on these timelines with ASM Taskforce members, so that the document can be aligned and incorporated into the RGG10 drafting process in 2026.

These are important steps that will pave the way during the drafting of RGG10.

Sourcing Advisory: Gasabo Gold Refinery (Rwanda)

The European Union imposed sanctions on a senior Rwandese mining executive and the Kigali-based Gasabo Gold Refinery in late March.

The sanctions follow the recent escalation of the civil war in Eastern Congo by the M23, a Rwanda-backed rebel group. Since January, M23 has made significant territorial gains in both North and South Kivu, the most mineral rich provinces in Eastern Congo, exacerbating one of the longest and most deadly conflicts in the world.

The EU announcement noted: “The Gasabo Gold Refinery…began its refining activities on 1 June 2022 following the closure of Aldango Gold Refinery. The illegal extraction and trafficking of natural resources from eastern DRC, such as gold, contributes to the escalation of the conflict. The transit of gold through the only gold refinery in Rwanda, Gasabo Gold Refinery, contributes to the illicit export via Rwanda of illegally extracted gold. Hence, Gasabo Gold Refinery has been exploiting the armed conflict, instability or insecurity in the DRC, including through the illicit exploitation or trading of natural resources.”

The EU also sanctioned Francis Kamanzi, chief executive officer of Rwanda Mines, Petroleum and Gas Board (RMB) in February on similar grounds.

Gasabo boasts a production capacity of 96 tons per year and some of the most state-of-the-art refining technology on the continent outside of South Africa, with a capability to refine material to purity levels of 999.9.

Until Rwandan officials suspended Aldango’s export license in January 2021, the refinery was a 50-50 joint venture between Aldabra, a company owned by convicted money launderer Alain Goetz, and Rwandan government owned Ngali Mining. Early in March, Goetz lost an appeal of his listing by the US Office of Foreign Asset Control (OFAC).

Good Delivery List refiners and LBMA Members are requested to check their supply chains to ensure they have no connection to either Gasabo Gold Refinery or Mr. Kamanzi. This is especially the case for those with sourcing relationships in the United Arab Emirates where Gasabo Gold Refinery is known to trade.

End of an Era: Farewell to Sakhila

Sakhila Mirza

As many readers will know, Sakhila Mirza (Deputy CEO & General Counsel) is leaving LBMA in April.

Over the decade Sakhila has been with us, she has rightly garnered the respect and admiration within the precious metals market for her contribution guiding LBMA and its wider ecosystem toward better governance and transparency. Her departure leaves some very big stilettos to fill (those who know, know), and the entire LBMA team wishes her only the best in her next chapter. As this “interview” on responsible sourcing in the gold value chain (hosted by the World Gold Council) so aptly demonstrates, her number will remain on speed dial for many of us for a long time to come.

Stepping into that challenge is Sarah Sarvarian, a versatile legal professional with experience in banking, finance, corporate governance, and regulatory compliance.

Supported by the Responsible Sourcing team, she will oversee the day-to-day continuity of the programme while also guiding a restructuring process of the department that should conclude later in the year.

Please join us in extending a warm welcome to Sarah, and please do introduce yourself should the need arise. She can be reached at sarah.sarvarian@lbma.org.uk.