Responsible Sourcing Newsletter: Uniting Markets, Assurance Programme Enhancements & CoO Reporting Framework

In this newsletter, LBMA shares the appointment of Nirali Shah as our new Sustainability & Responsible Sourcing Director, announces a refresh of its International Bullion Centre Engagement Strategy, presents enhancements to its Assurance Programme with a standardised Approved Assurance Provider (AAP) Toolkit, and provides an update to the Country of Origin (CoO) Reporting.

Nirali Shah Appointed as Sustainability & Responsible Sourcing Director at LBMA

LBMA is delighted to let you know about the appointment of Nirali Shah as its new Sustainability & Responsible Sourcing Director. With over two decades of experience in sustainability, responsible sourcing, and assurance within the precious metals sector, Nirali brings deep practical expertise to further LBMA’s mission of advancing integrity and transparency in precious metals value chains.

“I am thrilled to join LBMA in this new capacity at such a pivotal moment for sustainability and responsible sourcing," said Nirali. "I have championed corporate integrity and sustainability throughout my career and I now look forward to working with the LBMA team and our stakeholders to drive meaningful industry-wide advancements.”

For more information on Nirali's background and expertise, please visit the LBMA Newsroom.

Gold Should Unite Markets, Not Undermine Them

Ruth Crowell speaking at the Dubai Gold Conference

Late last month, Ruth Crowell (CEO, LBMA) and Nirali Shah (Director of Sustainability and Responsible Sourcing, LBMA) attended the Dubai Precious Metals Conference to raise the case for better convergence and cooperation between leading actors in the precious metals industry.

Illicit flows erode trust in global supply chains and weaken market resilience. For economies reliant on gold revenues, the risks are real - and growing.

It’s time for every gold hub to lead.

Five years ago, LBMA set out clear recommendations for International Bullion Centres. While progress has been made behind the scenes, today - with gold well above $4000/oz and new sourcing threats from emerging conflict zones like Sudan or the Sahel - the need for collective action is greater than ever.

LBMA has taken several concrete steps to increase governance and transparency in gold supply chains since our initial IBC announcement in 2020. The Responsible Gold Guidance version 9 (RGG9) introduced new requirements for intermediate refiners based in high risk locations that supply GDLs to undergo an OECD aligned assurance. We launched the ASM Toolkit to address the market avoidance and lack of appropriate due diligence over a significant source of feedstock to global gold markets. This month, we will publish an updated Disclosure Guidance that makes LBMA the first industry scheme to meet the transparency requirements governing OECD Red Flag locations.

LBMA is refreshing our original IBC recommendations, starting with discussions in the UAE to jointly update recommendations and practical next steps.

Our focus is on ways to:

• Tackle risks in hand-carried gold
• Formalise transaction systems
• Increase transparency in governance and enforcement
• Support ASM through responsible frameworks

Criminality has no place in gold hubs. It impacts all of our reputations, irrespective of where it happens.

Looking ahead to 2026, LBMA will announce further details early in the new year on how we plan to advance cooperation and practical solutions with partners in key International Bullion Centres.

Assurance Programme Enhancements: Key Updates

By Amardeep Rihal (Policy Manager, LBMA)

Turning back to 2025, enhancing the assurance programme has been a key focus this year. We have introduced a number of measures - covering training, tools and guidance - to support Approved Assurance Providers (AAPs) and, in addition, strengthen the Responsible Sourcing Programme. Here’s what’s new:

AAP Terms & Conditions

We have introduced significant updates to the AAP application process. The AAP form is structured into the following three key components:

• AAP Terms & Conditions: Introducing a robust framework, including higher entry thresholds;
• Applicant Firm Core Competency Form: Aligned with ISAE 3000 and ISQM 1 standards, this form sets comprehensive requirements for ethics, independence, and quality management, alongside firm attestations;
• Individual Applicant Capability Form: A new addition designed to capture technical skills and practical experience. Applicants will self-assess proficiency across four levels.

AAP Toolkit

The AAP Toolkit is a series of templates and forms designed to provide AAPs with a standardised structure for assurance planning, execution and reporting. Centred in advancing consistency, transparency and quality across assurance engagements, the AAP Toolkit will be used for assurance engagements from 1 January 2026.

AAP Training

This year, we introduced case study focus sessions to explore both contextual supply chain risks and the use of investigative approaches to identify and assess scenarios. These were designed to further support AAPs to think critically and challenge Refiners during the assurance process. Rolled out across six half-day sessions, over 125 AAPs attended the training.

Refining the Standard: LBMA Launches Periodic Country of Origin Reporting Framework

By Varsha Peiris (Standards and Assurance Manager, LBMA)

LBMA has introduced periodic reporting of Country of Origin (CoO) data. As announced at LBMA’s 2025 Global Precious Metals Conference in Kyoto, next year will be the implementation year for periodic reporting, and 2027 will be mandatory - where all Good Delivery List Refiners will be expected to report their CoO data monthly via the Gold Bar Integrity (GBI) platform.

CoO data has been a requirement under the Responsible Sourcing Programme since 2018. However, as assurance expectations evolve, LBMA has moved to make CoO data a strategic tool for ongoing due diligence and risk detection efforts.

In the current framework, refiners are expected to report CoO data as part of their annual Assurance Deliverables. This requirement will remain unchanged. However, the increasing complexity of sourcing landscapes and the need for early visibility over supply chains in high-risk locations have highlighted the value of periodic reporting.

Why Is Periodic Country of Origin Reporting Important?

First, it provides LBMA with earlier visibility of significant sourcing shifts - such as changes in supplier geography or introduction of new jurisdictions. When data is only reviewed annually, these shifts can go unnoticed until the next assurance cycle, by which point issues may have already escalated.

Second, from a governance perspective, it strengthens transparency and the need for continual due diligence.

Third, it reframes CoO reporting as an active risk management tool.

Periodic reporting facilitates more agile responses to market changes and faster decision-making.

2026: Your Window to Trial Monthly Country of Origin Reporting

All Refiners are encouraged to take the opportunity next year to test the new reporting requirements, to ensure any issues can be highlighted and fixed in time for mandatory reporting in 2027.

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