Responsible Sourcing Newsletter: June 2025

Data and supply chain transparency are sometimes relegated to the realm of the technical and nebulous, the purview of number crunchers and over-zealous civil society activists, with little benefit to the bottom line.

This approach fails to see the wider necessity and practical implications transparency has as a cornerstone of responsible supply chains.

Last week, LBMA launched a public consultation process to amend the current Disclosure Guidance, the document that guides Refiners in what to report in their annual assurance reports.

The consultation comes after LBMA announced plans to fast-track crucial transparency enhancements for Refiners at the OECD Forum on Responsible Minerals in May.

The proposed transparency roadmap LBMA unveiled at the OECD refers to disclosure requirements outlined in Footnote 59 of the Gold Supplement of the OECD Due Diligence Guidance for Conflict Affected and High Risk Mineral Supply Chains.

In a nutshell, from 1 January 2026, LBMA intends to become the first industry scheme to require Refiners to publicly disclose:

• The identity of the Refiner and local exporter in 'red flag' locations as per OECD Guidance;
• All World Gold Council (WGC) miners and mines from which Refiners receive material;
• All locations (countries) from which mined material is received.

The Need for Transparency: RGG v.10 and Global Events

Further disclosures are planned during the drafting of the Responsible Gold Guidance version 10 (RGG v.10) - targeted for 2026 - which will see Refiners move to bring additional transparency to their supply chains. This will include disclosures on the identity of suppliers, locations (countries) and total volumes of all mined material (not just those from WGC members). These disclosures will be made irrespective of the risk rating of either supplier or location. LBMA has further committed to release the identity of all suppliers in high-risk locations as defined in RGG v.10.

Those that might be tempted to dismiss the significance of this process as LBMA simply satisfying the fine print of an obscure footnote are overlooking the bigger picture.

Two reports by well respected authors landed last month that brought home why transparency matters, and is, in fact, very much in the self interest of GDL Refiners and all participants in the wider precious metals market.

Writing in Foreign Policy, Sasha Lezhnev and John Prendergast of the Sentry highlighted how the continued trading of illicitly mined gold in Sudan was facilitating continued war and repression. They estimated as much as $1 billion worth of gold was smuggled into the UAE alone from the war-torn country in 2023.

One of their main recommendations?

“The United States, led by Secretary of State Marco Rubio, should … work with the gold industry to establish and lead a public-private illicit gold initiative that can publish real-time data on the gold trade and independently monitor and certify trading centres. Rubio, together with U.S. Treasury Secretary Scott Bessent, should create an illicit-gold task force that can investigate and sanction gold-trafficking networks and exchange data on these networks with banks and refiners. In the absence of such measures, illicit gold will further infiltrate global markets and fund war and criminal gangs.”

A second piece by Thierry Vircoulon, a longtime observer of African affairs for the Institut Francais des Relations Internationals (IFRI) looked at Russia’s growing presence in Africa and how that relationship was helping Moscow to circumvent Western economic sanctions with ease.

Vircoulon wrote: “The biggest mystery in Russian-African trade is gold, which plays an important role in Russian monetary strategy. Although it is difficult to estimate volumes, Africa is probably Russia’s largest gold supplier. Russian gold import networks consist of official companies, such as NordGold operating in Guinea and Burkina Faso, and mafia-like paramilitary organisations, such as the Wagner Group, which operates several gold mines in the Central African Republic. Before the outbreak of war in Sudan, the Wagner Group was involved in gold trafficking, thanks to its alliance with General Hemedti’s rebel forces, who control gold-mining areas. But in Sudan and Burkina Faso, ongoing conflicts have significantly impacted gold mining. NordGold had to close its Taparko mine for security reasons in 2022, while international sanctions forced this company to change refiners and conceal its exports through intermediaries.”

Add to this, recent reports that the military junta in Mali plans to construct a 200 tonne capacity refiner in partnership with Russian conglomerate, the Yadran Group. Once operational, the refinery intends to process material from across the gold-rich yet democratically challenged Sahel region.

Increasingly Digital: Gold Bar Integrity and Supply Chain Technology

LBMA’s move to enhance the chain of transparency and introduce the Gold Bar Integrity (GBI) platform to track gold flows coming into our Refiners is an effort to use our leadership position to advance accountability and ensure a more ethical gold trade. The motivation is simple: a lack of supply chain transparency undermines market and public confidence in the gold industry.

By understanding and disclosing “red flag” suppliers and localities, external stakeholders and other market participants can have additional comfort that appropriate due diligence and oversight has been done on suppliers operating in higher risk jurisdictions. Transparency is an important antidote with which to build trust, demonstrate supply chains are free of OECD Annex II risks and provide clearer line of sight of where Refiners source their material.

But as we made clear when we unveiled our transparency roadmap at the OECD, LBMA cannot do this alone. Given the increasing complexity and interconnectedness of the precious metals industry, other industry schemes and trading hubs are encouraged to follow suit and match our proposal so that nefarious actors that threaten the integrity of the global market cannot game the system..

So far the response is positive. The OECD, which is moderating discussions on industry schemes meeting Footnote 59 requirements, has committed to another meeting later this year. Collectively, we can raise the bar on transparency, and shift the conversation to where the risks and need for improvement is needed most.

Have Your Say

As mentioned above, earlier this month we launched a consultation process to amend the Disclosure Guidance to reflect the Footnote 59 requirements. We encourage interested parties to participate in this process. Your feedback is very much welcomed and appreciated.

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