Responsible Sourcing FAQs

GDL Refiners must obtain an independent Assurance Report on the Intermediate Refiners’ responsible sourcing practices on a comply or explain basis. The assurance should include conformance with an OECD aligned responsible sourcing scheme, be commissioned by the Intermediate Refiner, and be completed before the start of a new business relationship or within a reasonable timeframe of the Refiner implementing the Responsible Gold Guidance (RGG).

LBMA expects GDL Refiners to obtain Compliance, Assurance and Management Reports. GDL Refiners are expected to review these reports and make an informed decision on risks in these supply chains. GDL Refiners must also seek appropriate comfort that any non-conformances have been fully remedied.

LBMA accepts an independent assurance against the Responsible Minerals Initiative (RMI) or against the LBMA Responsible Sourcing Programme. Furthermore, the independent assurance must be conducted by an approved Assurance Provider listed under the relevant scheme.

GDL Refiners must use best efforts to identify the Intermediate Refiners in these supply chains. GDL Refiners are expected to review the supply chain mapping and due diligence undertaken by traders to assess whether red flags have, or reasonably should have been, identified in the Intermediate Refiners’ supply chains. Sourcing should only be undertaken once the GDL Refiner is satisfied that risks are sufficiently mitigated in the Intermediate Refiners supply chain. Where Intermediate Refiners cannot be identified, GDL Refiners should satisfy themselves that the traders supply chain mapping and due diligence has been undertaken using best efforts and responsible sourcing risks are low.

Version 3 of the Disclosure Guidance is effective from 1 January 2026 for reporting cycle 2025 onwards.

GDL Refiners must disclose:

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

Please refer to DG3 for full details on the above points.

Please note that GDL Refiners should continue to conduct risk assessments and due diligence based on the RGG9 integrated risk assessment and continue to report to LBMA the official names and locations, and confirmation of enhanced due diligence, of all RGG9 high-risk suppliers through the Gold High-Risk Suppliers form available via the GBI platform.

For the FY2025 reporting period (i.e. Compliance Reports submitted in 2026), GDL Refiners are expected to disclose the identities of suppliers in ‘Red Flag’ locations as set out in the DG3. For this first year of reporting, these Refiners Transparency Roadmap disclosures (RTR - 2026 disclosures) are exempt from the third-party assurance scope.

Furthermore, GDL Refiners are expected to consult historic FATF grey lists from 2022 onwards to determine red flag locations. It is understood that GDL Refiners, when undertaking risk assessments and requisite enhanced due diligence (EDD) as per Responsible Gold Guidance Version 9 (RGG9), may have only consulted the FATF current list, in line with RGG9 requirements. There may therefore be differences in classification and EDD outcomes of high-risk suppliers per RGG9 and suppliers in red flag per RTR - 2026 Disclosures in DG3. For the avoidance of doubt, RGG9 high risk supplier classification and EDD outcomes are included in the third-party assurance scope. Where differences arise due to the use of historic sources, the EDD outcomes are also exempted from the assurance scope.

A limited assurance.

Yes.

Any Refiner applying to be an LBMA Good Delivery accredited Gold or Silver Refiner is required to implement the LBMA Responsible Gold or Silver Guidance and pass an audit prior to becoming a member of the Good Delivery List. All GDL Applicants must use an assurance provider on the LBMA's Approved Assurance Provider List. Please click here to see the current list in the LBMA Toolkit.

A refiner has to wait five years before submitting their application.

Refiners should use the LBMA Refiners Toolkit to implement the Responsible Gold or Silver Guidance. These documents are intended to enhance the quality and consistency of the Programme Application. Refiners will be asked to justify any deviations from the scope of the Toolkit (on a comply or explain basis).

No. It is up to refiners to establish their own risk assessments and investigations according to their activities.

If a refiner’s certificate appears to have expired but is still listed on the Current Gold List, this means that certification of these refiners is still ongoing. They will remain listed on the Good Delivery List.

Once your assurance report has been received, it can take up to three months before the Compliance Review Panel provides an official response. A member of the Panel may get in touch during that time with any follow up questions. It can take an additional ten days before you receive your certificate. This process will take longer if your assurance requires a Corrective Action Plan to be submitted.

Deadline extensions may be granted under exceptional circumstances. You are advised to get in touch with LBMA as quickly as possible in advance of the deadline.

Precious metals concentrates are process materials from precious metals mining.

Broadly speaking, base metal concentrates are process materials from base metal mining. Precious metals may be by-products of these base metal concentrates.

This is when the material becomes commercially viable to extract the precious metals.

No. Even where material is not sanctioned material, there is a probability that the material can be used to raise finance and circumvent sanction regimes.