Page 8 - Bullion World Issue 1 May 2021
P. 8

Bullion World | Issue 01 | May 2021

           This article summarises the main threats   RECYCLED GOLD
           to the gold supply chain, outlines the   In 2018, 55% of gold processed by   “ In 2018, just 1% of
           Recommendations sent to IBCs, and   LBMA Good Delivery refiners was    LBMA Good Delivery
           considers why international collaboration   recycled compared to about 44%   refiners’ production
           is necessary.                     Large-Scale Mining (LSM). LBMA           was sourced from
                                             recognises the importance of recycling   ASM. LBMA recognises
           2:  THREATS TO THE                for companies in addressing environ-       the importance
                  INDUSTRY                   mental concerns. However, recycled              of engaging
           Not all IBCs operate to the same   gold’s traceability can be problematic   and maintaining
           Responsible Sourcing standards and   as its provenance can be lost from one
           inconsistencies could have a significant   supplier to the next with due diligence   relationships with ASM
           impact on the international market,   standards diverging between counter-         suppliers. ”
           should they remain unaddressed.   parties.

                                             CASH TRANSACTIONS
           Responsible Sourcing vulnerabilities
           can, and will, continue to cause industry   Although several regulatory regimes pro-  requirements. The breadth of the
           fractures and loss of trust  across the   hibit the use of cash for high-value trans-  activities undertaken within IBCs and
           supply chain, regulatory bodies and the   actions, it remains the primary method   the involvement of international counter-
           general public. It is therefore important   of payment in many parts of the world.   parties mean IBCs can be vulnerable to
           to understand the provenance in order   It is therefore vital that jurisdictions have   responsible sourcing risks.
           to safeguard that trust. However, doing   robust anti-money laundering regulations
           so can come at a cost, with some supply   with enforceable oversight powers. This   To help address vulnerabilities to risk,
           chain actors disengaging from high-risk   would also help to reduce the risks of   LBMA is keen to work with IBCs to im-
           sources. In other cases, there is also   smuggling for hand-carried bullion.  plement or demonstrate consistency with
           potential for the provenance  to become                             the Recommendations. Each Recom-
           doubtful, especially in relation to recycled   Sourcing from ASM    mendation represents the overarching
           gold.                             In 2018, just 1% of LBMA Good Delivery   objective of integrity, trust and confi-
                                             refiners’ production was sourced from   dence.
                                             ASM. LBMA recognises the importance
           This means the following key areas re-
           quire urgent action from IBCs to mitigate   of engaging and maintaining relation-  1.    Effective scrutiny and verification of
           threats to the industry:          ships with ASM suppliers. This sector   local and regional supply chains;
                                             provides a livelihood for over 40.5 million   2.    Effective regulation of local and
                                                           people across the       regional supply chains;
                       “  In 2018, 55% of gold             world therefore for-  3.    Effective enforcement powers;
                                                           malising this sector, as
                                                                                   Effective co-operation with local,
                                                                               4.
                 processed by LBMA Good                    opposed to disen-       regional and international
             Delivery refiners was recycled                gagement, will help     organisations;
                    compared to about 44%                  ASM gold enter supply   5.    Develop ASM specific guidance
                                                           chains legitimately.
                                                   ”                               responsible ASM supply.
               Large-Scale Mining (LSM).                                           to support and further legitimise


                                             3:  INTERNATIONAL                 All five Recommendations are supple-
                                             BULLION CENTRE                    mented by a number of requirements to
                                                                               assist IBCs’ practical interpretation of the
                                             RECOMMENDATIONS                   measures set out above.
                                             In order to instil trust in the market, LBMA
                                             has published Recommendations that
                                             support the Organisation for Economic
                                             Co-operation and Development (OECD)
                                             Due Diligence Guidance framework  and
                                             also recognises key findings from the
                                                                                  1 OECD Due Diligence Guidance
                                             Financial Action Task Force (FATF).
                                                                                  for Responsible Supply Chains of
                                                                                 Minerals from Conflict-Affected and
                                             Responsible Sourcing is fundamental to all   High-Risk Areas, version 3, April
                                             parties within the supply chain, who can    2016 (OECD)
                                             all benefit from the assurance that bullion
                                             traded throughout the IBCs is responsi-
                                             bly sourced and aligned to international


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