Page 25 - Bullion World Issue 7 November 2021
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Bullion World | Issue 07 | November 2021

           o  Advancing standards –          the Financial Action Task Force      transactions, and
              defining best practice         (FATF).                           3.  the provision of support for
              Key initiative: Responsible Gold                                    Artisanal and Small-scale
              Guidance version 9             Given the reliance by the            mining (ASM).
           o  Transparency – improving       international market on the GDL,
              disclosure and reporting       LBMA is well placed to collaborate   In order to address these strategic
              Key initiative: Disclosure     and engage with IBCs, to advance   priorities as a global industry, IBCs
              Guidance                       standards that ultimately aim     should implement the following five
           o  Audit programme –              to address the integrity of the   key recommendations:
              enhancing credibility          precious metals market. The       1.  Effective scrutiny and
              Key initiative: Auditor training   breadth of the activities undertaken   verification of local and regional
              and engagement                 within IBCs and the involvement      supply chains IBCs must have
           o  Artisanal and Small-scale      of international counterparties      visibility of local and regional
              Mining (ASM) – engaging        mean IBCs can be vulnerable to       supply chains, in particular on
              responsibly                    responsible sourcing risks.          recycled bullion to ensure its
              Key initiative: Supporting                                          legitimacy.
              initiatives and leading dialogue  In November 2020, LBMA         2.  Effective regulation of local and
                                             wrote to 12 major IBCs* with         regional supply chains IBCs
           These five key areas are important   recommendations to encourage      must implement stringent rules
           to help build long-term trust and   consistency in responsible         governing local and regional
           credibility in the industry globally.   sourcing standards across      bullion activities.
           While the Programme has achieved   these major trading hubs. Each   3.  Effective enforcement powers
           significant milestones over the last   recommendation supports LBMA’s   IBCs must be appropriately
           nine years, the LBMA recognises   overarching objectives of integrity,   empowered in order to apply
           that much remains to be done,     trust and confidence.                any regulations.
           particularly in the following areas.                                4.  Effective co-operation with
                                             The IBCs operate important           local, regional and international
           1.  Value chain accountability:   market infrastructure for bullion    organisations.
              International Bullion Centre   trading activities. This includes   5.  Develop ASM specific guidance
              Recommendations — Building     trading exchanges; storage           to support and further
              leverage to eliminate gold     facilities; processing, recycling    legitimate ASM supply.
              laundering                     and refining facilities; international
                                             and domestic logistics facilities;   LBMA believes these
           A global effort among all the value   domestic consumption; and     recommendations must be
           chain actors, national authorities,   regulatory oversight. The breadth   implemented and enforced to
           and law and enforcement agencies   of the activities undertaken within   ensure a globally responsible
           is required to continue addressing   these IBCs and the involvement of   supply chain. If an IBC fails to meet
           the outstanding challenges and    international counterparties mean   the recommendations, GDL refiners
           risks.                            these centres can be vulnerable   and other parties throughout the
                                             to responsible sourcing risks.    supply chain could be discouraged
           There are limitations to any audit   Responsible sourcing vulnerabilities  from engaging with that Centre.
           programme. While LBMA can         in IBCs can and will cause a      While LBMA encourages
           effectively remove a refiner from the   negative impact for the financial   responsible engagement, the
           Good Delivery List for Responsible   institutions, refiners, investors,   failure of IBCs to adopt these
           Sourcing failures, unauthorised   mints, jewellery and electronic   recommendations may bring the
           material may still potentially find its   companies who rely on the integrity  legitimate global supply chain into
           way into the Good Delivery system.      of the bullion market.      disrepute.
           To address these limitations, LBMA
           published the International Bullion   The IBC recommendations focus   Over the course of 2021, LBMA
           Centres (IBC) Recommendations     on three strategic priorities:    undertook bilateral outreach with
           that support the OECD Due         1.  the responsible sourcing of   all the IBCs. An initiative of this
           Diligence Guidance framework and     recycled gold,                 magnitude requires extensive
           also responds to key findings from   2.  the elimination of cash    collaboration between many actors

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