RESPONSIBLE GOLD. Overview, Update and Next Steps 2015

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1 RESPONSIBLE GOLD Overview, Update and Next Steps 2015

2 SCOPE LBMA/RJC Responsible Gold Forum 01 Responsible Gold Development 02 Industry Harmonisation Implementation Process Audit Implementation 03 LBMA Next Steps 2

3 LBMA RESPONSIBLE GOLD GUIDANCE Purpose & Structure To ensure London Market is free from metal that had financed conflict or been used for money laundering or terrorist financing. Global, long term focus. OECD + KYC, AML + mandatory audits = All feedstock (mined production, scrap, investment bars) subject to due diligence and audit. Risk-based: Higher risk = more due diligence is needed (and vice versa) All production (large bars, kilo bars, scrap etc.) therefore conflict-free. Focuses on conflict-free process, not conflict-free product. 3

4 OECD GUIDANCE Internationally recognised global framework Recognised by the SEC Rules. Encourages responsible engagement in worldwide conflict areas, including DRC. Provides internationally recognised framework for all actors to engage in conflict areas responsibly on a global level. The LBMA is currently Co-facilitator for the OECD Multi-Stakeholder Group (MSG). 4

5 RESPONSIBLE GOLD GUIDANCE LBMA & GD Refiner Implementation LBMA Responsible Gold Guidance (RGG) Developed and recognised. Refiner, Industry and Public Consultation conducted. RGG - Official requirement of London Good Delivery Refiners accept & implement Steps 1-3 Audit Guidance Refiner, Industry & public consultation Mutual Recognition Achieved with LBMA/RJC/EICC Audit Guidance & consultation crucial to achievement Audit Guidance finalised Q1 Refiners accept & implement Steps Audit Reports Submission & Review Auditor Training & continued refiner support Continued Cooperation with industry programmes, 2013 Audit Reports Submission & Review Development of refiner & bullion bank best practice guides (2013/14) Independent Third Party Auditor requirement no longer allows use of government bodies 2014 Audit Reports Submission & Review All 73 Good Delivery refiners undergone RGG Audit Version 6 of RGG released. Includes Country of Origin disclosure OECD Audit of LBMA RGG Programme due in Q Audit Reports Received Continued support & implementation of OECD 5

6 RESPONSIBLE GOLD GUIDANCE Audit Implementation Third Party Audit Guidance The Third Party Audit Guidance provides transparency and consistency for the Responsible Gold programme. List of Approved Auditors The LBMA has published a list of Approved Auditors. Any independent, certified auditors are eligible to conduct the LBMA audit, provided they have the required credentials. 6

7 GOLD INDUSTRY INITIATIVES Support & Recognition throughout gold supply chain Miners Refiners Jewellers RJC Chain of Custody Covers All Actors 7

8 MUTUAL RECOGNITION For Refiner Audits Achieved Sept 2015 LBMA RJC CFSI (EICC) Common Features: 3 rd Party Audit, OECD & SEC Compliance Tailored Focus London Bullion Market Jewellery Supply Chain - Mine to Retail Manufacturers Audit outcome Continued Good Delivery Accreditation CoC Certification Validated Smelter/ Refiner list Harmonisation RJC CoC, CFS audits = Responsible Gold Requirement. LBMA, CFS =. RJC, LBMA audits = CFS. One Audit Report Three Programmes World Gold Council, Fairtrade and Fairmined initiatives support refiner due diligence. 8

9 RESPONSIBLE GOLD GUIDANCE VERSION 6 The story so far All 73 LBMA GDL gold refiners are compliant More choice of auditor firms Separate offices of global firms, increase in organisations wanting to carry out audit. Increased competition, increased variety. Continuous improvement. Enhancing mutual recognition E.g. CFSI and mutual refiners encouraged to do the LBMA audit due to AML aspect. Recognition by CME LBMA RGG programme, is recognised by the exchange. EU draft Conflict-Free regulation Extensive engagement with EU commissions, parliament and member states to facilitate recognition of the LBMA RGG. 9

10 RESPONSIBLE GOLD GUIDANCE VERSION 6 What s new in Version 6 Onsite visits for high-risk sources Reduction of time-frame from 12 to 6 months RGG introduced in 2012 should have performed EDD/site visits by now New accounts/changes in circumstances Country of Origin Reporting Disclosure ISO v ISAE (annex) Global regulatory requirement (CSFI/Dodd-Frank) Further enhance Mutual Recognition Corrections, alignments and issues of clarity. 10

11 RESPONSIBLE GOLD GUIDANCE VERSION 6 Approved Auditors Increased List (variety and choice) Expanded Geography Competition Only Local Office recognition Regular review/quality Control Government agencies removed 11

12 RESPONSIBLE GOLD GUIDANCE VERSION 6 Current versus Future state The Current State of Affairs All 73 refiners Progress on Reviews Associate (Non-GDL) refiners All new GDL applications Recognition/Licensing Future State Continuous improvement Fit for Purpose European Union OECD Conformity of Best Practice 12

13 NEXT STEPS Refiner Support & Bullion Bank Implementation Best Practice Guides for Refiners: Criteria/Indicators for determining High-Risk & Conflict-Affected Areas Guidance on how best to conduct KYC for scrap Templates Other, as needed Regular webinars/seminars to address implementation challenges Developing KYC best practice guide for bullion banks in order to ensure they are compliant with the OECD, SEC due diligence rules. 13

14 Contacts

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