Review Process Case Studies

PwC Belgium has been removed from the Approved Service Providers List, effective Friday, 13 June 2025. This action has been taken while clarification on ongoing matters remains underway.

Arkan and Ergin (Turkey) has been removed from the Approved Service Providers List, effective Thursday, 13 February 2025. This action was taken as they no longer satisfy LBMA's Service Provider requirements.

The Incident Review Process (IRP) has been invoked to review matters that have been raised during Umicore’s assurance process. This process involves consultation with a range of stakeholders, alongside a peer review. LBMA remains focused on a transparent and rigorous approach and will advise of further updates in due course.

Umicore remains a Good Delivery Refiner. Umicore has made the following statement:

"Umicore PMR takes duly note of the decision made by the LBMA and will fully cooperate in order to resolve this matter soon and to take appropriate measures for further improvement. Umicore PMR has implemented a robust due diligence process for its business partners over the years, which has continuously evolved. Umicore PMR is confident that this review and the conclusions out of it, will inspire further enhancements to our processes.”

An IRP was launched against PT Aneka Tambang Tbk (Logam Mulia) in June 2024 following the launch of a criminal investigation by the Indonesia Attorney General’s Office. The investigation is looking into concerns about the actions of former general managers relating to the Refinery’s brand stamping operations from 2010 to 2021.

The IRP is ongoing at the time of writing and LBMA will provide further updates once the review process has concluded. The Refiner is cooperating fully with LBMA.

In June 2024, LBMA moved to immediately revoke the membership of VPower after its designation on a Russia-related sanctions list maintained by the US Office for Foreign Asset Controls (OFAC).

The Incident Review Process (IRP) was invoked against Dowa Metals & Mining Co Ltd in August 2023 following a review of the true country of origin of precious metals contained in base metal concentrates. Following the conclusion of the IRP, LBMA did not find any instances of zero-tolerance nonconformance.

On 14 July 2023, Emirates Gold, an Affiliated Member based in Dubai, was suspended after a due diligence review.

Hindustan Zinc Ltd was suspended from the LBMA Good Delivery List on 18 July 2022 for failing to meet the requirements of the Responsible Sourcing Programme. The Refiner was reinstated to the GDL on 4 October 2022, following the satisfactory submission of its 2021 annual Assurance Reports. All silver refined during the suspension is considered compliant with the GDL Rules and, therefore, is Good Delivery.

The Incident Review Process (IRP) was invoked against Korea Zinc Co Ltd in August 2023 following a review of the true country of origin of precious metals contained in base metal concentrates. Following the conclusion of the IRP, LBMA did not find any instances of zero-tolerance nonconformance.

The Incident Review Process was invoked against The Perth Mint on 9 March 2023, following media allegations about The Perth Mint’s historical conduct.

The IRP focused on The Perth Mint’s conformance with LBMA requirements, and concerns regarding the refining quality at its assay lab were found to be unwarranted and in keeping with industry practices. As an iterative process, this IRP involved extensive discussions with the Refiner, auditor and market participants.

The IRP found no zero-tolerance non-conformances, and The Perth Mint remained on the Good Delivery List. Elements of The Perth Mint’s management systems continue to be strengthened through its remediation plan.

In October 2021, Brazilian media reported that one of Chimet’s suppliers, CHM, had illegally sourced gold from protected environmental and indigenous lands in the Amazon.

The Italian Refiner immediately implemented a mitigation strategy that included suspending its relationship with CHM, seeking a legal opinion regarding its legal obligations and jeopardy.

The legal opinion concluded that there was no evidence of any involvement in or knowledge by Chimet of the alleged illegality perpetrated by CHM, and that under Brazilian law, the legal onus lay with the supplier to guarantee the accuracy of provenance claims. The opinion further concluded that the Refiner could not be held responsible for the illegal behaviour of others.

The annual audit by Deloitte Italia found no fault with the Refiner’s sourcing practices or the way it responded to the allegations against CHM.

LBMA did not invoke an Incident Review Process in this instance because it felt that Chimet’s proactive response was consistent with both the OECD Due Diligence Guidance and Responsible Gold Guidance, which call for remediation in instances of sourcing challenges. LBMA further noted that at no time have Brazilian authorities sought to question or implicate Chimet in any wrongdoing.

In June 2021, the 11-step Incident Review Process (IRP) was invoked against Kyrgyzaltyn JSC in response to issues concerning the non-delivery and potential for fraud related to a gold shipment from the Kyrgyzstan-based refinery.

While the IRP was still underway, the refiner was suspended from the Good Delivery List in September 2021 for failing to meet the requirements of the Responsible Sourcing Programme, most notably the submission of its annual audit reports.

While the dispute of the gold shipment was settled through legal remedy with the affected parties (and allegations of fraud not proven), LBMA engaged Kyrgyzaltyn in a lengthy dialogue that culminated in the refiner submitting its audit reports and successfully completing a Corrective Action Plan.

Kyrgyzaltyn was reinstated to LBMA’s Good Delivery List (GDL) on 3 May 2022.

In May 2018, the USA imposed trade and economic sanctions on Venezuela. Subsequently, LBMA received an anonymous grievance from a whistle-blower and a number of third-parties, following prominent news stories alleging that Venezuelan gold was exported to Turkey for refining/conversion to help bypass the sanctions. In order to be able to refute any link to the Turkish refiners on the GDL, an independent auditor was engaged to undertake a limited scope engagement of the Turkish GDL refiners, based on the ISAE standards.

The scope of the audit was limited to the matter of confirming that there had not been any trade or business of gold between those GDL refiners and Venezuela. The audit sought to confirm the completeness and accuracy of the public statements and the Country of Origin data provided by the GDL refiners as part of their original 2018 audits. This review also included an assessment of the management systems and controls to confirm whether the GDL refiners were able to comply with the requirements on an ongoing basis.

The independent audits confirmed that those GDL refiners had not sourced from or traded with any entities dealing with Venezuelan gold.

LBMA’s Compliance Panel rejected the first 2018 RGG audit submitted by the GDL refinery due to a lack of confidence in the findings. LBMA consequently appointed a different Approved Auditor for a re-audit, who identified two high-risk non-conformances relating to steps 1 and 2 of the RGG. This broadly required formalisation of the due diligence processes and clarity on roles and responsibilities as well as escalations. This also triggered the requirement for a Corrective Action Plan to then be followed up with another audit within 90 days. LBMA also visited the GDL refinery to discuss how the non-conformances were being addressed as a high priority.

The GDL refiner was fully engaged throughout the process and was transparent in its disclosure. After the final re-audit, and through review by the Compliance Panel, LBMA issued a RGG certificate to confirm compliance. The 2018 re-audit and follow-up audit, together with the 2019 certification, were positively achieved and are available on LBMA’s website.

LBMA invoked an IRP in June 2019 in response to the human rights and environmental allegations relating to the North Mara mine in Tanzania (formerly owned by Acacia Mining).

While details of this process have been already been covered in the 2020 Responsible Sourcing Report, we highlight it again because of the ongoing commitment and engagement by both the refiner and miner to prevent and mitigate potential and actual adverse impacts. This is evidenced by the continued appointment by the refiner of independent expert consultants to monitor and provide suggestions on ways to mitigate potential risks. This is a high risk mine dealing with legacy issues that will require continual engagement between stakeholders and, as such, represents a model others in similar circumstances may want to emulate.

An IRP was invoked in June 2020 in response to media allegations regarding the Perth Mint sourcing from an aggregator in Papua New Guinea (PNG). Engagement with the refiner and its auditors confirmed that while The Perth Mint had suitable systems and controls in place, LBMA considered that “there was a lack of clarity” in the application of The Perth Mint’s policies and procedures to a particular gold aggregator in PNG. Notably, the refiner’s country and risk assessment procedures did not flag the need for an in-country assessment due to an assessment process weighted to country rather than counterparty risk. As part of the IRP, a second special audit was undertaken with an audit firm chosen by LBMA. The initial auditor was removed from the list of LBMA approved auditors. While no zero-tolerance non-conformances were identified, a Corrective Action Plan was put in place to address improvements to the refiner’s management systems. The Perth Mint fully complied during the IRP and implemented all the required improvements outlined in the Corrective Action Plan in October 2020. Subsequently, The Perth Mint has introduced additional measures above those identified in the CAP to further enhance their risk assessment processes.

The 2018 data included a significant increase in recycled gold sourced from the United Arab Emirates (UAE). Given that LBMA classes the UAE as a high-risk jurisdiction, the report was escalated to the Compliance Panel. LBMA required a Special Audit focused on the GDL refiner’s transactions of materials received from the UAE in 2018. The Special Audit did not detect any non-conformances. The auditor concluded that the GDL refiner’s 2018 Compliance Report, in all material respects, described fairly the activities undertaken during the year to demonstrate compliance. LBMA issued the 2018 RGG certificate in December 2019. The 2018 Special Audit report is published on LBMA’s website.