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This policy outlines the framework implemented by Gold Bank to ensure that all precious metals purchased by the business are sourced ethically, responsibly, and legally.
Gold Bank operates as a secondary market bullion dealer, purchasing previously owned precious metals from private individuals and businesses. The company does not purchase newly mined materials directly from mines or mining intermediaries.
Objectives of This Policy
- Prevent the introduction of stolen, illicit, or criminally obtained precious metals into the supply chain
- Ensure compliance with UK financial crime legislation and sanctions regulations
- Align with internationally recognised responsible sourcing frameworks including:
- OECD Due Diligence Guidance for Responsible Supply Chains of Minerals
- LBMA Responsible Gold Guidance principles
- Promote transparency and integrity within the precious metals market
This policy applies to:
- All directors, employees, and representatives of Gold Bank
- All purchases of precious metals conducted by the business
Covered Precious Metal Products
- Gold bullion coins and bars
- Silver bullion coins and bars
- Platinum and platinum group metals
- Scrap precious metals
- Pre-owned investment bullion products
Gold Bank is committed to maintaining a supply chain that does not contribute to:
- Criminal activity
- Money laundering
- Terrorist financing
- The handling of stolen goods
- Human rights abuses
- Environmental harm
- Sanctions violations
Because the company operates exclusively in the secondary market, the metals we purchase have already been refined and circulated. This significantly reduces risks associated with conflict minerals or unethical mining practices.
Nevertheless, robust due diligence procedures implemented to ensure that all purchases are legitimate.
Gold Bank’s responsible sourcing approach follows the five-step framework outlined by the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals.
Step 1 – Establish Strong Company Management Systems
Gold Bank maintains internal policies and procedures designed to ensure ethical sourcing, including:
- Documented compliance procedures
- Transaction monitoring systems
- Record retention protocols
- Staff training on compliance and suspicious activity
Management maintains oversight of the sourcing framework and periodically reviews risk exposure.
Step 2 – Identify and Assess Supply Chain Risks
As purchases occur directly from individuals or businesses in the secondary market, risk assessments are conducted for each transaction.
Potential Risk Indicators
- Sellers unable to provide a reasonable explanation of ownership
- Attempts to sell unusually large quantities of bullion
- Goods appearing recently altered or damaged
- Transactions significantly below prevailing market prices
- Behaviour suggesting urgency or concealment
Where elevated risk is identified, additional due diligence may be performed or the transaction declined.
Step 3 – Implement Risk Mitigation Measures
Where potential risk indicators arise, Gold Bank may:
- Request additional documentation from the seller
- Verify the seller’s identity and address
- Record serial numbers or hallmarks
- Delay or refuse transactions pending further review
Transactions suspected of involving illicit material will not be completed.
Step 4 – Maintain Records and Traceability
Detailed transaction records are maintained to ensure traceability of purchased items.
Records May Include
- Seller identification details
- Description of items purchased
- Weight and purity of metal
- Serial numbers or identifiable markings where available
- Date and value of the transaction
- Method of payment
Records are retained securely in accordance with legal and regulatory requirements.
Step 5 – Periodic Review of Responsible Sourcing Practices
This policy and related procedures are reviewed periodically to ensure alignment with:
- Evolving regulatory expectations
- Industry best practices
- International responsible sourcing frameworks
To mitigate financial crime and stolen goods risks, Know Your Customer (KYC) procedures are applied where appropriate.
Sellers May Be Required to Provide
- Government-issued photo identification
- Proof of address
- Contact details
- Bank details for payment where applicable
These checks ensure transactions are conducted with identifiable and verifiable individuals.
Handling stolen property is a criminal offence under UK law. Gold Bank implements several safeguards to mitigate this risk.
Identity Verification
Where required, the identity of sellers is verified before completing transactions.
Transaction Monitoring
Staff are trained to identify potential red flags, including:
- Unusual selling behaviour
- Attempts to sell items below market value
- Sellers unwilling to provide identification
- Recently modified or defaced bullion products
Suspicious transactions may be declined.
Item Inspection
Precious metal products are inspected where possible to identify:
- Serial numbers
- Mint marks
- Hallmarks
- Signs of tampering
Any goods suspected of being stolen will not be purchased.
Cooperation with Law Enforcement
Gold Bank cooperates fully with law enforcement authorities.
Where there is reasonable suspicion that goods may be stolen or linked to criminal activity, the company may:
- Refuse the transaction
- Retain transaction information
- Provide records to relevant authorities if required
Gold Bank complies with applicable UK sanctions regimes, including regulations administered by the Office of Financial Sanctions Implementation (OFSI).
The company does not knowingly conduct transactions with:
- Individuals or entities subject to financial sanctions
- Persons located in sanctioned jurisdictions
- Persons acting on behalf of sanctioned entities
Where appropriate, sellers may be screened against relevant sanctions lists.
To reduce financial crime risk, transactions may be subject to enhanced scrutiny where sellers are identified as:
- Politically Exposed Persons (PEPs)
- Close associates or family members of PEPs
- Individuals linked to high-risk jurisdictions
Additional due diligence may be conducted before proceeding with such transactions.
Gold Bank operates in accordance with UK legislation including:
- Proceeds of Crime Act 2002
- Money Laundering Regulations 2017 (as amended)
- Relevant financial crime prevention guidance
AML Measures Include
- Customer due diligence
- Monitoring suspicious transactions
- Maintaining transaction records
- Staff awareness of financial crime risks
Payments for purchased goods are conducted through transparent and traceable financial channels where possible.
Gold Bank seeks to avoid practices that may increase financial crime risk, including:
- Anonymous payments
- Structuring transactions to avoid reporting thresholds
- Use of unverifiable third-party payment methods
Employees involved in purchasing precious metals receive periodic training covering:
- Responsible sourcing obligations
- Identification of suspicious transactions
- Recognition of stolen goods indicators
- Compliance with AML and sanctions regulations
- Record keeping and transaction documentation
Transaction and due diligence records are maintained securely for a period consistent with applicable legal requirements.
These records support:
- Regulatory compliance
- Law enforcement cooperation
- Internal risk reviews
This policy is reviewed periodically to ensure it remains consistent with:
- UK legislation
- OECD responsible sourcing guidance
- Industry best practices
Gold Bank is committed to operating a transparent, responsible, and compliant precious metals business.
Through strict due diligence procedures, secondary market sourcing, and alignment with recognised international frameworks, Gold Bank aims to minimise risks associated with illicit precious metals while maintaining trust with customers, partners, and regulators.
Gold Bank is committed to improving ethical, social, and environmental standards within the precious metals trading sector in London.
✓ We maintain a zero-tolerance approach to modern slavery and human trafficking in compliance with the Modern Slavery Act 2015, and we fully adhere to the UK Bribery Act 2010, ensuring integrity and transparency in all our business activities.
✓ We also operate in strict compliance with our Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy, which outlines our procedures for preventing financial crime and ensuring regulatory compliance. This policy is available to view on our website.