Following the suspension of Russian refiners and the imposition of sanctions, there has been increased attention on Refiners’ Responsible Sourcing third-party audits to guarantee Russian material is not entering the market. To reiterate, all Good Delivery List (GDL) Refiners are expected to comply with UN, EU, US, UK, or any other relevant economic and/or trade penalty lists under the LBMA Good Delivery Rules.
Any violation of the applicable sanctions list (for example, GDL refiners engaging with a sanctioned firm) will result in removal from the Good Delivery List. Removal might take the form of a suspension or permanent de-listing. Individual organizations must ensure that they undertake their own due diligence approach in order to get comfort and stay up to date on any new punishments issued by the government.
The Gold Bar Integrity initiative has achieved significant progress. A Request for Proposal (RfP) was issued, with invites only extended to service providers with significant industry knowledge and contacts in the precious metals sector, and proposals are currently being reviewed by independent market consultants.
A Steering Group was formed, and a scorecard was created to allow the Steering Group to benchmark the summary of the ideas prepared by the consultants, allowing them to make recommendations on which proposals to forward through the process.