Selling gold doré to an LBMA refiner: the file decides the terms.

What’s changing

With gold trading around $4,000 an ounce through October, small and restarting mines have every reason to sell, and to sell well. Selling well usually means selling to an accredited refiner. Before it can buy, that refiner must check who you are, where your gold comes from and how it moves.

Three developments since June make that check harder to pass on a thin file.

• New rules for refiners. LBMA opened consultation on version 10 of its Responsible Gold Guidance (RGG10) on 10 June. A second round closed on 16 October. The final text is due in December, with a transition year from 1 January 2027.
• A refiner’s standing depends on its suppliers. On 5 August LBMA suspended Shandong Gold Smelting from its gold and silver Good Delivery Lists, pending review, after the refiner was added to the US forced labour Entity List. It showed how directly a refiner’s own market access depends on its supply chain.
• Exporting countries are tightening too. In Ghana, since 1 September, doré bought by self-financing aggregators must be refined locally, at a refinery GoldBod approves, before it can be exported.

What a refiner must check before it buys

Accredited refiners work to the LBMA Responsible Gold Guidance. For a mine, the starting point is LBMA’s KYC Questionnaire for Mined Material. It runs to nineteen sections, but the refiner is really asking three questions.

1. Who owns and runs the mine? Registration, mining licence and, where needed, export licence. Every owner of 10 per cent or more identified, with photo ID, and screened.
2. Where does the gold come from? The mine’s location, production and methods, and proof of mining origin for each shipment, along the route to the refinery.
3. How is it paid for and protected? Payments above $10,000 through banks, not cash. Who provides security at the mine and on the road, and whether artisanal miners work on or near the concession.

Where the answers point to high risk, for example artisanal material, mercury use or a route through a conflict-affected area, the refiner must carry out enhanced checks. That includes a visit to the mine before trading, or at the latest within six months of starting.

What RGG10 adds

The draft keeps the core checks and widens them. The text may still change before December, but the direction is clear.

• The route counts more. Gold that has passed through a high-risk location is treated as high risk, as is gold declared from a country that conflict gold is known or suspected to pass through.
• Owners count more. Owners with interests in high-risk locations, or who hold public office, raise the risk rating of the mine itself.
• Environment and climate are in scope. Tailings, biodiversity and greenhouse gas measurement sit alongside labour and safety. Refiners must encourage mines that use cyanide to follow the International Cyanide Management Code.
• Origin becomes more visible. Refiners will report country of origin to LBMA monthly, with an annual summary made public.

One clarification will help many smaller operators: a mechanised medium-scale mine that does not meet the artisanal definitions is treated as a large-scale mine.

The cost of an incomplete file

A refiner that cannot complete its checks cannot onboard you. The gold still sells, but through traders or other intermediaries, usually on weaker terms, with slower payment and banks that ask more questions.

The arithmetic is simple. At around $4,000 an ounce, a mine pouring 2,000 ounces a month sells about $8 million of gold a month. Every percentage point given up to an intermediary is about $80,000 a month, before any delay in payment.

Five questions to answer before you approach a refiner

1. Can you show everyone who owns 10 per cent or more, through every holding company to the people at the end, and has each one been screened?
2. Are your mining and export licences current, and held in the name of the company that will sell the gold?
3. Can you show the route from mine to refinery, everyone who handles the doré, and proof of origin for each shipment?
4. Do all payments above $10,000 go through banks, and can you evidence it?
5. Is there artisanal mining on or near your concession, and who provides security at the mine and along the route?

If any answer is “not yet”, it is better found now than in the refiner’s first round of questions.

A sensible first step

We build the file a refiner’s compliance team needs, in the order it reads it, against the current guidance and the RGG10 draft. Every statement is tied to a document, its source and its date. Page one carries a plain rating: ready to submit, ready with named gaps, or not yet submittable.

After this, you can:

• approach your target refiner with its questions already answered;
• close named gaps before they delay onboarding or a site visit;
• keep the file current as owners, routes or partners change.

It starts with a readiness check against your target refiner’s requirements, in five working days. The fee is fixed and confirmed on the first call. We do not certify mines, replace the refiner’s own site visit, or assay or handle gold.

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