OECD Due Diligence for Gold: What Buyers Must Check

OECD due diligence for gold: OECD due diligence is the international standard for making sure gold doesn’t fund conflict, human rights abuses, money laundering or corruption.

It comes from the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, which includes a Supplement on Gold.

The 5-step framework:

1. Have a supply chain policyand management systems.
2. Identify and assess risksin the supply chain.
3. Respond to the risksyou find.
4. Have refiners audited
5. Report publiclyeach year on your due diligence.

For a gold buyer, it comes down to four questions:

• Who is the seller?
• Where was the gold mined?
• How did it travel?
• Can every claim be proven with documents?

Why it matters for African gold: refineries, banks and importers in Dubai, Switzerland, the EU and the US increasingly refuse gold that comes without OECD-aligned due-diligence documents.

Why OECD Due Diligence Matters to Gold Buyers

• Refiners require it.LBMA Good Delivery refiners must follow the LBMA Responsible Gold Guidance, which is based on the OECD Guidance. They won’t accept gold without supporting documents.
• Banks require it.Banks financing or paying for gold deals check the source of the gold as part of anti-money-laundering rules.
• The law requires it in many markets:
  • European Union:the Conflict Minerals Regulation (EU) 2017/821, in force since 2021, requires EU importers of gold above set volumes to carry out OECD-based due diligence.
  • United States:Section 1502 of the Dodd-Frank Act requires listed companies to report on gold (and tin, tantalum and tungsten) from the DRC and adjoining countries, which include Uganda, Rwanda, Tanzania, Burundi, Zambia and South Sudan.
  • United Arab Emirates:gold refiners and traders must follow due-diligence regulations based on OECD principles.
• It protects you.The same checks that satisfy regulators also expose most fake gold and fake sellers.

The OECD 5-Step Framework for Gold

Step	What it means	What it means for a buyer
1. Strong management systems	Adopt a supply-chain policy (based on Annex II), assign responsibility, keep records, and set up a grievance mechanism	Have a written sourcing policy. Ask your supplier for theirs
2. Identify and assess risks	Map the supply chain, collect information on origin and transport, and check for red flags	Collect KYC on the supplier, the mine or source, and the transport route. Look for red flags
3. Respond to identified risks	Design a risk-management plan: carry on with improvements, pause, or stop trading	Don’t buy if serious risks can’t be resolved
4. Independent third-party audit	Refiners’ due diligence is audited (for example under LBMA or RMI programmes)	Prefer refiners and suppliers whose refiners are audited
5. Report annually	Publish a due-diligence report	Larger buyers and importers publish reports; smaller buyers keep records

Annex II: The Risks You Must Rule Out

The OECD’s Annex II Model Supply Chain Policy lists the risks every buyer must avoid supporting:

Serious abuses, which mean stopping immediately:

• torture or cruel, inhuman or degrading treatment
• forced or compulsory labour
• the worst forms of child labour
• other gross human rights violations, such as widespread sexual violence
• war crimes, crimes against humanity or genocide

Other risks to manage or avoid:

• direct or indirect support to non-state armed groups,including illegal taxation or extortion at mines or along transport routes
• public or private security forcesthat act illegally at mine sites or on routes
• bribery and fraudulent misrepresentation of the gold’s origin
• money laundering
• non-payment of taxes, fees and royaltiesdue to governments

Gold Red Flags Under the OECD Gold Supplement

Red flags about location:

• The gold comes from, or passed through, a conflict-affected or high-risk area (CAHRA), for example parts of eastern DRCor Sudan.
• The gold is said to come from a country with limited known gold reserves or production, compared with the volumes being offered.
• The gold passed through a country known to be a transit route for illegal gold.

Red flags about the supplier:

• The supplier operates in, or has shareholders or linksin, a red-flag location.
• The supplier is linked to armed groups, security forces or politically exposed persons.
• The supplier has a history of sanctionsor links to money laundering or fraud.

Red flags in the transaction:

• Cash paymentsor unusual payment routes, such as third-party accounts or crypto.
• Unexplained differencesin weight, purity or documents.
• Gold described as “recycled” or “scrap”but looking like newly mined doré. This is a common way to hide where gold came from.
• A price below the spot price, or unusual urgency.

What to do when you find a red flag: carry out enhanced due diligence. Get more information, visit the source, and get independent verification. If you can’t resolve the red flag, don’t buy.

OECD Due Diligence Checklist for Buyers of African Gold

1. Know your supplier (KYC)

• ☐ Company registration certificate and the directors’ IDs
• ☐ Ultimate beneficial ownersidentified
• ☐ Valid mineral dealer’s or export licence, verified directly with the government authority
• ☐ Tax registration and tax clearance
• ☐ Sanctions and politically-exposed-person screening of the company and its owners
• ☐ The supplier’s own responsible sourcing policy

2. Know the gold’s origin

• ☐ Certificate of originfrom the exporting country
• ☐ The mine or source: a licensed large-scale mine, a licensed artisanal source, a mineral market or buying centre, or a refinery
• ☐ Mining licence details for the source, where available
• ☐ For artisanal gold: the miners’ licences or cooperative records, and the buying-centre or mineral-market records
• ☐ Check whether the source or route is in a CAHRA

3. Know the transport chain

• ☐ Export permitfor the specific shipment
• ☐ Assay certificate(weight and purity) and, where required, the refining record
• ☐ Customs export declaration (HS code 7108.12) and air waybill
• ☐ An insured, declared carrier, never hand-carried gold
• ☐ Proof that royalties and export levies were paid

4. Know the money

• ☐ Payment through banks, to the supplier’s company accountin the same name as the licence holder
• ☐ No cash, crypto or third-party payments
• ☐ Records kept for at least five years, or longer if the law requires

5. Record and review

• ☐ A due-diligence file for every shipment
• ☐ A risk assessment and the decision taken (buy, buy with conditions, or don’t buy)
• ☐ A review of each supplier at least once a year

Related Standards Built on the OECD Guidance

Standard or law	Who it applies to	Link to OECD
LBMA Responsible Gold Guidance	LBMA Good Delivery refiners	Based on the OECD Guidance, with independent audits
RMI Responsible Minerals Assurance Process (RMAP)	Smelters and refiners in electronics and other supply chains	OECD-aligned audits
EU Conflict Minerals Regulation 2017/821	EU importers of gold above set volumes	Requires OECD-based due diligence
US Dodd-Frank Act, Section 1502	US-listed companies using 3TG minerals (tin, tantalum, tungsten and gold)	Reports often use the OECD framework; covers the DRC and adjoining countries
UAE due-diligence rules for gold	UAE gold refiners and traders	Based on OECD principles
ICGLR Regional Certification Mechanism	Great Lakes countries (including Uganda, DRC, Rwanda, Tanzania)	A regional mineral certification aligned with the OECD Guidance

OECD Due Diligence and Uganda Gold

Uganda borders the DRC, so gold exported from Uganda gets extra attention from refiners and banks. Buyers should expect, and ask for:

• the exporter’s Mineral Dealer’s Licenceand export permit for each shipment
• proof the gold was refined to at least 99.9%, which Ugandan law requires for exports
• a certificate of originand source records
• KYC on the supplier and its owners
• payment through banks only

Gold of DRC origin passing through Uganda without proper certification is exactly the risk the OECD Guidance and Dodd-Frank are designed to catch. A compliant supplier should be able to show where the gold came from.

FAQs: OECD Due Diligence for Gold

What is the OECD Gold Supplement? It’s the part of the OECD Due Diligence Guidance that sets out the specific steps and red flags for gold supply chains, covering mined gold (large-scale and artisanal) and recycled gold.

Is OECD due diligence a legal requirement? The Guidance itself is voluntary, but it’s built into laws and rules such as the EU Conflict Minerals Regulation, UAE due-diligence regulations and LBMA requirements for refiners. In practice, you need it to sell gold to reputable refiners and banks.

What are Annex II risks? The risks listed in the OECD Model Supply Chain Policy: serious human rights abuses, support to armed groups, illegal security forces, bribery and misrepresenting origin, money laundering, and not paying taxes and royalties.

What is a CAHRA? A conflict-affected or high-risk area: a region with armed conflict, widespread violence or serious risk of harm to people. Gold from or through a CAHRA needs enhanced due diligence.

Does a certificate of origin prove gold is conflict-free? Not on its own. It’s one piece of evidence. Due diligence also needs supplier KYC, source records, transport records and payment checks.

Do small buyers need to do OECD due diligence? Yes, in proportion to their size. Even a small buyer should check the supplier’s licence, the origin, the export documents and the payments, and keep records.

Buy Gold With a Full Due-Diligence File

Buy Gold Bars Africa Ltd supplies refined gold bars exported legally from Uganda. Every order comes with a due-diligence file built around the OECD steps:

• our company and licence documents for your KYC
• the export permit for each shipment
• an assay report and certificate of origin
• payment through banks only

You can inspect the gold before you pay. Call or WhatsApp +256 707 585144, or contact us.