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Refinery KYC for Uganda-origin gold: what the questionnaire asks, and what a Ugandan seller can and cannot show
Before an accredited refiner accepts a first lot of mined gold, its compliance team sends the supplier a questionnaire and verifies the answers. This page takes the LBMA mined-material questionnaire, updated April 2024, and the published policies of two accredited refiners, and sets out for each section what good evidence is, which Ugandan document would show it, and what no Ugandan seller can show today. Uganda Gold Report has no supplier, no lot and no refinery relationship, and has completed no questionnaire for anyone.
What a refiner's KYC questionnaire is
Refiners on the LBMA Good Delivery List must identify and assess every supplier of mined gold under Step 2 of the Responsible Gold Guidance: the supplier's name, address, registration and licences, verified independently; its ultimate beneficial owners at 10 per cent or more, with government-issued photo identification; the location of the mine; and the transport route to the refinery. The questionnaire collects this. LBMA publishes a model for mined material; refiners add their own.
Two accredited refiners describe the same gate in their own words. One will only transact "in terms of a formal signed agreement with the OWNER of the gold", "on a principal-to-principal basis", and the owner "must be a registered company". The other monitors "consistency between documentation provided and physical deliveries" and subjects any acceptable high-risk supply chain to enhanced due diligence "including an on-site visit". We name neither refiner here and recommend none.
The UAE, the main recorded destination of gold exported from Uganda, imposes the same structure by regulation: supply-chain entities must identify and verify each supplier and its beneficial owners at 25 per cent and above, keep records of each supply, and assess conflict-affected and high-risk-area risks. See documents and compliance.
The questionnaire, section by section, for a Ugandan lot
The LBMA mined-material questionnaire has nineteen sections and an anti-money-laundering annex. The table groups them by the question a compliance officer is really asking and shows which document under Uganda's Mining and Minerals Act 2022 would answer it. The law provides for each document; whether a given seller holds it is for the buyer's checks.
| Questionnaire area | What the form asks | What good evidence looks like | How a Ugandan seller would show it |
|---|---|---|---|
| Counterparty identity (sections 1, 2, 19) | Registered and business address, incorporation date and country, registration number, tax and VAT numbers, auditors, group chart, legal proceedings in five years; type of business, from large-scale mine to "Precious Metals trader"; ID copies for authorised signatories | A certificate matching the name on every later document, and a licence entry in the same name | URSB company records; a tax identification number; the holder's entry on the directorate's list of active dealer and refining licences |
| Ownership at 10 per cent (sections 3, 4) | Shareholders above 10 per cent, then the individuals above 10 per cent, each with percentage, address, country and PEP status | Named natural persons, with identification, that the refiner then screens itself | Company records, which name shareholders; PEP status is declared by the seller and tested by the buyer's own screening |
| Licences and permits (section 6) | A copy of the mining licence and the environmental licence with dates; whether the regulator has visited the site; and "Is your Company legally required to have a license to export precious metals?" | Current licences in the counterparty's name, and the export authority for this consignment | A dealer's licence (s.140), refining licence (s.121) or mineral right; and, because a mineral may be exported only under an export permit (s.150), the permit applied for on Form 52 for this consignment. Which licence types can currently obtain one is not settled: see Uganda gold regulations |
| Mine of origin and chain of custody (sections 9, 10, 11) | Number and names of mining sites, their GPS coordinates, daily production, estimated reserves, extraction method, whether the mine sources from artisanal miners on its concession or ore and doré from outside it; where the processing plant is | Records that reconcile from a named licensed site to this lot | The mineral right number; the movement permit (Form 57); the dealer's register entry (s.143) and monthly return (Form 66) giving the source licence. A dealer cannot answer the production and reserves questions from its own records; only the mineral-right holder can. See gold chain of custody |
| Transport (section 14) | How ore reaches the plant, how doré reaches the export location and by whom, how it will reach the refinery, and whether there is "any military/police checkpoint along the road from the mining site until the export location" | A named carrier for each leg and a route the refiner can monitor shipment by shipment | The movement permit's route map and schedule; the carrier and air waybill for the international leg: shipping gold internationally |
| Payment (section 5) | Source of funding; financial statements; the "usual payment method" the company uses to pay its own suppliers, by percentage: bank transfers, cheques, cash | Bank-settled purchases that match the register | The dealer's register records the price and date of every purchase (s.143); the seller's bank records show how it was paid |
| Sanctions and PEP (sections 4, 17, 18) | PEP status of each owner; the company's own AML and anti-bribery programme, with copies | Clear screening of the company, its owners, directors and intermediaries on the date of checking | The seller supplies the names; the refiner screens them against UN, US, UK and EU lists. A clear result holds only for those names on that date |
| Policy and audit (section 15 and the refiner's own terms) | A supply-chain policy consistent with Annex II of the OECD guidance, with a copy; LBMA guidance adds an on-site visit where enhanced due diligence is triggered, "before any transactions occur or, at the least, within six months" | A written policy, and access to the site and the records | The policy is the seller's own. The register must be produced to the Minister or an authorised officer when required (s.143), but access to a mine site is given by the mineral-right holder, not by a dealer |
The two red flags that touch Uganda
LBMA's Step 2 lists the circumstances that make a supply chain high-risk and trigger enhanced due diligence. Two of them are met by Uganda on the public record before any seller is named.
The first is gold claimed to originate from "a country that has limited known reserves, likely resources or expected production levels". Uganda recorded about 62 tonnes of gold exports in 2025, against recorded mine production of about 15 kg a year in the latest official figures found.
The second is gold that "is claimed to originate from a country through which gold from CAHRAs is known, or reasonably suspected, to transit". United Nations experts assessed Uganda's 2025 export surge as largely attributable to gold originating from the Democratic Republic of the Congo, with declared origins not corroborated by trade data. The Act itself provides for exporting minerals that are not from Uganda, in which case the exporter must also produce the origin country's documents (s.150(4)(d)).
An export permit answers neither flag: it shows that a consignment was authorised to leave Uganda, not where the gold was mined. What answers them is the chain of mine-level records above, reconciling from a named mineral right to the lot, and the site visit the refiner's policy requires.
What a Ugandan seller cannot show today
- Accreditation of a Ugandan refiner. No Ugandan refinery was on the LBMA Good Delivery List on 31 October 2026. The directorate's list showed 8 refining licences with the commodity given as gold; that is a licence class, not evidence of output or of any audit. See gold refining in Uganda.
- An ICGLR certificate for gold. Uganda launched issuance in November 2023, and we could not establish whether any certificate has yet been issued for gold. See the ICGLR certificate.
- A settled answer to the export-licence question. The copy of Uganda's 2024 export regulations we reviewed states a minimum of 99.9% gold for exports (S.I. 30 of 2024, regulation 3). We have not confirmed that it is currently in force. Which licence types can obtain an export permit is also unsettled.
- Public audits of dealers. The directorate's list shows licence entries, not lots, audits or stock.
Ask any seller who claims to have closed these gaps for the document.
What Uganda Gold Report can show
Nothing beyond the registration of the company that operates this site and the standards we publish. We hold no Ugandan licence, no lot, no supplier records and no refinery relationship, so we could not complete this questionnaire for any refiner today. We publish the map so that a compliance team can test any Ugandan offer, including a future one from us. The documents a lawful export carries are on documents and compliance; what a buyer may ask of us is on the buyer compliance file.
Where Uganda Gold Report stands
Uganda Gold Report is developing documented gold-sourcing routes and welcomes enquiries from qualified international buyers. Product availability, specifications, seller authority and export eligibility are subject to independent verification and applicable regulatory approvals.
No refiner has told us it would accept Ugandan gold, and we have answered no refiner's questionnaire. If your compliance team needs documented origin, say so when you request a gold quote, and we reply with what can and cannot be quoted at this stage. See also how buying gold from Uganda works.
Questions buyers ask
What does a refinery's KYC questionnaire ask a gold supplier?
The LBMA model for mined material, updated April 2024, asks for the company's registration and tax details, its owners above 10 per cent with PEP status, its financial statements and source of funding, copies of its mining and environmental licences and whether it needs a licence to export, the names and GPS coordinates of its mining sites with production and reserves, how doré is transported to the export point and to the refinery, its payment methods to its own suppliers, its supply-chain policy under Annex II of the OECD guidance, and its AML and anti-bribery programmes. Refiners add their own forms and verify the answers independently.
Is a Ugandan export permit enough for a refiner's KYC?
No. The questionnaire asks whether the supplier is legally required to hold an export licence, and the permit answers that line only. It does not answer the origin questions, because it shows that a consignment was authorised to leave Uganda, not where the gold was mined. The Act itself provides for exporting minerals that are not from Uganda (s.150(4)(d)). Origin is shown by the mineral right, the movement permit, the dealer's register and monthly return, reconciling to the lot.
Why is Uganda-origin gold treated as high risk by refiners?
Two of the circumstances LBMA lists for enhanced due diligence apply on the public record: origin claimed from a country with limited known reserves or production relative to its exports, and a country through which gold from conflict-affected and high-risk areas is known or reasonably suspected to transit. Uganda recorded about 62 tonnes of exports in 2025 against recorded mine production of about 15 kg a year, and UN experts assessed the surge as largely of Congolese origin. Enhanced due diligence includes a site visit before any transaction or within six months.
Is any Ugandan refinery LBMA-accredited?
No Ugandan refinery was on the LBMA Good Delivery List for gold on 31 October 2026. The directorate's list showed 8 refining licences with the commodity given as gold; a licence class is not evidence of output, accreditation or audit. Bars refined in Uganda would be assayed by the buying refinery on arrival.
Can Uganda Gold Report complete a refiner's questionnaire today?
No. We hold no Ugandan licence, no lot, no supplier records and no refinery relationship, so the only items we could show are the registration of the company that operates this site and the standards we publish. We have answered no refiner's questionnaire, and no refiner has told us it would accept Ugandan gold. This page exists so that a compliance team can test any Ugandan offer, including a future one from us.
Quotes
Tell us what you are buying.
Send the gold form, fineness, quantity, delivery point and the documents you require. We reply by email with what can and cannot be quoted at this stage, and on what basis.
Sources for the figures and rules on this page
Evidence for this page
Each statement is labelled by the strength of its evidence and dated. How we label evidence.
| Statement | Evidence | Source | Checked |
|---|---|---|---|
| The LBMA Questionnaire, Mined Material (LSM/MSM), marked "Updated April 2024", has nineteen numbered sections (company details; business activity by scale, including "Precious Metals trader"; beneficial owners and ultimate beneficial owners at more than 10%, with PEP status; financial information including source of mining-operation funding and "usual payment method" to suppliers by percentage, bank transfers, cheques or cash; regulatory framework, including copies of the mining and environmental licences, regulator site visits and "Is your Company legally required to have a license to export precious metals?"; government payments; human resources; origin, capacity and mining practices, including site names, GPS coordinates, daily production, estimated reserves, sourcing from artisanal miners on the concession and ore or doré from outside it; processing plant; materials; community engagement; security; transportation of ore, of doré to the export location and to the refinery, and "any military/police checkpoint along the road from the mining site until the export location"; a supply-chain policy consistent with Annex II of the OECD Guidance; environment; AML/CFT; anti-bribery; authorised signatories with ID copies) and an AML annex. | Official | LBMA, KYC Questionnaire LBMA Mined Material, Updated April 2024, PDF opened and text extracted 2 Nov 2026 | |
| Step 2 requires identification and verification of the counterparty's name, physical address, registration and licence information; of ultimate beneficial owners "defined as 10% or more ownership" using "reliable and current government-issued photo identity documents"; the location of the mine (LSM and ASM); and the general transportation routing from origin to refinery. High-risk circumstances include gold claimed to originate from "a country that has limited known reserves, likely resources or expected production levels"; gold that "Is claimed to originate from a country through which gold from CAHRAs is known, or reasonably suspected, to transit"; "material discrepancies/inconsistencies in the documentation provided"; UBOs that are PEPs; sourcing from a high-risk country in the last 12 months. Where EDD is triggered, refiners must undertake an on-site visit at the location of the gold origin, "Conducted before any transactions occur or, at the least, within six months of the business relationship commencing." | Verified | LBMA Responsible Gold Guidance v9, Step 2: Identify and assess supply chain risks, read 2 Nov 2026 | |
| An accredited refiner's customer page states: "Rand Refinery will only transact in terms of a formal signed agreement with the OWNER of the gold"; "The owner of the gold must be a registered company; an individual cannot register in his/her private capacity"; "Rand Refinery only transacts on a principal-to-principal basis and does not transact through intermediaries or third parties"; "Potential customers need to have relevant permissions and permits before we will consider sourcing gold from them"; "Material deposited at Rand Refinery must be of known provenance"; audits check conformance with the OECD five-step process; payment by EFT only. The refiner's separate responsible-sourcing page URL returned 404 on 2 Nov 2026; the refiner is not named in the page text and is not recommended. | Verified | Rand Refinery, Customer Self-service page, read 2 Nov 2026 | |
| The refiner's Responsible Sourcing (Precious Metals) Policy (PDF created 16 March 2026) assesses supplier, location and material risks; monitors "Consistency between documentation provided and physical deliveries"; has "Zero tolerance" for metal from world heritage sites, international sanctions or UBOs implicated in serious abuses, armed-group support or financial crime; has "Low appetite" for metal that originates from or is transported through a CAHRA, or "Are claimed to originate from a country with limited known reserves, likely resources or expected production levels", for suppliers with foreign PEP UBOs, with "Material discrepancies or inconsistencies in the documentation provided or refusal to provide requested documentation", or sourced from offshore artisanal operations or through an intermediate supplier with a high-risk chain; an acceptable high-risk chain "is subject to an enhanced due diligence, including an on-site visit"; suspension is considered if an improvement plan is not achieved within 6 months. Its refinery process page states doré is "shipped to The Perth Mint Refinery with an approved security transport provider", melted "to obtain a truly representative sample", assayed by "dual stream fire assay analysis", and "Payment is based on the final troy ounces of gold and silver determined in your metal and the current spot price." The refiner is not named in the page text and is not recommended. | Verified | The Perth Mint (Gold Corporation), Responsible Sourcing (Precious Metals) Policy, PDF opened and text extracted 2 Nov 2026; The Perth Mint, Refinery: The process, read 2 Nov 2026 | |
| The UAE Ministry of Economy's Due Diligence Regulations for Responsible Sourcing of Gold (Version 1, August 2022, reinforced by Ministerial Decree No. (68) of 2024) require relevant supply-chain entities to establish management systems and identify and assess supply-chain risks including CAHRA risks; the regulations define Beneficial Owner at 25% or more ownership and require KYC information on suppliers including verification of ultimate beneficial owners who own 25% and above, records of each supply, and enhanced due diligence where a supplier or beneficial owner is a PEP. | Official | UAE Ministry of Economy, Due Diligence Regulations for Responsible Sourcing of Gold; ministry page read 2 Nov 2026; thresholds and record requirements from the project's saved copy of the regulations | |
| The Supplement on Gold, Step 1, requires upstream companies to collect and share for every gold input: "the mine of origin, with the greatest possible specificity"; locations of consolidation, blending, crushing, milling, smelting and refining; the method of extraction and dates; "the weight and assayed quality characteristics"; the identity, ownership including beneficial ownership and corporate structure of all suppliers and service providers from mine to refiner; taxes, fees and royalties paid; payments to government agencies and officials; payments to security forces; and how gold is transported (p. 99). Annex II is the Model Supply Chain Policy that companies commit to "incorporate in contracts and/or agreements with suppliers" (p. 20). | Official | OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, third edition, 2016, Supplement on Gold and Annex II; PDF opened and text extracted 2 Nov 2026 | |
| Buying or selling minerals as principal or agent requires a mineral dealer's licence (s.140). Refining needs a licence (s.121). A mineral may be exported only under an export permit (s.150). s.143(1): a dealer's register shows all purchases and sales with nature and weight, price and date, "the name and address of the vendor and his or her right to be in possession of the minerals", the place of origin and the purchaser or consignee, and is produced to the Minister or an authorised officer when required. s.150(4): the permit does not exempt the holder from proof of fees and royalties, a certificate of origin where applicable, a certificate of analysis authenticated by the country of origin and, where minerals are not from Uganda, an export permit or related documents from the country of origin. | Official | Mining and Minerals Act 2022 (Uganda), assented copy, ss.121, 140, 143 and 150; section numbers per research/legal/05; as carried on the Uganda gold suppliers and gold chain of custody pages | |
| Form 52 (export permit) asks for applicant and licence number, TIN, mineral, quantity, grade, source, destination or consignee and royalty status, and requires a dealer applicant to attach official documents evidencing ownership by the person it bought from. Form 57 (mineral movement permit) asks for mineral, quantity, grade, licence number, origin and destination, a route map and schedule. Form 66 (dealer's monthly return) gives the original source of each mineral as a licence or mineral-right number, or the other dealer's licence number. | Official | Mining and Minerals (Licensing) Regulations 2023, Forms 52, 57 and 66, from the mining directorate's licensing procedures and forms, as carried on the gold chain of custody page | |
| DGSM publishes a list of active mineral dealer and refining licences; it showed 223 entries on 31 Oct 2026 (214 dealer, 8 refining, 1 test record); the list view does not state the mineral, and each entry's detail page gives a commodity class, Gold on all 8 refining licences. The list shows licence entries, not lots, audits or stock. | Official | DGSM list of active dealer and refining licences, read 31 Oct 2026; Uganda Gold Report count | |
| No Ugandan refinery appears on LBMA's Good Delivery List for gold. The list page read on 2 Nov 2026 showed a total of 67 gold refiners without a country table in the fetched text; the 31 Oct 2026 reading of the full list stands. | Official | LBMA Good Delivery List, gold, read 31 Oct 2026 and 2 Nov 2026 | |
| Uganda recorded gold exports of about 62 tonnes in 2025, which UN experts judged largely attributable to gold of DRC origin, with declared import origins not corroborated by trade data. Recorded mine production was about 15 kg a year in the latest official figures found. | Official | UN Group of Experts on the DRC, final report S/2026/466, para. 212; Uganda EITI reports FY2020/21 and FY2021/22; as carried on the how-it-works page | |
| Regulation 3 states: "A person shall not export gold out of Uganda unless the gold is at a minimum purity level of 99.9% Au." Made 9 May 2024; Statutory Instruments Supplement No. 15 of 24 May 2024. Current force not confirmed. | Official | Mining and Minerals (Export of Refined Gold) Regulations 2024, S.I. 30 of 2024, regulation 3; scanned copy on the mining directorate (DGSM) website, read 31 Oct 2026 | |
| Uganda launched issuance of the ICGLR certificate in November 2023; whether any certificate has yet been issued for gold could not be established. | Reported | As carried on the ICGLR certificate page, with its sources | |
| The United Arab Emirates is the largest recorded destination of gold from Uganda in every year it has filed (to 2023). On Uganda's own 2025 figures, the UAE took 48,524 kg. | Verified | UN Comtrade partner (mirror) data, HS 7108, as carried on the how-it-works page | |
| Which licence types can currently obtain an export permit is not settled; a dealer's licence alone does not authorise export. Section 140(1) applies to "a person" with no exception for foreigners; no official text found addresses a foreign buyer taking title in Uganda. | Subject to verification | Uganda Gold Report analysis, as carried on the Uganda gold suppliers and how-it-works pages; question for Ugandan counsel | |
| The company operating the site appears on the URSB public register as REGISTERED (ERN 80040113567680); its certificate of incorporation, incorporation date and registered office are not yet on file. Uganda Gold Report holds no Ugandan licence, no lot, no supplier records and no refinery relationship, has answered no refiner's questionnaire, and no refiner has told us it would accept Ugandan gold. | Subject to verification | URSB public register, read 1 Nov 2026; Uganda Gold Report company identity record | |
| Search volume for "gold supplier kyc", "lbma kyc questionnaire" and "gold refinery supplier requirements" has not been read in SEMrush; the page is drafted on buyer-intent evidence from the 2 Nov 2026 audience research and the volume reading is outstanding. | Subject to verification | SEMrush reading outstanding (free plan, web UI); research/seo/buyer-audience-opportunities-2026-11-02.md, candidate C1 |