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Due diligence
Gold chain of custody and proof of ownership: the records a documented lot carries from mine to refinery
Chain of custody is the record of who held a lot of gold, in what form and weight, at every transfer from the mine to the refinery. Refiners and regulators ask for it because an export permit shows that a consignment may leave a country, not where the gold was mined. This page sets out what the record contains, what proof of ownership a seller must show, and the paper trail Uganda's law provides for. Uganda Gold Report has seen no lot's records and holds none.
What chain of custody means
The OECD Due Diligence Guidance defines chain of custody as "a record of the sequence of entities which have custody of minerals as they move through a supply chain". The UAE Ministry of Economy's due-diligence regulations for gold use the same definition. The Responsible Jewellery Council's Chain of Custody Standard 2024 calls it "a documented sequence of custody of material as it moves along the supply chain".
Three words do the work. Record: paper or data, not a promise. Sequence: every holder in order, with no gap. Custody: who held the gold, which is not the same as who owned it.
Chain of custody, traceability and audited schemes
Sellers use the terms loosely. The OECD guidance speaks of "a chain of custody and/or traceability system"; the RJC standard describes material segregated along the supply chain and audited by a third party at every stage. Read together, the standards separate three claims.
| Claim | What it means | What it does not show |
|---|---|---|
| Chain of custody | A record of each holder of the lot, in order, with form, weight and dates | That the first entry is true, or that every holder was lawful |
| Traceability | The lot can be followed back along that record to a named origin | That the origin was checked by anyone other than the seller |
| An audited scheme such as RJC chain of custody | Eligible material, kept segregated, with a transfer document for each shipment and third-party audit at every stage | Anything about material outside the scheme |
A seller who says a lot is "traceable" should be asked for the record that makes it so.
What the record contains
The three standards that matter most for Ugandan gold converge on one list. The OECD Gold Supplement sets out what upstream companies collect for every gold input; the UAE regulations set the minimum records a regulated entity keeps for each supply, including the transport documents "to establish Chain of custody from origin to refinery"; and LBMA's Responsible Gold Guidance, at Step 2, sets what a refiner establishes and checks on arrival.
| Item in the record | OECD Gold Supplement | UAE regulations | LBMA guidance, Step 2 |
|---|---|---|---|
| Mine of origin | With the greatest possible specificity | Official certificate of origin or equivalent | Location of the mine |
| Form, weight and assay | Weight and assayed quality | Form, weight and assay as supplied | Checked against transport documents on arrival |
| Every holder | Identity and ownership of all suppliers and service providers | Supplier KYC, owners at 25 per cent and above | Supplier registration, licences, owners at 10 per cent and above |
| Transport | How the gold is transported | Waybill, pro forma invoice, bill of lading | Transport route for each shipment |
| Dates and references | Dates of concentrating, smelting and refining | Unique reference numbers and dates for each input and output | Consistency across purchase orders, receipts and invoices |
The OECD guidance and the UAE regulations both ask for these records to be kept for at least five years.
Proof of ownership: what a seller must show
Custody and ownership are different questions, and a buyer needs both answered. In Uganda, the Mining and Minerals Act 2022 provides the test. A person may buy or sell minerals, as principal or agent, only as a licensed mineral dealer (s.140(1)); a dealer may buy only from a person who acquired the minerals lawfully (s.140(2)); and the holder of a mineral right may sell its own output without a dealer's licence (s.140(3)). Lawful ownership of a lot therefore rests on the mineral right under which it was mined, or on a purchase by a licensed dealer from someone who held it lawfully.
The Act then says what a dealer must record. Its register must show every purchase and sale with the nature and weight of the minerals, the 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, entered within 24 hours, with a copy sent to the Minister every quarter (s.143). The export permit application, Form 52, requires a dealer applicant to attach official documents evidencing ownership of the mineral by the person it bought from. The dealer's monthly return, Form 66, gives the original source of each mineral as a licence or mineral-right number, or the other dealer's licence number if it was bought from a dealer.
Proof of ownership for a Ugandan lot is therefore not a single certificate. It is the seller's licence or mineral right, the register entry for the purchase, the previous holder's right to possess, and the source licence number on the monthly return. A licence without the purchase record shows a right to trade, not ownership of this lot. See the mineral dealer's licence guide.
The paper trail from mine to refinery: Uganda
This is the paper trail the Act and its forms provide for. It is not a description of any lot: Uganda Gold Report has seen no lot's records, holds none, and has no supplier. Whether a given holder keeps these records as the law requires is for the buyer's checks.
| Step | Who holds the gold | Record the law provides for | What must reconcile |
|---|---|---|---|
| 1. Extraction | Holder of a mineral right | The mineral right itself; the holder may sell its own output (s.140(3)) | The licence number appears on every later document |
| 2. Movement | Transporter or holder | Mineral movement permit, Form 57: mineral, quantity, grade, licence number, origin and destination, route map and schedule, royalty paid or secured | Quantity and licence number against step 1 |
| 3. Purchase by a dealer | Licensed mineral dealer | Register entry (s.143): weight, price, date, vendor and the vendor's right to possess, place of origin; monthly return, Form 66, with the source licence number | Weight and source against the movement permit |
| 4. Refining | Holder of a refining licence | Refining needs a licence (s.121); refiners export at purity levels set by regulations (s.130); input lots linked to output bars by reference numbers | Input weight and fineness against output bars, with the loss explained |
| 5. Export | The exporter | Export permit (s.150(1)), Form 52: applicant and licence number, mineral, quantity, grade, source, consignee, royalty; plus proof of fees and royalties, certificate of origin where applicable and certificate of analysis authenticated by the country of origin (s.150(4)) | Quantity, grade and source against steps 3 and 4 |
| 6. Arrival at the refinery | The buying refinery | Weight, assay and seal numbers checked against the transport documents; the buyer's own record of the lot | Arrival weight and assay against the certificate of analysis |
One line of the Act matters most for origin. Where the minerals are not from Uganda, the export permit does not exempt the exporter from producing the origin country's export documents (s.150(4)(d)): the law itself contemplates gold leaving Uganda that was not mined there. Uganda recorded about 62 tonnes of gold exports in 2025, and UN experts assessed the rise as largely attributable to gold originating from the Democratic Republic of the Congo. A Ugandan export permit is the end of the chain, not its proof. See production and export figures and what each export document should prove.
Where the chain breaks
- The record starts at a dealer. If the monthly return's source licence number is another dealer's number, the chain runs back to that dealer, not to a mine.
- An export permit, certificate of analysis or invoice offered as proof of origin. Each proves something else.
- A document the issuer cannot confirm.
- Weights that do not reconcile between the movement permit, the register, the export permit and the arrival assay, with no refining loss to account for the difference.
- A seller who holds the gold but cannot show the previous holder's right to possess it.
The Uganda gold scams guide shows how these gaps appear in real offers, and the five due-diligence checks give an official source for each test.
Who keeps the records
In Uganda, the dealer keeps the register, produces it to the Minister or an authorised officer when required and to a senior police officer during an investigation, and sends a copy to the Minister each quarter (s.143). The directorate's public list shows licences, not lots. On the buyer's side, the UAE regulations and the OECD guidance require the records of each supply to be kept for at least five years. A buyer therefore obtains the chain from the seller and tests it; no public register supplies it. What a refiner asks a supplier for is in the buyer compliance file and, for the UAE route, importing gold into the UAE.
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. We hold no stock, no lots and no Ugandan licence, and no lot is documented to mine level today. If you need documented origin, say so when you request a gold quote. See also how buying gold from Uganda works and how to check a Ugandan gold supplier.
The sections of the Act behind this trail are summarised on the Mining and Minerals Act 2022: gold.
Questions buyers ask
Is a Ugandan export permit proof of origin?
No. An export permit shows that a consignment was authorised to leave Uganda. The Act itself provides for exporting minerals that are not from Uganda, in which case the exporter must also produce the origin country's export documents (s.150(4)(d)). Origin is shown by the chain of records from the mine: the mineral right, the movement permit, the dealer's register and monthly return, and the certificate of origin where applicable.
What is the difference between traceability and chain of custody?
Chain of custody is the record itself: the sequence of entities that held the gold, with form, weight and dates, as the OECD guidance and the UAE regulations define it. Traceability is what that record makes possible: following a lot back along it to a named origin. A lot can carry a chain-of-custody record that stops at a dealer and is therefore not traceable to a mine.
What proof of ownership should a gold seller in Uganda show?
The licence or mineral right under which it holds the gold, the register entry for its purchase showing the vendor and the vendor's right to possess the minerals (s.143), the source licence number carried on its monthly return (Form 66), and, for an export, the official documents evidencing the previous holder's ownership that Form 52 requires. A licence alone shows a right to trade, not ownership of a particular lot.
Who keeps the chain-of-custody records?
In Uganda the licensed dealer keeps the register and sends a copy to the Minister each quarter; movement and export permits are applied for on official forms. Buying refiners and UAE regulated entities keep the records of each supply for at least five years. There is no public register of lot records; the directorate's list shows licences, not lots. A buyer obtains the chain from the seller and tests it.
Can Uganda Gold Report show a lot's chain of custody today?
No. We hold no stock, no lots and no Ugandan licence, we have no supplier, and we have seen no lot's records. The worked example on this page is the paper trail the law provides for, not a description of any lot. If you need documented origin, say so in your quote request and we will tell you what can and cannot be quoted at this stage.
Quotes
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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 |
|---|---|---|---|
| Chain of custody is defined as "a record of the sequence of entities which have custody of minerals as they move through a supply chain". The guidance refers to "a chain of custody and/or traceability system". The Gold Supplement asks upstream companies to collect, for every gold input: the mine of origin with the greatest possible specificity; locations where gold is consolidated, blended, crushed, milled, smelted and refined; the method of extraction and dates of concentrating, smelting and refining; the weight and assayed quality; the identity and ownership of all suppliers and service providers from the mine to the refiner; all taxes, fees or royalties paid; payments to government and to security forces; and how the gold is transported. Chain-of-custody information is to be kept for a minimum of five years. | Official | OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, third edition, 2016: definitions; Step 1 C.4; Supplement on Gold, Step 1 B.5 | |
| Chain of Custody is defined as "A record of the sequence of entities which have custody of gold as they move through a Supply Chain". Due diligence is carried out on each supply of gold. The records inventory shall include, at least: form, type and physical description of the gold; proof of origin of mined gold through an official government-issued certificate of origin or equivalent document and invoices and packing list; weight and assay as provided by the supplier; supplier KYC including beneficial owners at 25% and above; unique reference numbers for each input and output; dates of input, output, purchases and sales; shipping documents (waybill, pro forma invoice, bill of lading) "to establish Chain of custody from origin to refinery"; and arrival, assay and payment details (1.3.7 to 1.3.8). Records are kept for not less than five years (1.3.10); shipments are physically segregated until verified (1.3.11). | Official | UAE Ministry of Economy, Due Diligence Regulations for Responsible Sourcing of Gold, Version 1, August 2022, reinforced by Ministerial Decree No. (68) of 2024; ministry page opened 2 Nov 2026, text read from the project's saved copy of the regulations | |
| The RJC Chain of Custody Standard (December 2024 version, approved by the RJC Board on 19 November 2024) describes a chain of custody as "a documented sequence of custody of material as it moves along the supply chain". COC material is traceable and segregated along the supply chain, with third-party auditing at every stage. A transfer document is issued for each shipment or transfer of COC material (provision 8) and accompanies each shipment, physically attached or digitally linked (9.1); for mined material the declaration states the country or countries where it was extracted (8.2(c)). | Verified | Responsible Jewellery Council, Chain of Custody Standard 2024, introduction and provisions 8 and 9 | |
| Step 2 requires a refiner to establish, for mined gold, the location of the mine and the general transport route from origin to refinery; to monitor the actual transportation routing for each shipment; to verify the physical shipment against shipping and transportation documents (assays, weights, serial numbers); and to confirm that purchase orders, goods receipts, invoices and KYC information are consistent. Suppliers' registration and licences are verified and beneficial owners at 10% or more are identified. | Verified | LBMA Responsible Gold Guidance v9, Step 2: Identify and assess supply chain risks | |
| s.140(1): a person shall not buy or sell, as principal or agent, any minerals unless a licensed mineral dealer. s.140(2): a licensed dealer may only buy from a person who acquired the minerals lawfully. s.140(3): a holder of a mineral right may sell minerals acquired under the Act without a dealer's licence. 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", details of the place of origin, and the purchaser or consignee; every transaction is recorded within 24 hours; the register is produced to the Minister or an authorised officer when required and to a police officer not below Assistant Superintendent during an investigation. s.143(2): a copy goes to the Minister quarterly. s.150(1): no export without an export permit. s.150(4): the permit does not exempt the holder from proof of fees and royalties where applicable, 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.140, 143 and 150; section numbers per research/legal/05 | |
| Refining needs a licence (s.121), and refiners export at purity levels set by regulations (s.130). | Verified | Mining and Minerals Act 2022 (Uganda), assented copy, as carried on the Uganda gold suppliers page | |
| Form 52 (reg. 84(2), export permit) asks for applicant and licence number, TIN, mineral, quantity, grade, source, destination or consignee and royalty paid or secured, and requires a dealer applicant to attach official documents evidencing ownership of the mineral by the person from whom it was purchased. Form 57 (reg. 86(2), mineral movement permit) asks for the mineral, quantity, grade, mineral right or licence number, location, origin and destination, purpose, royalty paid or secured, and a route map and schedule. Form 66 (reg. 93(5), dealer's monthly return, due within 14 days of the month's end, with evidence of royalty payment) gives the original source of each mineral as a licence or mineral-right number, or the other dealer's licence number where bought from a dealer. | Official | Mining and Minerals (Licensing) Regulations 2023, Forms 52, 57 and 66, from the mining directorate's licensing procedures and forms | |
| Uganda recorded gold exports of approximately 62 tonnes in 2025, the third consecutive year of record exports; declared trade data showed significant inconsistencies in declared countries of origin; the Group of Experts assesses that the surge in gold exports was largely attributable to gold originating from the Democratic Republic of the Congo. | Official | UN Group of Experts on the DRC, final report S/2026/466, para. 212 | |
| The mining directorate's public list shows active dealer and refining licence entries; it does not show lots, lot records or the holder's stock. | Official | DGSM list of active dealer and refining licences, read 31 Oct 2026 |