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Due diligence
Responsible gold sourcing: the OECD, LBMA, RJC, RMI and UAE frameworks, and what each asks of a Ugandan route
Responsible gold sourcing is governed by one root framework, the OECD Due Diligence Guidance and its Gold Supplement, and by the schemes and laws that apply it: LBMA's Responsible Gold Guidance for refiners, the RJC's standards for jewellery-industry members, the RMI's assessment of smelters and refiners, the UAE's due-diligence regulations, the EU conflict-minerals regulation and US securities disclosure. This page sets out what each requires, how they fit together, and what a Ugandan supply route would have to show. Uganda Gold Report holds no audit or membership under any of them.
The frameworks at a glance
The OECD guidance is the reference point. Its five steps are the structure LBMA's guidance and the UAE regulations follow, the framework EU importers must apply by law, and the requirement the RMI's standards are written to meet. Each scheme decides whom it binds and how conformance is shown.
| Framework | Whom it binds | What it requires | How conformance is shown | Where to read it |
|---|---|---|---|---|
| OECD Due Diligence Guidance, third edition 2016, with the Supplement on Gold | A government-backed recommendation to companies; binding only where a law adopts it | Five steps, from management systems to annual reporting; red flags for gold | Step 4 is an audit of a refiner's due-diligence practices. There is no OECD certificate | oecd.org |
| LBMA Responsible Gold Guidance v9, finalised November 2021 | All refiners on the LBMA Good Delivery List | The same five steps; beneficial owners at 10 per cent; sanctions and government-list checks; zero-tolerance risks | Annual assurance by a provider from LBMA's approved list, with a public Compliance Report and a confidential Country of Origin Annex | lbma.org.uk |
| RJC Code of Practices 2024 and Chain of Custody Standard 2024, both effective 1 January 2025 | RJC members; chain-of-custody certification is voluntary and requires Code of Practices certification first | COP 7 due diligence, including conflict-affected and high-risk areas; COP 7.2 requires refiners to report the origin of gold; the chain-of-custody standard covers eligible mined, recycled and legacied material | Independent audit by an RJC-approved firm; surveillance audit 12 to 18 months after certification; recertification before expiry | responsiblejewellery.com |
| RMI Responsible Minerals Assurance Process, Gold Standard, released 18 December 2017, revised 7 January 2023 | Smelters and refiners that join the process | An independent third-party assessment of the facility's management systems and sourcing practices; the RMI says it "is not a material validation assessment" | Public facility lists; an assessment is valid for one or three years | responsiblemineralsinitiative.org |
| UAE Due Diligence Regulations for Responsible Sourcing of Gold, August 2022, reinforced by Ministerial Decree No. 68 of 2024 | Gold supply-chain entities in the decree's scope and precious-metals dealers under Ministry supervision | Five steps; location and supplier red flags; beneficial owners at 25 per cent; enhanced due diligence where a red flag is found | Refiners and recyclers appoint a Ministry-approved independent reviewer and submit a due-diligence report | moet.gov.ae |
| Regulation (EU) 2017/821 | Union importers of tin, tantalum, tungsten and gold above the Annex I thresholds, from 1 January 2021; 100 kg a year for gold | Management system, risk management, third-party audit and disclosure, following the OECD five-step framework | Member-state authorities check documents and audit reports; in the UK it applies in Northern Ireland | eur-lex.europa.eu |
| Dodd-Frank Act section 1502 and the SEC conflict-minerals rule, 2012 | SEC-reporting companies that use conflict minerals necessary to their products | Annual disclosure of whether the minerals originated in the Democratic Republic of the Congo or an adjoining country; if so, a report on due diligence with an independent private-sector audit | The report filed with the SEC and published on the issuer's website | sec.gov |
| ICGLR Regional Certification Mechanism | Exporters in member states | Mine-site inspection and a certificate for each export | See the ICGLR certificate for gold | icglr.org |
A UAE Good Delivery refiner works under the UAE regulations and LBMA's guidance; its European customer may be an EU importer or an SEC issuer. Each pushes the same questions up to the seller.
The five OECD steps applied to a Ugandan lot
The OECD defines conflict-affected and high-risk areas by "the presence of armed conflict, widespread violence or other risks of harm to people", and includes areas of political instability, institutional weakness and widespread human-rights abuses.
Step 1, management systems: policy, structures and records. For gold the supplement asks an upstream company to collect, for every input, the mine of origin, the weight and assayed quality, the identity and ownership of every supplier and service provider, the taxes, fees and royalties paid, and how the gold was transported, and to keep the record for at least five years. In Uganda the law provides for most of that record; the chain-of-custody page sets out each document.
Step 2, risk identification. The Gold Supplement lists red-flag locations of origin and transit. Two of them touch Uganda directly. The first: gold "claimed to originate from a country that has limited known reserves or stocks, likely resources or expected production levels of gold". Uganda recorded about 62 tonnes of gold exports in 2025, far above any official figure for its own mines. The second: gold "claimed to originate from a country through which gold from conflict-affected and high-risk areas is known or reasonably suspected to transit". UN experts assessed the 2025 rise as largely attributable to gold originating in the Democratic Republic of the Congo, and the US Africa Gold Advisory points to eastern Congo as an area where gold finances conflict. LBMA's guidance carries both flags in the same words. A lot described as Ugandan therefore starts with red flags raised. They do not condemn it; they oblige the buyer to establish, through enhanced due diligence, where it was mined. See Uganda's production and export figures.
Step 3, risk response. The company decides what to do about each identified risk: continue with mitigation, suspend, or disengage. Under LBMA's rules non-conformances are rated medium-risk, high-risk or zero-tolerance; gold sourced in breach of international sanctions is zero-tolerance. The UAE regulations require enhanced due diligence, including site visits, before a high-risk supplier is engaged.
Step 4, independent audit. The OECD places the audit at the refiner, LBMA requires it annually from an approved provider, the UAE requires a Ministry-approved reviewer, and the RMI assesses the facility. No Ugandan refiner is on the LBMA or UAE Good Delivery lists, so for a Ugandan lot the audited point is the buying refinery abroad, whose auditor will look for the Step 1 records.
Step 5, reporting. LBMA refiners publish a Compliance Report; EU importers disclose; SEC issuers file. What a seller supplied becomes part of what the buyer reports.
What "responsible" does not mean
No framework on this page makes a seller "certified". The OECD issues no certificate. LBMA assurance is a conclusion on a refiner's annual report, not on any lot or supplier. The RMI says its assessment "is not a material validation assessment". RJC certification attaches to a member company, and its chain-of-custody standard to eligible material in the scheme. The ICGLR certifies mine sites and consignments, not traders. Ask a seller who claims to be "OECD-compliant" or "LBMA-approved" for the audit report or list entry, and check it with the issuer. Uganda Gold Report uses no such word about itself; the Uganda gold scams guide shows how borrowed accreditation appears in offers.
What a Ugandan route would need to show
| What the buyer's framework asks for | Where the requirement comes from | What a Ugandan route would produce |
|---|---|---|
| The mine of origin, named with the greatest possible specificity | OECD Gold Supplement Step 1; LBMA Step 2; UAE certificate of origin | The mineral right under which the gold was mined, the movement permit, and the dealer's register entry naming the place of origin |
| Volumes that reconcile with the source | OECD and LBMA red flag on limited known reserves; FATF red flag on consignments inconsistent with the exporter's scale | Weights that match from the movement permit through the register, the export permit and the arrival assay |
| Every holder identified, with owners screened | LBMA owners at 10 per cent; UAE at 25 per cent; OECD identity and ownership of all suppliers | Company records, identification of each beneficial owner and a dated sanctions check per name: see the five due-diligence checks |
| A lawful export | Mining and Minerals Act 2022 s.150; the 2024 export regulations | An export permit for this consignment, an authenticated certificate of analysis and an answer on the 99.9 per cent purity rule: see what each export document should prove |
| Origin documents for any gold not mined in Uganda | Mining and Minerals Act 2022 s.150(4)(d) | The origin country's export permit or related documents |
| A regional certificate where one exists | ICGLR Regional Certification Mechanism | See the ICGLR certificate; no gold instance has been established |
| An audited refiner at the end of the chain | OECD Step 4; LBMA; UAE; RMI | The buying refinery's own listing and audit, since no Ugandan refiner is on the LBMA or UAE lists: see gold refining in Uganda |
See also Uganda gold suppliers and 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 audit under any framework on this page, belong to no scheme, and have no relationship with any accredited refiner. We hold no stock, no Ugandan licence and no verified supply route, and no lot is documented to mine level today. What we publish is the standard a lot would have to meet, set out in the buyer compliance file. If you have a genuine requirement, send us your form, fineness, quantity and destination, 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 is responsible gold sourcing?
Due diligence on where gold came from and who handled it, carried out to the OECD's five-step framework: management systems, risk identification, a response strategy, independent audit and annual reporting. The OECD guidance defines the standard; LBMA, the RJC, the RMI, the UAE regulations and the EU regulation apply it to refiners, members, importers and dealers in their own ways.
Is the OECD guidance legally binding?
Not by itself. It is a government-backed recommendation. It becomes law where a jurisdiction adopts it: EU importers of 100 kg or more of gold a year must apply its five steps under Regulation (EU) 2017/821, the UK applies that regulation in Northern Ireland and expects importers into Great Britain to follow the guidance, and the UAE's regulations require the same steps of dealers and refiners under the Ministry's supervision.
Does any scheme certify a gold seller as responsible?
No. The OECD issues no certificate; LBMA assurance is a conclusion on a refiner's annual report; the RMI says its assessment is not a material validation; RJC certification attaches to a member company and its chain-of-custody standard to eligible material in the scheme; the ICGLR certifies mine sites and consignments. A seller who calls itself certified or approved should be asked for the audit report or list entry, and the claim checked with the issuer. Uganda Gold Report uses no such word about itself.
Why is gold from Uganda a red flag under these frameworks?
Two of the OECD Gold Supplement's red flags, repeated in LBMA's guidance, fit Uganda's figures: gold claimed from a country whose declared volumes are out of keeping with its known production, and gold claimed from a country through which gold from conflict-affected areas is suspected to transit. Uganda recorded about 62 tonnes of exports in 2025, far above any official figure for its own mines, and UN experts assessed the rise as largely of Congolese origin. The flags oblige the buyer to establish the mine of origin through enhanced due diligence; they do not condemn a lot in advance.
Is Uganda Gold Report audited under any of these frameworks?
No. We hold no audit, belong to no scheme, and have no relationship with any accredited refiner. We hold no stock, no Ugandan licence and no verified supply route, and no lot is documented to mine level today. The standard a lot would have to meet is set out in our buyer compliance file, and we say what can and cannot be quoted when you send a requirement.
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 |
|---|---|---|---|
| Conflict-affected and high-risk areas "are identified by the presence of armed conflict, widespread violence or other risks of harm to people"; high-risk areas "may include areas of political instability or repression, institutional weakness, insecurity, collapse of civil infrastructure and widespread violence" and "are often characterised by widespread human rights abuses". The five-step framework: 1. establish strong company management systems; 2. identify and assess risks in the supply chain; 3. design and implement a strategy to respond to identified risks; 4. carry out independent third-party audit (in the Gold Supplement, of the refiner's due diligence practices); 5. report annually on supply chain due diligence. Supplier identification includes "checking government watchlist information (e.g. UN sanctions lists, OFAC Specially Designated Nationals Lists, World-Check search)". | Official | OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, third edition, 2016: introduction, Annex I and Supplement on Gold; PDF downloaded and read 2 Nov 2026 | |
| Red flag locations of gold origin and transit: gold that "originates from or has been transported through a conflict-affected or high-risk area"; gold "claimed to originate from a country that has limited known reserves or stocks, likely resources or expected production levels of gold (i.e. the declared volumes of gold from that country are out of keeping with its known reserves or expected production levels)"; gold "claimed to originate from a country through which gold from conflict-affected and high-risk areas is known or reasonably suspected to transit"; and recyclable or mixed gold refined in such a transit country. The risk is increased where anti-money laundering and customs controls are weakly enforced, informal banking operates and cash is extensively used. Supplier red flags: suppliers or other known upstream companies operating in, or having sourced from, a red-flag location in the last 12 months. Step 4 objective: "To carry out an independent third-party audit of the refiner's due diligence". | Official | OECD Due Diligence Guidance, third edition, 2016, Supplement on Gold, Step 2 (pp. 78-79) and Step 4 | |
| 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, third edition, 2016: Step 1 C.4; Supplement on Gold, Step 1 B.5, as carried on the gold chain of custody page | |
| The Responsible Gold Guidance was finalised in November 2021 and "is the document that underpins LBMA's Responsible Sourcing Programme"; "All LBMA Good Delivery List Refiners must adhere to our Responsible Sourcing Programme", which includes "annual independent auditing and public reporting". Its five steps: Establish Strong Company Management Systems; Identify and Assess Supply Chain Risks; Design and Implement a Management Strategy to Respond to Identified Risks; Obtain Independent Third-Party Assurance on Supply Chain Due Diligence Practices; Report Annually on Supply Chain Due Diligence. The page does not mention the OECD. | Verified | LBMA Responsible Gold Guidance v9, overview page, read 2 Nov 2026 | |
| Step 2 requires "Identification and verification of Ultimate Beneficial Owners (UBOs) (defined as 10% or more ownership)" and "Confirmation that the gold-supplying counterparty and its UBOs are not named on any government lists" as money launderers, fraudsters or terrorists; sanctions lists (US, UK, EU, UN) are a location-risk source. Mined gold is high risk where it "Originates from, has transited or has been transported via a Conflict Affected and High-Risk Area (CAHRA)", "Is claimed to originate from a country through which gold from CAHRAs is known, or reasonably suspected, to transit", or "Is claimed to have originated from a country that has limited known reserves, likely resources" or expected production levels. Gold "known to be sourced in breach of international sanctions" is zero-tolerance. | Verified | LBMA Responsible Gold Guidance v9, Step 2, sections 2.1 and 2.2 | |
| "Assurance of the Refiner's conformance to the RGG is required on an annual basis"; "Refiners must select an Assurance Provider from the Approved Service Providers List"; the provider expresses a conclusion on the refiner's annual reporting, covering the public Compliance Report and the confidential Country of Origin Annex; reasonable assurance in year one, limited assurance in the following two years only if no medium-risk, high-risk or zero-tolerance non-conformances are identified. | Verified | LBMA Responsible Gold Guidance v9, Step 4, section 4.1 | |
| The current standard is the Code of Practices 2024, effective 1 Jan 2025; certification audits against the 2019 version ended on 1 Jan 2026 with listed exceptions. Members "have two years to get certified". "The auditor conducts an independent third-party certification audit on your organisation" by an RJC-approved audit firm; a surveillance audit is required "12-18 months after the certification start date"; recertification before expiry and no more than six months in advance. COP 7 (Due Diligence) was amended to clarify due diligence for responsible sourcing including from conflict-affected and high-risk areas; COP 7.2 requires refiners to identify and report the origin of mined and recycled gold. The page does not mention the OECD. | Verified | Responsible Jewellery Council, Code of Practices page, read 2 Nov 2026 | |
| The current Chain of Custody standard is COC 2024, effective 1 Jan 2025; "This certification is voluntary for RJC members"; members must be COP-certified before certifying to the COC, and the COC certificate's expiry must match the COP certificate's; the "COC standard defines an approach for companies to handle and trade gold, silver and platinum group metals"; eligible material is mined (COC 5), recycled (COC 6) and legacied (COC 7); independent third-party audit by an RJC-approved firm, surveillance audit 12-18 months after certification, recertification before expiry. | Verified | Responsible Jewellery Council, Chain of Custody page, read 2 Nov 2026 | |
| The RMAP is "an independent third-party assessment of smelter/refiner management systems and sourcing practices", carried out by RMI-approved assessors on operational smelters, refiners and recyclers; it "is not a material validation assessment"; assessments are valid for one or three years; participating facilities are publicly listed; "The RMAP standards are developed to meet the requirements of the OECD Due Diligence Guidance" and cite Regulation (EU) 2017/821 and the Dodd-Frank Act. | Verified | Responsible Minerals Initiative, Responsible Minerals Assurance Process page, read 2 Nov 2026 | |
| "Responsible Minerals Assurance Process, Gold Standard": released 18 Dec 2017, "Minor revisions released on 7 January 2023", effective 1 Jun 2018; relevant regulations Dodd Frank Act 1502 and the EU Conflict Minerals Regulation. "The RMI defines standards for smelters, refiners and recyclers that participate in the Assurance Process." | Verified | Responsible Minerals Initiative, Standards page, read 2 Nov 2026 | |
| Ministerial Decree No. (68) of 2024 concerns gold refineries' adherence to the Due Diligence Regulations for Responsible Sourcing of Gold. Entities in the gold supply chain within the decree's scope and precious-metals dealers under the Ministry's supervision "are required to implement" due diligence: Step 1 establish strong company management systems; Step 2 identify and assess risks in the gold supply chain; Step 5 report on supply chain due diligence activities where applicable; refiners and recyclers must "appoint an independent third-party reviewer" approved by the Ministry and submit a report. Regulations Version 1, August 2022: location red flags include CAHRAs or countries subject to international sanctions, limited discovered reserves, transit countries, and countries with weak money-laundering oversight and cash-intensive economies; supplier KYC includes beneficial owners at 25% and above; EDD, including site visits, is carried out before engaging a high-risk supplier and at least bi-annually. | Official | UAE Ministry of Economy and Tourism, Due Diligence Regulations for Responsible Sourcing of Gold, ministry page read 2 Nov 2026; regulations text read from the project's saved copy, sections 2.2 and 2.3 | |
| EU importers at or above 100 kg of gold a year must run supply-chain due diligence (management system, risk management, third-party audit, disclosure), applying from 1 Jan 2021; importers below the threshold are exempt. The EUR-Lex text could not be opened on 2 Nov 2026 (empty response); the row stands on the earlier reading. | Official | Regulation (EU) 2017/821, Art. 1(3), 4 to 7, 20 and Annex I, as carried on the buying gold from Africa page | |
| The regulation "aims to help stem the trade in four minerals", tin, tantalum, tungsten and gold; it "applies directly to between 600 and 1,000 EU importers"; importers' obligations started on 1 Jan 2021; importers must follow the five-step framework of the OECD Due Diligence Guidance; member-state authorities check compliance by reviewing documents and audit reports and can carry out on-the-spot inspections; downstream companies beyond the metal stage have no mandatory obligations. | Official | European Commission, Conflict Minerals Regulation explained, read 2 Nov 2026 | |
| UK government guidance states that businesses have a statutory requirement to comply with the OECD guidance only in Northern Ireland, and that the government expects all companies importing tin, tungsten, tantalum and gold into Great Britain to also comply with it. | Official | GOV.UK (FCDO), Importing conflict minerals into Northern Ireland, 27 Jan 2021, as carried on the buying gold from Africa page | |
| The SEC's conflict minerals rule, issued 22 Aug 2012, effective 13 Nov 2012, implements Section 1502 of the Dodd-Frank Act, which added Section 13(p) to the Securities Exchange Act of 1934 and "requires the Commission to promulgate rules requiring issuers with conflict minerals" necessary to their products to disclose annually "whether any of those minerals originated in the Democratic Republic of the Congo or an adjoining country"; if so, the rule "requires the issuer to submit a report to the Commission that includes a description of the measures it took", including an independent private sector audit, and to make the information public on its website. Compliance from the calendar year beginning 1 Jan 2013; page last reviewed 16 Jul 2025. The page does not list the adjoining countries or name the four minerals; the statutory definition was not re-read for this page. | Official | US Securities and Exchange Commission, Conflict Minerals final rule page, read 2 Nov 2026 | |
| 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 | |
| In June 2023 five US departments and USAID issued an Africa Gold Advisory naming conflict and terror financing, money laundering, sanctions evasion, human-rights and labour abuses and environmental harm among the risks, pointing to eastern DRC, Sudan, CAR and Mali, urging US individuals and entities to apply enhanced due diligence as appropriate and necessary; it states that it does not have the force of law. | Official | US Africa Gold Advisory, 27 Jun 2023, as carried on the buying gold from Africa page; PDF re-read 2 Nov 2026 | |
| FATF lists misclassified purity, weight, origin and value, and consignments inconsistent with the exporter's scale, as gold red flags. | Verified | FATF, ML/TF risks and vulnerabilities associated with gold (July 2015), as carried on the buying gold from Africa page | |
| No Ugandan refinery appears on LBMA's Good Delivery List for gold (67 refiners, 26 countries, read 2 Nov 2026) or on the UAE Good Delivery active gold membership list (version dated 27 Aug 2026, 9 members). | Official | LBMA Good Delivery List, gold, and UAE Good Delivery gold membership validity list, version 72, as carried on the gold refining in Uganda page | |
| 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. s.143: the dealer's register records each purchase with the vendor's right to possess the minerals and the place of origin; Form 57 movement permit and Form 66 monthly return give licence numbers and the original source. | Official | Mining and Minerals Act 2022 (Uganda), assented copy, ss.143 and 150, and the Mining and Minerals (Licensing) Regulations 2023 forms, as carried on the gold chain of custody 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." Regulation 2 states a levy on processed gold to be exported of USD 200 per kilogram. Current force not confirmed. | Official | Mining and Minerals (Export of Refined Gold) Regulations 2024, S.I. 30 of 2024, regulations 2 and 3, as carried on the gold refining in Uganda page | |
| Whether Uganda has issued any ICGLR certificate for gold has not been established; the certificate is issued by a member state for a consignment after mine-site inspection. | Subject to verification | Uganda Gold Report, the ICGLR certificate for gold (staged draft), and its draft notes | |
| Search volume for "responsible gold sourcing" has not been read in SEMrush; no volume figure is stated on this page. | Subject to verification | SEMrush reading pending (free plan; manual read required) |