Sanctions screening for a gold transaction: the lists, the names, the record

Which lists apply to a gold deal, and why

The law that binds a party is the law of its own jurisdiction: a UK company is bound by UK sanctions, a US bank in the payment chain by US sanctions. In practice the standards that govern gold ask for all the main lists at once. LBMA's Responsible Gold Guidance requires a refiner to check "Sanctions lists (US, UK, EU, UN, and relevant sanctions lists)" and to confirm that the supplying counterparty and its beneficial owners are not named on any government list as wanted money launderers, fraudsters or terrorists. The UAE's due-diligence regulations treat a supplier or beneficial owner "listed under international sanctions regulations" as a red flag. The OECD guidance names "UN sanctions lists, OFAC Specially Designated Nationals Lists" among the watchlists to check.

Name lists are not the whole picture. Sanctions can attach to the metal. The UK has prohibited the import and acquisition of gold exported from Russia on or after 21 July 2022, extended on 29 October 2022 to gold processed in a third country that incorporates such gold, with related prohibitions on financial services, funds and brokering. The United States has prohibited imports of gold of Russian Federation origin since 28 June 2022. A screen therefore asks two questions: is anyone involved listed, and is the origin of the gold itself prohibited? The second is answered by the lot's records, not by a name search: see gold chain of custody.

Whose names must be screened

A check that stops at the seller misses most of the exposure. The one Ugandan gold designation on the public record listed a refinery under two names, with its Ugandan registration number, its owner under three name variants, and companies linked to him in the United Arab Emirates, the Seychelles and Belgium. OFAC's prohibitions extend to any entity in which a designated person holds a 50 per cent or greater interest. LBMA refiners identify beneficial owners at 10 per cent or more; the UAE regulations at 25 per cent.

Search variants as well as the names on the contract. OFAC's search tool uses approximate matching with a threshold slider and says that it "does not provide recommendations with regard to the appropriateness of any specific confidence rating".

How to run a check, and what to keep

1. Collect the exact names from source documents: the certificate of incorporation, the licence entry, the passport or identity document, and the contract. Add former names, aliases, registration numbers, dates of birth and addresses.
2. Search each name on each list on the same day. Note the list's date or version and, on OFAC's tool, the threshold you set.
3. Record every result, including the clear ones, and keep a screenshot or export of each.
4. Treat any possible match as a stop. Resolve it against identifiers, such as date of birth, nationality, address and registration number, and write down why it was or was not the listed person.
5. Repeat before the contract, before shipment and before each payment.

A "no match" result is a statement about those names, on those lists, on that date. It says nothing about the lot, the licence or the origin. A confirmed hit stops the deal until it is resolved: the US Africa Gold Advisory warns that those who do business with or support a sanctioned person "may expose themselves to an array of consequences, such as potential designations, civil penalties, or other legal actions".

What is on the public record for Uganda

Three points. First, no sanctions programme is named for Uganda. OFAC's list of 36 active programmes contains none, and the UK's list of regimes, updated 25 March 2026, contains none. The designations that touch Uganda were made under other programmes against named persons and companies.

Second, one Ugandan refinery is designated. On 17 March 2022 OFAC designated African Gold Refinery Limited, also known as African Gold Refinery Uganda, of Entebbe, with Uganda registration number 180334, under its Democratic Republic of the Congo programme, together with Alain Francois Viviane Goetz and eight linked companies abroad. The Africa Gold Advisory of June 2023 describes the action as the designation of "an individual, his primary company, and his derivative networks for illicit movement of hundreds of millions of dollars' worth of gold and contributing to violence and instability in DRC". Both names were on the SDN file we downloaded on 2 November 2026, and we found no delisting. Our earlier search found no UK or EU listing of the same names; a negative search is not proof of absence, and we have not re-run it for this page. The record is on gold refining in Uganda; we name no other refiner.

Third, our own position. Enquiries to Uganda Gold Report are screened against the UK, EU, UN and US lists before any commercial engagement, and again before any contract, shipment or payment. Until we have taken UK sanctions legal advice, we do not accept enquiries involving Russia or Belarus: delivery there, payment from or through there, or parties located or incorporated there. We do not accept gold of Russian origin. That exclusion is a precaution pending advice, not a statement of what the law requires in every case. The other checks are in the five due-diligence checks and 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.

We screen enquiries against the public UK, US, EU and UN lists before any commercial engagement. We have screened no counterparty beyond public-list name checks, because we have no counterparty yet: no supplier, no buyer, no refinery relationship, no stock and no Ugandan licence. We have engaged no screening service. 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.