KYC, AML and OECD Due Diligence for Gold Doré Finance
Gold doré is a high-value intermediate product. It attracts the same criminal attention as refined gold, and it sits in a supply chain that the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas specifically.
Gold doré is a high-value intermediate product. It attracts the same criminal attention as refined gold, and it sits in a supply chain that the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas specifically addresses through its Supplement on Gold. A finance file from a mining company or a refiner that cannot show who produced the metal, how it left the mine or the collection point, and who will refine or buy it, is not a short document set. It is an incomplete mandate.
This guide supports the existing money pages on gold doré trade finance and gold doré bar supply chain finance. It does not replace them, and it does not replace Gold Doré Sourcing, Only If Legitimate or the group article on gold doré bar scam red flags. Read those first if the offer is a discounted unofficial bar. Financely is an advisor and arranger, not a lender, not a refiner and not a bullion dealer.
What the OECD guidance expects you to be able to show
The OECD guidance sets a five-step due diligence framework: establish strong management systems, identify and assess risks in the supply chain, design and implement a strategy to respond to identified risks, carry out independent third-party audits at identified points, and report annually on due diligence. The Supplement on Gold applies that framework to gold, and it distinguishes upstream actors, miners, local exporters, recyclers and international traders, from downstream actors. Companies are expected to carry out due diligence whether they own, lease or loan the gold.
The guidance is not a certificate you buy. It is a process. For a doré finance file, that process has to be visible in documents: mining or export rights, chain-of-custody records, transport and security, export permits, and a refining or offtake path that can be named. Artisanal and small-scale production is not automatically ineligible, but it is not a reason to skip steps. The OECD has published a separate FAQ on responsible supply chains in artisanal and small-scale gold mining, which is worth reading if that is the actual source of the metal.
LBMA, refiners, and why the exit matters
Refiners that wish to be accepted on the London Bullion Market Association Good Delivery system are expected to apply the LBMA Responsible Gold Guidance, currently in Version 9, which is built on the OECD framework. A capital provider looking at a doré shipment will often ask which refiner will receive the bars, whether that refiner will actually accept the origin, and how the assay and the settlement will work. A vague plan to sell into Dubai or to find a refinery later is not an exit.
Independent assay is part of that exit, just as independent Q&Q is part of a fuel file. Weight, fineness and impurities have to be established under a method the offtaker recognizes. The existing supply-chain page discusses production, assay, export and settlement in the wider facility context. The pre-financing note for small-scale miners exporting doré to Dubai is a narrower case study of that path, not a template for every origin.
KYC and AML are not a second file, they are the same file
Know-your-customer work on the applicant, the supplier, the offtaker and any agents sits beside know-your-transaction work on the metal. Banks will ask about beneficial owners, source of wealth, the purpose of the account, and whether the payment path could be used to launder proceeds. Sanctions screening applies to people, companies, aircraft, vessels and, where relevant, the place of origin. Financely does not give legal advice, and it does not waive a bank's own policy.
Offers that skip this work, and go straight to a discounted unofficial bar, a locked warehouse and a request for an advance fee, are described in the gold doré scam article. If you are still at the sourcing stage, stay with legitimate doré sourcing and commodity sourcing. Do not force a finance mandate onto a seller who cannot be named.
| Diligence area | What a capital provider usually wants to see | What usually stops the file |
|---|---|---|
| Origin and rights | Mining, buying or export authority that can be verified in the producing country | A trader who will not name the mine, the cooperative, or the exporter |
| Chain of custody | A documented path from source to the export point, with transport and security records | A gap between the claimed mine and the bars now sitting in a warehouse |
| Counterparty KYC | Beneficial owners, identity documents, and a business that exists outside the deal | Nominee companies, or an agent who will not identify the principal |
| Refinery or offtake | A named refiner or buyer that can accept that origin, plus an assay and settlement plan | A promised sale to the market, with no offtaker and no assay protocol |
What a failed doré file usually looks like
The bars are already said to be in a warehouse, but the warehouse will not confirm the account. The seller wants an advance to pay an export tax or a local official. The assay is a letter with no sampling protocol. The offtaker is described as the market. The company is newly formed and the beneficial owners are unclear. Any one of those facts can be enough to stop a review. Several of them together is the pattern already described in the scam article, and it should not be dressed up as a short-term finance request.
A workable file is slower and more boring. It names the source, shows the documents, accepts that a refiner may refuse the origin, and treats KYC as part of the trade, not as an insult. That is also why this guide does not quote fees, assays or typical tenors. Those terms, if a capital provider engages, are set in that engagement.
How to bring a doré finance mandate to Financely
The engagement is paid advisory. We review the origin file, the KYC pack, the export path, the assay and offtake plan, and the repayment structure, then introduce complete files to capital providers. We do not promise that a refiner or a bank will accept the metal. Submit what you have through deal submission, and say clearly if any part of the chain is still unconfirmed.
Frequently Asked Questions
Is OECD due diligence a certificate I can buy?
No. The OECD Due Diligence Guidance is a five-step process, with a Supplement on Gold. A finance file has to show that the process has been applied to the actual metal, including origin and chain of custody, not that a generic certificate was purchased. Financely advises and arranges. It does not certify the metal.
Does artisanal gold automatically fail a finance review?
No, but it does not skip steps. Origin, chain of custody, export rights, and offtake still have to be evidenced. The OECD has published a FAQ on responsible sourcing from artisanal and small-scale gold mining. A discounted unofficial bar remains a warning sign, not a shortcut around that work.
Why does the refiner matter so much?
The refiner is often the exit that repays the facility. LBMA Responsible Gold Guidance Version 9 is the usual responsible-sourcing standard for Good Delivery refiners. A refiner that will not accept the origin is not a repayment path. Financely does not buy, hold, or refine doré, and it does not lend.
Does Financely buy or refine doré?
No. Financely is an advisor and arranger only. It does not lend, buy, hold, or refine gold doré, and it is not a bullion dealer. A complete KYC, AML, and OECD due diligence pack is what a capital provider expects to see before it will consider a mandate from a mining company or other bankable principal.
Financely is an advisor and arranger, not a lender and not a supplier. If you have a real transaction and need a lender-ready file, submit the mandate through the intake form.
You can also read how structured trade finance advisory is scoped before you send the file.
Sources and references
- OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, third edition, including the Supplement on Gold.
- OECD FAQ, Responsible Supply Chains in Artisanal and Small-Scale Gold Mining.
- LBMA Responsible Gold Guidance Version 9: https://www.lbma.org.uk/publications/responsible-gold-guidance-v9
- Financely deal submission: https://www.financely.io/deal-submission