【London, UK】Responsible Sourcing Newsletter: Uniting Markets, Assurance Programme Enhancements & CoO Reporting Framework

LBMA is delighted to announce the appointment of Nirali Shah as its new Sustainability & Responsible Sourcing Director. With over two decades of experience in sustainability, responsible sourcing, and assurance within the precious metals sector, Nirali brings deep practical expertise to further LBMA’s mission of advancing integrity and transparency in precious metals value chains.

Late last month, Ruth Crowell (CEO, LBMA) and Nirali Shah (Director of Sustainability and Responsible Sourcing, LBMA) attended the Dubai Precious Metals Conference to advocate for better convergence and cooperation between leading actors in the precious metals industry.
Illicit flows erode trust in global supply chains and weaken market resilience. For economies reliant on gold revenues, the risks are real – and growing. It’s time for every gold hub to lead.
Five years ago, LBMA set out clear recommendations for International Bullion Centres. While progress has been made behind the scenes, today – with gold well above $4000/oz and new sourcing threats from emerging conflict zones like Sudan or the Sahel – the need for collective action is greater than ever.
LBMA has taken several concrete steps to increase governance and transparency in gold supply chains since our initial IBC announcement in 2020. The Responsible Gold Guidance version 9 (RGG9) introduced new requirements for intermediate refiners based in high risk locations that supply GDLs to undergo an OECD aligned assurance. We launched the ASM Toolkit to address the market avoidance and lack of appropriate due diligence over a significant source of feedstock to global gold markets. This month, we will publish an updated Disclosure Guidance that makes LBMA the first industry scheme to meet the transparency requirements governing OECD Red Flag locations.
LBMA is refreshing our original IBC recommendations, starting with discussions in the UAE to jointly update recommendations and practical next steps.
Our focus is on ways to:

– Tackle risks in hand-carried gold
– Formalise transaction systems
– Increase transparency in governance and enforcement
– Support ASM through responsible frameworks
Criminality has no place in gold hubs. It impacts all of our reputations, irrespective of where it happens.
Looking ahead to 2026, LBMA will announce further details early in the new year on how we plan to advance cooperation and practical solutions with partners in key International Bullion Centres.

By Amardeep Rihal (Policy Manager, LBMA)
Enhancing the assurance programme has been a key focus this year. We have introduced a number of measures – covering training, tools and guidance – to support Approved Assurance Providers (AAPs) and, in addition, strengthen the Responsible Sourcing Programme. Here’s what’s new:
AAP Terms & Conditions

We have introduced significant updates to the AAP application process. The AAP form is structured into the following three key components:
1. AAP Terms & Conditions: Introducing a robust framework, including higher entry thresholds;
2. Applicant Firm Core Competency Form: Aligned with ISAE 3000 and ISQM 1 standards, this form sets comprehensive requirements for ethics, independence, and quality management, alongside firm attestations;
3. Individual Applicant Capability Form: A new addition designed to capture technical skills and practical experience. Applicants will self-assess proficiency across four levels.
AAP Toolkit
The AAP Toolkit is a series of templates and forms designed to provide AAPs with a standardised structure for assurance planning, execution and reporting. Centred in advancing consistency, transparency and quality across assurance engagements, the AAP Toolkit will be used for assurance engagements from 1 January 2026.
AAP Training
This year, we introduced case study focus sessions to explore both contextual supply chain risks and the use of investigative approaches to identify and assess scenarios. These were designed to further support AAPs to think critically and challenge Refiners during the assurance process. Rolled out across six half-day sessions, over 125 AAPs attended the training.

By Varsha Peiris (Standards and Assurance Manager, LBMA)

LBMA has introduced periodic reporting of Country of Origin (CoO) data. As announced at LBMA’s 2025 Global Precious Metals Conference in Kyoto, next year will be the implementation year for periodic reporting, and 2027 will be mandatory – where all Good Delivery List Refiners will be expected to report their CoO data monthly via the Gold Bar Integrity (GBI) platform.