While attention on the role of gold in the illicit transfer and storage of value has increased, the global trade in gold concentrates – unrefined gold in containerised bulk bags – is exposed to distinct vulnerabilities that can be exploited for gold laundering (concealing the origins of gold) and gold-based money laundering (using gold to launder the proceeds of crime).
The profile of gold concentrate makes it vulnerable to trade‑based money laundering; it is lightly tracked, poorly understood, difficult to price, shipped in bulk as an unremarkable material, passed through copper-dominated trading and processing circuits, and can be easily mis-invoiced or mis-declared without attracting the scrutiny applied to refined gold. The amount by which declared imports for the relevant HS Code surpassed corresponding exports increased 400% between 2020 and 2024, with the discrepancy in 2024 amounting to a third of all concentrates imports in value terms. (UN Comtrade).
Significant volumes of gold concentrate are traded internationally and transported in maritime containers. In 2024, over 15% of world primary gold production was shipped as concentrate (MetalsFocus, 2025[1]). For context, while concentrate grade varies significantly, mined production of gold globally amounted to about USD 280 billion the same year, rising however to over USD 400 billion in 2025 due to the surge in gold prices. In addition, several key gold-producing countries have significantly increased exports of gold concentrate.
The beneficiation, blending and transformation stages of gold concentrate involve significant laundering risks, particularly in contexts where due diligence is weak or absent. Processing facilities that source material from multiple suppliers blend inputs in ways that, when accompanied by incomplete or falsified documentation, can obscure the origin of illicit gold.
It is important that law enforcement personnel are trained and equipped to detect and analyse crime typologies linked to gold concentrates. Policymakers might also consider introducing stricter licensing and oversight of processing plants and smelters.
All private sector actors in the gold and copper supply chains – especially processing plants, traders, refiners and smelters – should conduct enhanced due diligence on gold concentrates in line with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD, 2016[2]).
Illicit flows of gold concentrates in the maritime space
As attention to both supply chain due diligence and illicit financial flows has grown in recent years, gold has emerged as a favoured medium for the illicit storage and transfer of value (OECD, 2022[3]; OAS/DTOC, 2022[4]; FATF, 2015[5]). Elevated gold prices make this challenge more urgent and acute. Illegal gold mining, gold laundering (concealing the origins of gold), gold-based money laundering, using gold to launder the proceeds of crime), and gold-based sanctions evasion are widespread and corrosive to public institutions and trust (OECD, 2022[3]; Kennedy, John, et al., 2024[6]); Kennedy et al., 2024).
The reasons for these developments are fairly straightforward: gold is a highly portable, concentrated form of wealth; it is fungible and holds its value around the world, making it ideal for transferring wealth outside the formal global financial system; it can take many forms that allow for fraudulent or surreptitious movement; and it is not intrinsically illicit and can therefore be easily used to exploit legitimate supply chains (OECD, 2021[7]). Despite increasing scrutiny, some illicit gold flows have remained largely unexamined and pose considerable risks, including the most severe risks addressed by OECD standards on responsible business conduct like conflict finance, human rights abuses and financial crime (OECD, 2016[2]).
This brief focusses primarily on one of those typically overlooked flows: the global trade in gold concentrate, which presents distinct vulnerabilities. This form of gold is linked to illicit flows by organised criminal groups and often contributes to the intermingling of licit with illicit sources of supply (OECD, 2022[3]). In the Harmonised System (HS) of the World Customs Organization, gold concentrate falls under HS code 261690 for both raw ores and concentrates of precious metals other than silver. While this report focusses primarily on concentrate, it also addresses risks linked to the movement of raw gold ore through the global supply chain, especially in the often‑overlooked maritime space. It is noteworthy that some of the same risks and vulnerabilities apply to critical minerals essential to the energy and defence sectors (The Payne Institute for Public Policy at the Colorado School of Mines, 2025[8]).
A combination of factors makes concentrate attractive for trade‑based money laundering (TBML). In addition to its usefulness for gold laundering, it is unfamiliar to many in customs and law enforcement, is not widely tracked, and can easily be mis-invoiced or mis-declared due to the complexity of assessing its real value. It also moves in large quantities on cargo ships, where relevant authorities seldom look for gold bars, much less for concentrates that resemble dirty sand in big bags.
Existing analyses of the gold trade focus on either gold bars or gold jewellery. Gold bars of investment grade, such as Good Delivery bars of the London Bullion Market Association (LBMA), are physically moved as little as possible from secure vaulting facilities, though their ownership may change many times. While gold in all forms, from refined gold to semi-refined doré and unprocessed ore, remains subject to severe risks, scrutiny of gold jewellery and recycled gold has increased, and these materials have become subject to efforts of enhanced due diligence.
Gold concentrate has not been subject to comparable levels of scrutiny. This lack of attention is largely due to a prevailing focus among analysts and policymakers on illicit flows of doré and high-grade recycled gold. Relatively few analysts or regulators are sufficiently knowledgeable about gold concentrate to assess risks linked to it, or to detect illicit activity in the concentrate market.
Concentrate is gold that does not look at all like gold and does not transit through what most observers think of as the gold supply chain. Moreover, nearly all gold concentrate travels by sea, often in large consignments of many shipping containers. In focussing almost exclusively on gold bars, jewellery, and high-grade recycled gold (over 40% purity), all of which generally travel by air, analysts have tended to disregard the maritime space as a significant arena for illicit gold flows (LBMA, 2022[9]).
This gap in knowledge and awareness, coupled with the transparency challenges of the physical trade of gold concentrate, poses risks unmatched by any other form of gold circulating in global markets, and necessitates a careful assessment of those vulnerabilities and what can be done to mitigate them.
A productive gold mine might average five to seven grammes of gold per tonne (g/t) of raw ore. Because transporting such large quantities of low-gold-content material is inefficient, mines often carry out initial on-site processing to increase the gold concentration before the material is moved.
There are two main approaches to initial processing after milling the raw ore. The first is by liberating the gold to form doré bars, which can be accomplished either by leaching the gold out of the ore with cyanide or another lixiviant that dissolves and carries gold, or by using mercury to bond with the gold particles and form an amalgam, from which the mercury is then boiled off. The ensuing leakage of mercury into rivers, ground water and soil after use by informal and illegal miners has devastating environmental and public health impacts around the world. The second form of initial processing uses a range of technologies, from simple gravity separation at the artisanal level to sophisticated froth flotation techniques at industrial mines, to increase the overall percentage (known as the tenor) of gold in the milled ore. The result is gold concentrate, which resembles dirty sand, and may carry a gold content of anywhere from about 20 g/t at the artisanal end to well over 100 g/t, depending on the degree and sophistication of processing. Gold concentrate is mostly produced by large‑ and medium-scale mining, but concentrates are becoming increasingly important as artisanal and small-scale mining continues to mechanise worldwide. While most primary gold is processed and transported as doré, some producers opt for concentrates due to security considerations. In other cases, specific ore characteristics and technical requirements make shipping gold as concentrate the more practical option, when for example the ore is refractory (not free‑milling) and cyanidation is problematic or impossible (de Sousa, 2021[10]).
In many deposits, gold occurs together with copper, meaning that a significant portion of gold is produced not as a standalone gold concentrate, but as a by-product within copper concentrates or other polymetallic concentrates (com-d‑181122). Partly for this reason, gold concentrate does not go to refineries, but to base metal smelters – often copper smelters – or to roasters that use high heat to make the gold in the concentrate susceptible to subsequent cyanidation (de Sousa, 2021[10]). National and international traders play a key role in purchasing ore containing copper and gold, including from artisanal and small-scale production, sometimes blending concentrate from different sources to achieve favourable quality specifications (Grupo Propuesta Ciudadana, 2025[11]). Following this stage of processing, gold originating from concentrate, having been transformed into more commonly traded forms, continues to refineries.
While much gold concentrate goes directly from large mines to smelters, or to commodity traders that then sell to smelters, there are also artisanal and small-scale flows through local or regional trading intermediaries. Gold concentrate is usually shipped in large one‑tonne totes, also known as “bulk bags” or “big bags,” which are then containerised (com-b‑090522). Significant volumes of gold concentrate are traded internationally and transported via maritime container routes. As of 2024, just over 15% of world primary gold production by volume, was shipped as concentrate, though the trade data discrepancies discussed below suggest that actual volumes (and value) may be higher (MetalsFocus, 2025[1]).
Country-level trade data on the Harmonised System code for gold concentrates (HS 261690) provides only a high-level perspective, underscoring the opacity of the trade in gold ores and concentrates. Given the inconsistencies and potential inaccuracies in reported data, findings should be interpreted with caution, but significant discrepancies between what one country exports and what another country imports may be an indication of smuggling, fraud, trade‑based money laundering or other financial crimes. Broad data on HS 261690 show growing divergence between import and export records from 2020 to 2024, widening significantly in 2024. The mismatch increases by nearly 400% over four years (from USD 873 million in 2020 to USD 4.31 billion in 2024). In 2024, the discrepancy alone amounts to roughly one‑third of all reported global gold concentrate imports.
Discrepancies related to one of these trade relationships are detailed in the following table, which shows annual exports of HS 261690 from two Latin American countries to Country A, a large importer of raw ores and concentrates.
Source: UN Comtrade.
Note: A standard 5% downward adjustment is applied to import values to approximate Free On Board (FOB) equivalence, reflecting standard differentials between Cost, Insurance, and Freight (CIF)-reported imports and FOB-reported exports. Precious metals are generally associated with the lowest CIF/FOB margins globally (Fiallos, 2024[12]).
Country B and Country Care Latin America’s two biggest exporters to Country A, and for each there are significant reporting discrepancies in quantity as well as declared value. Although aggregation and trans-shipment, and to some degree varying grades of concentrate or different ways of measuring grade, may contribute to discrepancies, they cannot explain the magnitude of such discrepancies, and raise serious questions, especially in light of organised crime involvement in illegal mining and illicit gold flows in both exporting countries.
Striking discrepancies are also evident in European trade data as reported to UN Comtrade. In one case, an exporting country reported sending 5 486 kg of concentrate valued at USD 12 498 to a trade partner; the importing country reported receiving 54 365 kg of concentrate valued at nearly USD 163.5 million. Concentrate exported at a calculable unit price of USD 2.28 per kg arrived in its destination country valued at over USD 3 000 per kg. The trade is rendered even more problematic by the fact that the importing country has virtually no capacity for processing concentrate. As HS 261690 also covers platinum group metals (PGMs), it is theoretically possible that the reporting of both countries includes the value of closed-loop recycling of PGMs with their trading partners. Given the complex transactions of the metals trade, the reporting may also reflect an erroneous conflation of where the concentrate is physically moving and where the money in the transactions is flowing. In any case, these discrepancies, compounded by limited institutional and technical capacity within customs and other oversight bodies, could expose the sector to criminal exploitation.
Variations in reported trade flows, combined with discrepancies in reporting and additional qualitative indicators, suggest the need for closer monitoring. For example, one Southeast Asian country with a strong record of consistent trade reporting – but experiencing a rise in illegal mining – indicates no exports of gold concentrate to the principal importing country despite thorough reporting on other mineral exports. One of its trading partners, however, reports importing no gold concentrate from the exporting country in 2019, then over 100 000 t valued at nearly USD 372 million in 2022, and over 262 000 t valued at over USD 1 billion in 2024. None of that concentrate can be found in transaction-level trade data from such platforms as Panjiva and Abrams.wiki. While it is conceivable that gaps or errors in reporting may explain the lack of reported exports from the exporting country, the stunning rise of reported imports into the destination country, corresponding with a similar rise in illegal mining in the origin country, indicates how the trade in HS 261690 has grown, with attendant risks of gold laundering, fraud, and illicit financial flows.
Anomalous patterns in trade data, in addition to specific characteristics of the gold concentrate market, indicate that this commodity may be exposed to significant vulnerabilities.
1. There are no price benchmarks for gold concentrate, nor are there publicised short-term or spot pricing agreements. While refined mineral price indexes may serve as a reference, prices are typically agreed ad hoc between buyer and seller for each transaction (de Sousa, 2021[10]). This adds a layer of opacity to the concentrate supply chain, as there is no definite way for an external observer to discern the relationship between the unit price of a cargo and its actual gold content.
In terms of typologies, this creates space for mis-declaring the purity, and hence the value, of a cargo of gold concentrate. In one producer country, transaction-level trade data from the platforms SICEX and Panjiva indicate that the declared tenors of some export cargoes are on the order of 15 g/t – too high to be raw ore, but not high enough to have been beneficiated to industry standards. Such numbers suggest the possibility that the grade of the concentrate is being mis-declared (or, alternatively, that industry-grade concentrate is being blended with ore or low-grade concentrate of uncertain origin). In another, an industry source described a typical form of customs fraud as raising the grade of concentrate to 80‑100 grammes per tonne but declaring it for export at only 6 grammes per tonne, while claiming to lack the technology to beneficiate milled ore (com-b‑090522). This simple tactic can both reduce royalties and allow for significant quantities of illicit gold to be introduced covertly into otherwise legitimate flows. This modality extends to double invoicing for the purposes of customs fraud: a false, lower-value invoice is presented to authorities, while a separate, accurate invoice is issued to the importer for payment.
2. Most authorities are unfamiliar with gold concentrate as a commodity. Mis-declaring gold as a different commodity is therefore a low-risk endeavour. Customs authorities often lack the equipment to assay a load of gold concentrate (com-b‑090522; com-c‑090622). According to a subject-matter expert, there is currently no systematic monitoring of gold concentrate movements (cso-b‑291122). The lack of knowledge and equipment on the part of authorities makes it easy to mis-declare gold concentrate as a similar-looking commodity, such as copper concentrate or even sand. In a case in 2020, illegally mined gold was exported from a producer country bagged and containerised as silver, zinc, and copper concentrate (Vera, 2020[13]). In 2018, a mining company was accused of having concealed gold concentrate in bags as “fine coal” departing from its country of origin (proceedings were ended following a settlement agreement in 2024) (Agence France-Presse, 2019[14]; LeFaso.net, 2024[15]). Trade data also suggests that it may be feasible to disguise gold concentrate as sand given that exporters and traders routinely move cargoes of sand and other mineral concentrates out of the same ports as gold concentrate.
The lack of knowledge and appropriate technologies by authorities also opens the door to exploiting gold concentrate for the purposes of laundering the proceeds of crime. Historically, various forms of gold have been employed to launder criminal proceeds: gold is purchased with illicit funds and subsequently reintroduced into legal markets. Gold concentrate, which is often subject to less rigorous due diligence than gold bars, can facilitate this laundering typology.
3. Gaps in due diligence by initial processing plants increase the risk of laundering. Initial processing plants may serve to introduce illegally sourced gold into the legal market by blending it into concentrate prior to export. According to an investigative report, 2023 saw a sharp rise in exports of gold falsely declared as having been mined in concessions owned or operated by a handful of companies examined in that country (Torres, 2025[16]). In a recent case, a mining company linked to a drug trafficking organisation was contracted to operate a gold mine in exchange for a percentage of the mine’s production. In 2023, the operating company reported extracting over 11 000 t of crude material across 197 hectares, but there was no evidence of actual extractive operations. In 2023/24, the company exported 827 t of gold concentrate to a buyer abroad (Torres, 2025[16]).
As in the case above, an initial processing plant that beneficiates gold concentrate can source its material from many suppliers. Blending that material for onward sale, especially without sufficient documentation (or with fraudulent documentation), allows for the laundering of illegally sourced gold. According to an expert source, in one producer country, criminal organisations accustomed to laundering gold by using falsified documentation naming fictitious miners may sometimes run “out of fake miners,” – for instance due to increased scrutiny by authorities or the depletion of the roster of individuals willing to pose as miners or whose personal data has been stolen. In those cases, criminal organisations move their illegal gold in the form of concentrate, from mining areas in one country to buyers in another, who subsequently launder the gold through initial processing plants (cso‑a‑250122). In that country, illegally mined gold is processed through hundreds of small plants (Global Initiative Against Transnational Organised Crime, 2025[17]).
4. Beneficiation, blending, and transformation of gold concentrate in transit pose specific laundering risks. Cargoes can be blended or beneficiated to higher grade between purchase from a supplier and delivery to a buyer. While not an illegal practice, it could, intentionally or not, help obscure where the gold in a blended cargo originated. This risk is even greater when one considers the operations of smelters themselves. Given that smelting will substantially alter the form of the gold the operator receives in the form of raw ore or concentrate, processing can result in a tariff shift – a conversion from one HS code (261 690) to another (for instance, 710 812 for gold bars). That shift can allow for the country in which the processor operates to become the origin country of record (International Trade Administration, 2025[18]). Customs records no longer indicate the gold’s original source in such cases.
5. Gold concentrate and ways it is traded do not resemble what most stakeholders think of as the gold supply chain. Gold concentrate generally goes to copper smelters or roasters for processing before being sent on to refiners or other destinations, only merging back into that flow after a significant window in which manipulations can take place (de Sousa, 2021[10]). This natural diversion leaves significant room for mis-declaration or mis-invoicing in shipments to colluding smelters and roasters. Illicit gold could be laundered into the legitimate supply chain at this point as well.
6. Hidden value by-product minerals can be concealed within gold ores and concentrates. HS 261690 covers gold ore and ores and concentrates of platinum group metals (PGMs). Several high-value minerals – including critical minerals such as copper, tellurium, and antimony – can be found and extracted alongside gold. That extra value embedded in cargoes of concentrate is also effectively concealed, as only the primary metal in a given cargo is typically declared in customs documentation. Significant resource wealth can hence be exported without being declared. While this may not always constitute fraud, it can serve two covert purposes: to effectively under-invoice exports, perhaps by a considerable margin, and to supply the buyer or destination country with strategic mineral resources. When a company importing raw gold ore is the subsidiary of a company that specialises in the midstream processing of rare and critical minerals – a scenario evident in trade data from SICEX and Panjiva, as well as online business directories – the vulnerabilities become clear. This practice poses a challenge for producing countries’ domestic revenue mobilisation and can be exploited for illicit financial flows.
A related typology involves concealing gold concentrate within a shipment of another mineral; there have been reports of gold concentrate being concealed within shipments of copper concentrate, which generally contains some gold (gov-a‑180625).It is also significant that the concentrate falls within Chapter 26 of the Harmonized System (hence the HS code 261690), while most other forms of gold are in chapter 71. Even customs personnel who are vigilant about gold in other forms, and who therefore pay closer attention to shipments coded under chapter 71, may not understand that gold can travel under chapter 26.
7. Trade dynamics in specific countries can also pose risks to the concentrate supply chain. One commodity expert noted that gold concentrate flows involve warehousing or processing in free trade zones (FTZs) (cso-c‑250123). As examined in the OECD report on the role of FTZs in illicit gold flows, the high trade volume and light-touch regulation that characterise many FTZs open the door to fraud or other illicit exploitation of gold (OECD, 2022[3]). Furthermore, unlike bullion, gold concentrate often carries VAT, adding yet another potential avenue for fraud. Key gold-producing countries have gone from exporting very little concentrate to shipping out significantly larger quantities. To take one example, according to data from UN Comtrade and the analytics platform SICEX, a producer country in South America that reported exporting virtually no raw gold ore or concentrate in the years leading up to 2023 shipped out over 150 000 t in 2024.
8. As gold concentrate is transported almost exclusively by sea, it is embedded within large‑scale trade flows that remain challenging for authorities to monitor effectively. As key global trade nodes, the maritime shipping industry and port infrastructure become targets for criminal infiltration, and are therefore exposed to illicit trade flows, including illicit gold. A persistent constraint is the limited capacity of competent authorities to oversee the sheer magnitude of containerised and bulk shipping transiting the global seas and ports every day; globally, less than 2% of cargo containers are ever inspected (UNODC, 2023[19]). In addition, gaps in export and import documentation requirements across jurisdictions allow for cargo misreporting and concealment (OECD, 2019[20]).
One form of illicit financial flows enabled by these vast trade flows is shipping “phantom” concentrate to launder or move the proceeds of crime. The use of “phantom gold” is not exclusive to concentrates: shipments declared as gold but only existing as document trails – effectively, empty containers – are used to provide the rationale for a financial flow; this typology has recently been identified in a country that is a major exporter of HS 261690 (Yansura and Hazbun, 2025[21]). In the case of gold concentrate, which is a bagged and containerised cargo unlikely to be inspected, simple dirt or sand could easily be put in big bags for shipment and invoiced as relatively high-grade concentrate. This would also be a relatively low-cost means of gold-based money laundering, as concentrate generally carries significantly lower royalties than doré (com-e‑061 222). High sea sales present another vulnerability to illicit financial flows in the maritime space. High seas sale of concentrates refers to a transaction in which ownership of gold-bearing material is transferred while the shipment is en route, before reaching the port of discharge and before customs clearance. The bill of entry is not filled in, as the new owner takes possession of the commodity while in transit. While complex and expensive, by changing the consignee mid-transit and manipulating documentation, data related to destination and invoice value recorded at export will be different from data recorded at import.
Due to the vulnerabilities in the trade of raw ore and concentrates, these commodities may merit enhanced due diligence but specific indicators – some common to other gold forms – can be used to prioritise due diligence interventions. These include:
gold businesses that report unusually high volumes of sales for their geographic and economic areas of operation
concentrates wholly or partly processed in plants within or adjacent to conflict-affected and high risk-areas or countries with known illicit gold flows
mine production of milled ore or concentrate that is not commensurate with evidence of operations (including fuel, electricity, water, equipment and processing chemicals)
reported tenors of concentrate in customs filings that do not align with commercially viable levels
raw ore or concentrate that crosses multiple borders and is handled by multiple intermediaries
presence of short-lived companies acting as intermediaries
concentrate that transits or undergoes processing in FTZs – especially those with histories of illicit activity
large‑volume, frequent shipments of concentrate from companies or individuals with no visible ties to the gold or scrap gold trade
consistent and round numbers in terms of both declared quantity and value of concentrate trade
significant variations in amounts of gold reportedly purchased or sold as concentrate on a year-to-year or month-to-month basis.
Illicit financial flows through the trade of raw ores and concentrates divert funds to criminal actors and deprive producing countries of vital tax revenues. Governments may consider taking targeted action to address these vulnerabilities and strengthen oversight of the sector through a number of strategies:
Train personnel of competent authorities in the nature and trade of raw ores and concentrates. This includes building the capacity of customs and other law enforcement personnel to identify ores and concentrates, understand how the supply chain works, and detect typologies of crime related to these commodities. This requires training in how to analyse maritime shipping documents related to concentrates, such as bills of lading, customs declarations, and ship manifests.
Assert clear control and strengthen customs enforcement at port facilities that export gold ore and concentrate. Where international companies, either owned by other states or privately held, control these port facilities, require full data disclosure to regulators and law enforcement, and mandate unrestricted access to their operations and outgoing cargoes.
Equip customs facilities in major ports for raw ores and concentrates with the means for assaying cargoes. X-ray fluorescence (XRF) guns, which are often used by customs personnel to quickly assess the gold content of gold bars, recycled gold, or gold jewellery, are ineffective for raw ore or concentrate. Installing fire assays capacity at key port facilities will allow for detection of mis-declared or mis-invoiced shipments.
Conduct systematic or random assays of other mineral concentrates for gold content. Testing cargoes of mineral concentrates such as silver, copper, manganese, and zinc for their gold content as well as their content of high-value by-product minerals can enhance detection rates and help deter fraud.
Enhance national trade nomenclatures to improve data on gold concentrate flows, reduce the latitude for misrepresentation and help isolate and target the types of concentrate where fraud is the most prevalent. This could be done by instituting new national subdivisions at the eight‑digit level within HS code 261690 in line with WCO guidelines on maintaining coherence.
Take steps to ensure customs duties reflect the value of by-product minerals. Given that high-value minerals, including critical minerals and rare earth elements, can be found in gold ore and concentrate (as well as other ores and concentrates), customs authorities can mandate complete declaration of mineral contents in a shipment, with fees specific to each high-value mineral.
Establish and enforce more rigorous licensing and monitoring of initial processing plants’, traders’, and smelters’ traceability and due diligence practices. This includes strict licensing regimes that include rigorous monitoring and reporting – including in line with OECD Guidance expectations – for initial processing plants and traders, which buy and blend raw ore or process it into concentrate. Similar licensing and monitoring regimes would need to apply to smelters that receive concentrates.
Facilitate co‑operation, including information sharing, among law enforcement agencies of origin, transit, and destination countries. Illicit flows of ores and concentrates are invariably a transnational problem, and need to be addressed through international co‑operation and co‑ordination, both using available mechanisms such as joint customs operations and establishing new avenues of communication and collaboration.
What can the private sector do?
Given the persistent blind spots and potential vulnerabilities in gold concentrate supply chains, companies should treat the presence of such materials as a high-risk indicator. Where a company identifies gold concentrates in its supply chain, it is encouraged to prioritise due diligence measures to identify, address, and account for potential and actual risks of adverse impacts.
All entities in the gold and copper supply chains, particularly processing plants, traders, smelters and their customers, should conduct due diligence in line with the OECD Guidance. As part of their due diligence process, they should make sure their management systems are equipped to identify actual and potential risks of adverse impacts linked to gold concentrates, continuously monitor, put in place mitigation measures where relevant, and report publicly – particularly on risk identification and mitigation.
In particular, companies should ensure that their systems of control and transparency of the supply chain, including traceability systems as relevant, are capable of detecting discrepancies, vulnerabilities, and indicators warranting enhanced due diligence specific to gold concentrates. Where appropriate, they should carry out on-the‑ground assessments, plausibility checks and controls of due diligence systems of mines, beneficiation plants, exporters, smelters and refiners.
Verification initiatives like due diligence audit schemes should review and, where necessary, update the scope of their assurance processes to capture vulnerabilities linked to concentrates. This includes initiatives in both gold and copper supply chains.
The shipping industry should contribute to oversight of ore and concentrate shipments. Through the major trade associations – including BIMCO, INTERCARGO, ICS and WSC – shippers should explore the possibility of a code of conduct to help identify and prevent use of commercial vessels to transport illicit gold and other precious metals.
Companies sourcing copper and other base metal concentrates containing gold are encouraged to refer to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations to accurately establish a price for mineral sales (OECD, 2022[22]). In addition, further guidance on payable metal rates and thresholds are set out in the OECD/IGF Transfer Pricing Framework for Copper Toolkit (OECD/IGF, Forthcoming[23]).
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[21] Yansura, J. and I. Hazbun (2025), Addressing Illegal Gold Mining in the Hemisphere: New Approaches for U.S. Policy, FACT Coalition, https://thefactcoalition.org/wp-content/uploads/2025/08/Gold-Mining-Policy-Report-FACT-ENG-V3.pdf.
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This paper was prepared by Dr. David Soud, under the direction of Luca Maiotti, Louis Maréchal, Benjamin Katz and Hannah Koep-Andrieu (OECD Centre for Responsible Business Conduct). This report also benefitted from comments by Matthew Burnett Stuart (UNICRI), Marcena Hunter (Global Initiative Against Transnational Organized Crime), Kalale Mambwe (OECD), Frédéric Massé (Red CORAL), Víctor Hugo Pachas (Earth First Conservation and Development), Sophia Pickles (Global Initiative Against Transnational Organized Crime), Larissa Rodrigues (Instituto Escolhas), Andrew Viola (OECD), Tanya Wyatt (UNODC), and Julia Yansura (FACT Coalition). The report was presented to the Working Party on Responsible Business Conduct for information.
This study was prepared based on qualitative research that included a literature review, desk-based research, and remote semi-structured interviews. Figure 1 enumerates the interviews undertaken over the course of the study.