In November 2018, the US Office of Foreign Assets Control designated a network of Venezuelan entities and individuals responsible for what OFAC described as a gold-for-oil scheme coordinated at the highest levels of the Venezuelan state. The network — which included the state mining company Minerven and a series of front companies operating through Cuba — had exported billions of dollars in gold, much of it extracted from illegal operations in Venezuela's Orinoco mining arc, in exchange for crude oil shipments that bypassed US sanctions. The gold moved through intermediaries in Trinidad and Tobago, Turkey, and the UAE; the proceeds funded a government that had already been sanctioned for narcotics trafficking and human rights violations. OFAC's action named the individuals and entities, froze their US-linked assets, and signalled that the precious metals trade was firmly within the scope of US sanctions enforcement.
What made the Venezuelan network notable was not its sophistication — it relied on mechanisms that financial crime specialists had documented across multiple jurisdictions for decades — but its scale and its explicitness. The gold-for-oil scheme demonstrated, at a systemic level, exactly why the precious metals trade has become one of the most significant and least adequately addressed money laundering vectors in the global economy. The structural conditions that enabled it — fungible product, opaque supply chains, globally distributed dealer networks, regulatory frameworks that lag commercial reality by a decade — are not unique to Venezuela. They are features of the gold market everywhere.
This article examines those structural conditions, the primary laundering typologies that exploit them, and what compliance teams in financial institutions need to understand to monitor them effectively. The focus is on the full chain: from the illegal mine to the refinery, from the refinery to the dealer, and from the dealer to the institutions that ultimately process the payment flows.
Why Precious Metals Are Structurally Attractive to Financial Criminals
Gold is unique among commodity-based laundering vehicles because its most useful property — fungibility — is a chemical fact rather than a legal or administrative construct. A gram of .9999 fine gold refined from ore extracted by ELN fighters in Colombia's Chocó department is, at the molecular level, identical to a gram of .9999 fine gold from a fully-licensed and audited mine in Ghana. Once the doré bar enters a refinery and the gold is separated from other metals, the origin of that gold is physically undetectable. The integration phase — the point at which criminal proceeds are permanently merged into the legitimate financial system — is made irreversible at the moment of refining. No subsequent audit, no matter how thorough, can reverse it without documentation that a determined bad actor simply will not provide.
This is categorically different from real estate, where the property's history is documented and the beneficial ownership chain can be traced backward. It is different from shell company structures, where corporate records — however obscured — exist and can be obtained through legal process. Gold, once refined, erases its own history in a way that no other major asset class does. That property is not incidental to gold's laundering utility — it is central to it.
Value density compounds the advantage. A standard London Good Delivery bar — the benchmark for institutional gold trading — weighs 400 troy ounces, or approximately 12.4 kilograms. At current market prices, that bar is worth between $900,000 and $1,100,000 depending on spot. You can carry close to a million dollars in a bag that fits in an overhead locker. The equivalent value in cash — even in high-denomination notes — would weigh several times more and would be substantially more difficult to move across borders undetected. For criminal networks that need to move value across jurisdictions, gold's weight-to-value ratio is a significant practical advantage.
Price volatility provides a third structural advantage that is less commonly discussed but highly relevant to trade-based manipulation. Gold prices have historically moved by fifty percent or more across multi-year cycles, and by fifteen to twenty percent within individual calendar years. That volatility creates genuine commercial cover for the over- and under-invoicing that characterises trade-based money laundering. If a counterparty queries a gold shipment invoiced at fifteen percent above spot, the explanation — currency movement, quality premium, transaction costs, forward pricing — is commercially plausible in a way that the same premium on a stable-price commodity, say wheat or refined copper, would not be. Volatility is not a bug for those manipulating precious metals pricing; it is a feature.
The Predicate Offense — Illegal Mining in Latin America and the Caribbean
The majority of illicitly-sourced gold that enters the global supply chain originates from illegal or informal artisanal and small-scale mining operations, concentrated heavily in Latin America. Understanding the geography and mechanics of that source is essential context for understanding how the laundering typologies downstream operate.
Venezuela's Arco Minero del Orinoco — the mining arc of the Orinoco, a resource-rich zone in the south of the country covering approximately 112,000 square kilometres — has become one of the world's most significant sources of conflict gold. The region's gold deposits are controlled not by the Venezuelan state, despite its formal legal claim, but by a complex and violent patchwork of armed groups: the ELN (National Liberation Army), dissident FARC factions that did not demobilise following the 2016 peace agreement, and Venezuelan military and paramilitary actors who take extraction rents in gold rather than cash. The Maduro government's 2016 opening of the Arco Minero through presidential decree was intended to formalise and capture artisanal mining revenue; in practice it created legal cover for gold exports that are, in significant part, produced under armed coercion.
Venezuelan conflict gold exits the country through multiple channels. Trinidad and Tobago has been documented — including in CFATF mutual evaluation reports and investigative journalism — as a primary transit and documentation point, with gold from the Arco Minero acquiring Trinidadian paperwork before onward export. Brazil and Colombia serve as both transit corridors and points of first refinery access. UAE intermediaries — particularly in Dubai's gold souk and free zone ecosystem — receive Venezuelan gold through these chains, providing the final integration point before the metal enters the global institutional market.
Colombia's illegal mining landscape is dominated by the ELN, which has pivoted significantly toward gold mining revenues as an alternative to cocaine taxation following years of counter-narcotics pressure. The departments of Chocó, Bajo Cauca Antioqueño, and Nordeste Antioqueño are the primary operational zones. Gold extracted under ELN control is sold to small intermediary dealers — often legally registered — who aggregate supply from multiple artisanal sources, obscuring origin through purchase records that document the immediate seller but not the upstream mining context. From these aggregators, the gold moves to jewellery exporters in Medellín and Bogotá, where it enters formal export channels with documentation that accurately records the immediate transactional chain but conceals the criminal origin of the underlying metal.
Brazil's illegal mining crisis reached a documented peak in 2023 with the Yanomami health emergency — the formal recognition that illegal gold mining had devastated indigenous communities in Roraima state, with garimpo operations covering areas previously protected under Brazilian law. The laundering mechanism in Brazil exploits a legitimate regulatory structure: licensed distribuidores de ouro (gold distributors) are authorised to purchase gold from multiple small producers, aggregate it, and sell it into the formal market. That structure is commercially functional for small-scale legal miners but is also ideal for obscuring illegal sourcing — a distribuidor purchasing from fifty small producers cannot practically verify the legal status of every extraction operation, and the aggregation of multiple small purchases into a single documented lot erases the individual sourcing trail.
The Caribbean's role in this picture is not as a producing region but as a transit and documentation zone. Several Caribbean jurisdictions — Trinidad and Tobago being the most thoroughly documented, but others including Guyana, Suriname, and certain Eastern Caribbean states — are located on or adjacent to gold-producing regions and have served as re-documentation points for Venezuelan and Colombian conflict gold. Gold that acquires Caribbean export documentation may then be sold to European or UAE refineries as product of Caribbean origin, with the documentation trail pointing to the transit jurisdiction rather than the ultimate source.
The Core Laundering Typologies
Trade-Based Money Laundering Through Metals Dealers
Trade-based money laundering using precious metals is among the most thoroughly documented TBML typologies in the enforcement literature, and remains among the most actively exploited. The mechanics are well understood; what makes them persistent is not their obscurity but the weakness of the supervisory framework that should be detecting them.
Over-invoicing and under-invoicing in gold shipments operate on the same principle as in any commodity TBML: the stated transaction value is manipulated to transfer value between the buyer and the seller beyond what the underlying commercial transaction would justify. A gold exporter invoicing a shipment at fifteen percent above spot is transferring an additional fifteen percent of the shipment's value to the buyer's jurisdiction — value that can represent criminal proceeds being remitted from one party to another under the guise of a commercial payment. Under-invoicing works in reverse: a buyer pays less than spot, and the difference is settled through a separate channel that may carry criminal proceeds in the other direction.
Multiple invoicing — the documentation of the same physical shipment multiple times, across different borders and using different counterparties — is particularly suited to the precious metals trade because physical gold moves through intermediary chains in which the same bar may genuinely change hands multiple times. Multiple invoicing exploits the legitimate complexity of the trading chain to generate multiple documented "commercial" transactions from a single physical movement, each of which can serve as a conduit for a value transfer payment.
Quality and quantity misrepresentation provides a variant that is harder to detect without physical assay of the shipment. Gold described as being of lower purity than it actually is can be invoiced at a lower price, with the undisclosed value difference representing a concealed payment. Alternatively, gold shipments that include jewellery — where the "craftsmanship premium" over raw metal content is genuinely subjective and can legitimately vary by orders of magnitude — create a pricing space that is almost impossible to scrutinise from the outside. A piece of jewellery invoiced at three times its metal content value may be a genuine artisanal piece, or it may be a vehicle for moving a hidden payment under the guise of a craftsmanship premium.
One of the most operationally significant TBML corridors in the Western Hemisphere runs gold from Venezuela and Colombia, through Caribbean transit points, to the United States. Cocaine proceeds — accumulated in dollars in the US — are used to purchase artisanal gold from Colombian mining intermediaries. The gold is exported via the Caribbean, often with re-documentation at the transit point, and sold to US bullion dealers or jewellery manufacturers. The sale proceeds are then wired back to the original criminal group as commercial income from a gold export transaction. The proceeds have made a circuit: dirty dollars out, gold in, clean dollars back. FinCEN has brought enforcement actions against Florida and Texas bullion dealers specifically for involvement in this corridor, documenting the mechanism in enforcement orders that remain publicly available.
The Jewellery Sector
The jewellery sector deserves specific treatment because it combines the laundering utility of precious metals with a pricing structure that is uniquely resistant to external verification. A piece of jewellery has two components of value: the metal content, which can be assayed and priced against spot; and the craftsmanship premium, which is a function of design, maker reputation, and market positioning and which cannot be objectively verified against any external reference. That combination creates a manipulation space that is structurally wider than almost any other asset class.
The basic jewellery laundering mechanism is well documented: criminal proceeds are used to purchase jewellery at full retail price — which includes the craftsmanship premium — and the jewellery is then sold or pawned at a price reflecting only the metal content value. The apparent "loss" on the transaction — which can be forty to sixty percent of the original purchase price in the case of mass-market jewellery — is the cost of cleaning the funds. For the criminal, that cost is acceptable because the proceeds that emerge are documented as income from a legitimate sale transaction.
At higher values, the mechanism becomes more sophisticated. Jewellery pieces with genuine subjective value — antique pieces, named-maker pieces, pieces with documented provenance — can be bought and sold at prices that are genuinely difficult for a compliance officer to benchmark. A criminal who purchases a piece at €200,000 and sells it at €180,000 has cleaned €200,000 at a cost of €20,000, through a transaction that looks from the outside like a modest loss on a collectible.
Under FATF Recommendations 22 and 23, dealers in precious metals and precious stones (DPMS) are designated as non-financial businesses and professions subject to AML obligations equivalent to those applied to financial institutions: customer due diligence, record keeping, suspicious transaction reporting, and registration with a supervisory authority. In practice, across most Caribbean jurisdictions and many LATAM jurisdictions, that designation exists in legislation but is implemented as close to fiction as regulation can be. Jewellers operate on cash, conduct no CDD on customers making significant purchases, file no suspicious transaction reports, and in many cases are not registered with any supervisory authority that has the capacity to inspect them. The gap between FATF designation and supervisory reality in this sector is one of the most significant unresolved weaknesses in the regional AML framework.
Refinery Integration and the "Recycled Gold" Problem
Refineries occupy the most critical point in the gold laundering chain because they are where the irreversible homogenisation occurs — where doré bars of mixed and potentially criminal origin become standard refined gold that is, thereafter, physically indistinguishable from any other refined gold in the world. A refinery that accepts a doré bar from an intermediary who purchased it from an artisanal aggregator in Medellín is not just processing metal; it is permanently integrating whatever criminal proceeds are embedded in that metal into the legitimate global gold market.
The London Bullion Market Association's Responsible Gold Guidance — the primary industry standard for refinery due diligence — requires LBMA-accredited refineries to conduct supply chain due diligence, assess the risk profile of their doré suppliers, and take steps to avoid sourcing from conflict-affected or high-risk areas. That standard has meaningfully improved practice at the largest global refineries with institutional client bases. It has not resolved the problem for three reasons.
First, the LBMA framework applies only to LBMA-accredited refineries, which represent a significant but not exhaustive share of global refining capacity. Non-LBMA refineries — including many operating in the UAE, Turkey, and certain Asian jurisdictions — operate under weaker or no equivalent standards, and gold that could not pass LBMA due diligence can be refined through these channels and re-enter the institutional market from a subsequent transaction point.
Second, compliance with Responsible Gold Guidance is a documentation exercise as much as a substantive one. A refinery that receives doré accompanied by export documentation from a Caribbean jurisdiction, purchase records from a licensed Colombian distribuidor, and a legal opinion from a local law firm has technically completed a due diligence process even if each of those documents reflects a laundering chain rather than a legitimate one. The documentation is real; what it describes is not.
Third, the doré supply chain for small and medium refineries is often genuinely dependent on artisanal sourcing. A refinery serving the artisanal mining sector in a LATAM country may have no commercially viable alternative to purchasing doré from intermediaries who aggregate from hundreds of small producers. Responsible sourcing standards that require full traceability to individual mine sites are, for much of this supply chain, commercially impractical without a fundamental restructuring of the market.
The "recycled gold" and "scrap gold" framing deserves specific attention because it has become the preferred documentation strategy for concealing illicit origin. Gold described as recycled or scrap — jewellery being melted down, industrial gold being reclaimed, old coins being processed — requires no upstream mining documentation because there is no mine of record. That framing is entirely legitimate when the gold is genuinely recycled, and entirely false when it is illicitly-mined doré given a fictitious retail history. Swiss refineries — which process a very large proportion of global gold refining volume — have faced documented scrutiny from NGOs and Swiss prosecutors specifically over doré purchases from intermediaries in high-risk jurisdictions where the recycled gold narrative has been used to obscure illegal artisanal sourcing.
The Dubai Nexus
No analysis of precious metals money laundering is complete without examining the UAE's role — specifically Dubai's — as the world's largest gold re-export hub. The UAE imports and re-exports more gold by volume than any other country in the world. Dubai's gold souks are genuine commercial institutions with deep historical roots in regional trade; the city's free zones enable large-volume precious metals trading with logistical infrastructure that supports the movement of bullion at institutional scale. The legitimate commercial gold trade through Dubai is enormous, and that legitimacy is not in question.
What is in question is the degree to which Dubai's gold trading infrastructure has been used to integrate illicitly-sourced gold into the legitimate market, and the adequacy of the supervisory framework that should be preventing it. The FATF conducted a mutual evaluation of the UAE in 2020. That evaluation identified serious deficiencies across the AML framework, specifically including the supervision of dealers in precious metals and stones — the DPMS sector that encompasses gold traders, jewellers, and the free zone entities through which large-volume gold trading occurs. The deficiencies were significant enough that FATF added the UAE to its increased monitoring list — commonly described as the "grey list" — in February 2022.
The UAE's greylisting was not a punitive designation; it reflected a finding that the country's AML framework required substantial remediation across multiple sectors, with DPMS supervision among the most significant gaps. The UAE's response was serious and systematic: DPMS registration requirements were strengthened, beneficial ownership transparency requirements for free zone entities were enhanced, and supervisory capacity was increased. FATF removed the UAE from the increased monitoring list in February 2024, reflecting the progress made across the remediation programme.
What is important for compliance teams to understand is that the UAE's exit from the grey list reflects progress in the supervisory framework, not resolution of the underlying structural challenge. The volume of legitimate gold trading through Dubai is so large that even a small percentage of illicitly-sourced gold integrating into it represents significant absolute volumes. The trading infrastructure — souks, free zones, intermediary dealer networks — remains in place. The supervisory improvements are real, but the challenge of monitoring a market of this scale and commercial complexity is substantial. For financial institutions with clients in the UAE precious metals sector, the appropriate response is not reduced vigilance because the country is no longer grey-listed, but continued enhanced due diligence calibrated to the sector's inherent risk profile.
The DNFBP Gap — Where the Regulatory Framework Breaks Down
The theoretical framework for regulating the precious metals sector is not deficient. FATF Recommendations 22 and 23 designate dealers in precious metals and precious stones as DNFBPs — designated non-financial businesses and professions — subject to AML and CFT obligations equivalent to those applied to financial institutions. That designation means DPMS should conduct customer due diligence, maintain records, appoint a compliance officer, implement internal controls, train staff, and file suspicious transaction reports. The obligations are clear, comprehensive, and well-established in FATF's standards.
The implementation reality, particularly across the Caribbean and significant parts of LATAM, is a systematic failure at every stage of the supervisory chain. The problem begins with registration: in multiple Caribbean jurisdictions, DPMS registration requirements exist in law, but the registration process is either non-functional in practice or captures only a fraction of the actual dealer population. Jewellers, bullion dealers, pawnbrokers, and scrap metal dealers who handle gold operate without formal registration with any authority that has AML supervision as part of its mandate.
CFATF — the Caribbean Financial Action Task Force — has documented DPMS supervision as a systemic gap in mutual evaluation reports across multiple member states. The pattern is consistent: legislation that transposes the FATF designation, a designated supervisory authority with primary responsibility for financial institutions that has limited bandwidth and expertise for the DPMS sector, no meaningful inspection programme, and no record of enforcement actions against DPMS entities for AML failures. The designation exists; the supervision does not.
The political economy of this gap is worth understanding because it helps explain why it has persisted despite being well-documented. DPMS sectors in Caribbean and LATAM jurisdictions tend to be diffuse — many small operators scattered across the retail economy — and do not have strong trade associations that would engage with regulators on compliance issues. The supervisory resources available to national financial intelligence units and AML supervisors are limited and prioritised toward the banking and insurance sectors, which are seen as higher-profile and more amenable to supervision. And the political pressure to enforce against small jewellers and gold dealers — whose customers often include ordinary members of the public — is lower than the pressure to supervise banks.
Many jurisdictions also have formal or informal "small dealer carve-outs" — either explicit thresholds below which CDD requirements do not apply, or informal supervisory practices that focus resources on the largest operators and leave the long tail of the market effectively unsupervised. In a sector where the most significant laundering risk often runs through the aggregation of many small transactions — exactly the transactions that fall below formal reporting thresholds or supervisory attention — the small dealer carve-out creates a practical exemption for the majority of the market's risk surface.
Red Flags for Compliance Teams
Financial institutions with clients in the precious metals sector — or with exposure to commodity trade finance, international wire transfers, or correspondent banking relationships that touch the gold supply chain — should maintain typology-specific red flag awareness calibrated to the sector. The following indicators, individually or in combination, warrant enhanced scrutiny and, where appropriate, suspicious activity reporting.
- Cash payments near or below reporting thresholds: Structured cash payments for precious metals purchases — multiple transactions by the same customer or associated customers, each below the applicable reporting or CDD trigger — are a primary indicator of smurfing in the DPMS sector. The pattern is well-documented in FinCEN enforcement actions against US bullion dealers.
- No documentation of gold origin: A seller or exporter of gold who cannot produce or declines to produce documentation of origin — mining licence records, purchase receipts from intermediate sellers, export paperwork from the producing jurisdiction — is presenting a material red flag. Legitimate commercial gold has a documented chain; illicitly-sourced gold's distinguishing characteristic is the absence of verifiable upstream documentation.
- Gold described as "scrap" or "recycled" from unverifiable sources: The recycled/scrap gold framing, where the asserted retail history of the metal cannot be verified, is the standard documentary strategy for concealing illegal artisanal origin. It is not an automatic red flag — genuine scrap and recycled gold are significant and legitimate market segments — but it requires verification that a customer should be able to provide if the narrative is genuine.
- Frequent counterparties in Venezuela, illegal mining areas of Colombia, or artisanal mining zones of Brazil and Peru: Geographic concentration of a precious metals customer's supply chain in areas with documented conflict gold production should trigger enhanced due diligence into the sourcing documentation and the intermediary chain.
- Valuation discrepancies — significant deviation from spot: Invoiced prices for gold that deviate significantly from prevailing spot prices — either above or below — without a commercially explicable rationale (quality premium, forward pricing, transportation costs) are a primary TBML indicator in precious metals trade finance and export documentation review.
- Opaque beneficial ownership of purchasing entities in high-risk jurisdictions: DPMS clients structured through entities in jurisdictions with limited beneficial ownership transparency — particularly free zone companies in the UAE, shell entities in Caribbean offshore centres, or holding structures in non-cooperative jurisdictions — require enhanced due diligence into the ultimate beneficial owner and the commercial rationale for the structure.
- Multiple transactions from different individuals with similar identifying characteristics: The use of multiple nominal purchasers — different individuals presenting similar identification, similar addresses, or similar account characteristics — to aggregate purchases that avoid individual reporting thresholds is a structuring indicator specific to the DPMS retail context.
- Requests for specific bar weights or purity specifications consistent with illicit market preferences: Certain bar weights and purity specifications are preferred in illicit precious metals markets for ease of transport and valuation. Requests that are unusually specific about these characteristics — particularly from clients without an obvious commercial rationale for the specification — warrant scrutiny.
- Source of funds for large precious metals purchases unexplained or unexplainable: A customer who cannot provide a coherent account of the source of funds for a significant precious metals purchase, or whose stated source of funds is inconsistent with their known business profile, presents a material due diligence gap.
- Export documentation that does not match declared weight or purity: Discrepancies between the gold described in export documentation and the gold declared at the point of import — detected through customs data sharing or correspondent banking documentation review — are direct evidence of quantity or quality misrepresentation in a TBML context.
- Intermediary trading companies with no credible business history in metals handling: A gold trading counterparty that was recently incorporated, has no physical presence in the metals trade, lacks verifiable staff or infrastructure, and appears to have been created specifically for the transaction in question presents a significant beneficial ownership and purpose red flag.
- Sudden large increase in precious metals transactions without corresponding business explanation: A DPMS client whose transaction volumes increase sharply without a commercially explicable explanation — new contract, market expansion, documented business growth — warrants account review against the background of the precious metals TBML typologies.
The Compliance Imperative
The precious metals laundering problem does not sit primarily at the jeweller's counter or the artisanal mining site — it sits in financial institutions' operational flows. Illicit gold moves through wire transfers settling bullion dealer transactions. It moves through trade finance facilities supporting commodity exports. It moves through correspondent banking relationships that clear payments between the producing jurisdiction, the transit point, the refinery, and the end buyer. It moves through FX transactions converting between the currencies of the multiple jurisdictions through which a single gold shipment may pass. And it moves, occasionally, as physical cash at the DPMS retail level where the laundering chain begins.
Financial institutions that bank DPMS clients, that provide trade finance to commodity exporters with precious metals in their product range, or that operate correspondent relationships with banks in gold-producing or gold-transit jurisdictions have direct exposure to this risk. The question is whether their customer risk assessments, their EDD programmes, and their transaction monitoring parameters are calibrated to the actual typologies operating in this sector — or whether precious metals clients are being assessed against a generic commodity risk framework that does not reflect the specific indicators documented in FinCEN enforcement actions, FATF typology reports, and CFATF mutual evaluations.
Building adequate controls begins with a typology-aware risk assessment for DPMS customers. That means going beyond identity verification and basic business description to understand the sourcing geography of a precious metals client's supply chain, the structure of the intermediary chain between the mine or scrap source and the client's inventory, and the client's own CDD practices for their upstream suppliers. A gold dealer who cannot describe their supplier verification process is not just a compliance concern — they are a potential conduit for conflict gold that no amount of downstream monitoring can fully compensate for.
Transaction monitoring for precious metals clients should be calibrated to the specific TBML indicators documented above: price deviation from spot, counterparty concentration in high-risk jurisdictions, structuring patterns in cash transactions, and documentation mismatches in trade finance flows. Generic AML monitoring rules designed for retail banking or standard commercial clients will not reliably surface precious metals TBML — the sector requires its own parameter set built from its own typology evidence base.
For enhanced due diligence on DPMS clients with supply chains touching Venezuela, Colombia, Brazil, or Caribbean transit jurisdictions, the EDD scope should extend to supply chain documentation review: asking for and critically assessing the mining licence records, distribuidor purchase receipts, export documentation, and assay certificates that should accompany legitimately-sourced gold. A client who provides complete and consistent documentation is demonstrably lower risk. A client who cannot or will not provide it is presenting a red flag that warrants escalation.
amlx.io tracks AML intelligence across commodity sectors including precious metals, aggregating real-time sanctions designations, typology updates, enforcement actions, and FATF and CFATF evaluation findings into a single intelligence feed. For compliance teams who need current, sector-specific intelligence on precious metals risk — without the overhead of monitoring OFAC, FinCEN, FATF, and multiple national regulators simultaneously — it provides the coverage the sector requires without the resource cost of building it from scratch.
If your institution has DPMS clients, commodity trade finance exposure, or correspondent relationships touching the gold supply chain and you want to assess whether your current controls are adequate to the typologies operating in this sector, the Four CCCC team works with financial institutions building precious metals sector compliance frameworks — from customer risk assessment design through to transaction monitoring calibration and EDD programme development. The laundering mechanisms in this sector are well understood and well documented. Building controls that reflect them is achievable; the gap between what the enforcement record demands and what most institutions currently have in place is where the work begins.