Sanctions and sourcing

Sanctions

We screen every client, beneficial owner, counterparty, shipper and consignee against the UK Sanctions List and the consolidated list of financial sanctions targets maintained by the Office of Financial Sanctions Implementation, at onboarding and whenever the lists are updated. Where a movement touches another jurisdiction we screen against that jurisdiction's list as well.

A match, or a credible near-match we cannot rule out, stops the instruction. We freeze rather than proceed, report to OFSI where required, and we are frequently prohibited from explaining why. Breaching financial sanctions is a criminal offence and there is no commercial justification that outweighs it.

Primary regime

Sanctions and Anti-Money Laundering Act 2018 and regulations made under it

Competent authority

Office of Financial Sanctions Implementation (OFSI), HM Treasury

Screening provider

to be supplied

Russian-origin gold

The import of gold of Russian origin has been prohibited in the United Kingdom since 2022. We do not accept, store or move gold that originates in Russia, was refined in Russia, or was exported from Russia on or after the relevant date, irrespective of where it has been held since. Where origin cannot be established to our satisfaction, we decline.

Responsible sourcing

Gold can finance armed conflict and serious human rights abuse. A custodian that accepts metal without asking where it came from launders that history along with the value. We apply due diligence based on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, and on the LBMA Responsible Gold Guidance as the market standard.

What we ask for

1. The refiner, and whether it appears on the LBMA Good Delivery List.
2. Serial numbers and assay documentation for each bar.
3. The chain of custody since refining, with documentary support.
4. For newly mined or artisanal material, the mine, the country and the due diligence already performed upstream.
5. For recycled material, the source and the checks the supplier carried out.

What we will not accept

• Metal with no verifiable chain of custody.
• Metal that we have reason to believe originates from a conflict-affected or high-risk area without OECD-conformant due diligence.
• Metal linked to child labour, forced labour, or the financing of armed groups.
• Unmarked or defaced bars where the markings appear to have been removed.
• Metal offered by someone unwilling to answer the questions above.

Declining is not a commercial judgement about the client. It is the only defensible answer when provenance cannot be established.

Export control and prohibited goods

Carriage is subject to export control, prohibition and restriction rules in every country a consignment touches. You must tell us accurately what is inside. Misdeclaration can void insurance, delay a consignment indefinitely and constitute a criminal offence in its own right.

Membership and certification

LBMA status

to be supplied

Responsible sourcing certification

to be supplied

Freight association

to be supplied

These are blank because the certificates do not yet exist to support them. We would rather show the gap than a badge nobody can verify.

Raising a concern

If you believe metal held or moved by us has been improperly sourced, write to info@goldstarbullionsecurity.com marked for the attention of the nominated officer. Concerns can be raised anonymously and we will not retaliate against anyone who raises one in good faith.

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Questions about this document go to info@goldstarbullionsecurity.com, or write to Gold Star Bullion Security, 144 Houndsditch, London EC3A 7BX, United Kingdom.