Page 16 - Bullion World Issue 01 Volume 06 January_2026

Bullion World | Volume 6 | Issue 01 | January 2026

Illicit Flows of

Gold Concentrates

In the Maritime Space

(Summary based on OECD Report, Dec 2025)

What can policymakers do? Conduct systematic or random assays of other
Illicit financial flows through the trade of raw ores mineral concentrates for gold content. Testing cargoes
and concentrates divert funds to criminal actors and of mineral concentrates such as silver, copper,
deprive producing countries of vital tax revenues. manganese, and zinc for their gold content as well as
Governments may consider taking targeted action to their content of high-value by-product minerals can
address these vulnerabilities and strengthen oversight enhance detection rates and help deter fraud.
of the sector through a number of strategies:
Enhance national trade nomenclatures to improve
Train personnel of competent authorities in the data on gold concentrate flows, reduce the latitude for
nature and trade of raw ores and concentrates. misrepresentation and help isolate and target the types
This includes building the capacity of customs and of concentrate where fraud is the most prevalent. This
other law enforcement personnel to identify ores could be done by instituting new national subdivisions
and concentrates, understand how the supply chain at the eight-digit level within HS code 261690 in line
works, and detect typologies of crime related to these with WCO guidelines on maintaining coherence.
commodities. This requires training in how to analyse
maritime shipping documents related to concentrates, Take steps to ensure customs duties reflect the
such as bills of lading, customs declarations, and ship value of by-product minerals. Given that high-value
manifests. minerals, including critical minerals and rare earth
elements, can be found in gold ore and concentrate
Assert clear control and strengthen customs (as well as other ores and concentrates), customs
enforcement at port facilities that export gold ore and authorities can mandate complete declaration of
concentrate. Where international companies, either mineral contents in a shipment, with fees specific to
owned by other states or privately held, control these each high-value mineral.
port facilities, require full data disclosure to regulators
and law enforcement, and mandate unrestricted Establish and enforce more rigorous licensing and
access to their operations and outgoing cargoes. monitoring of initial processing plants’, traders’,
Equip customs facilities in major ports for raw ores and and smelters’ traceability and due diligence
concentrates with the means for assaying cargoes. practices. This includes strict licensing regimes that
X-ray fluorescence (XRF) guns, which are often used include rigorous monitoring and reporting – including
by customs personnel to quickly assess the gold in line with OECD Guidance expectations – for initial
content of gold bars, recycled gold, or gold jewellery, processing plants and traders, which buy and blend
are ineffective for raw ore or concentrate. Installing raw ore or process it into concentrate. Similar licensing
fire assays capacity at key port facilities will allow for and monitoring regimes would need to apply to
detection of mis-declared or mis-invoiced shipments. smelters that receive concentrates.

16