Gold is a form of currency. It can be used as an exchange medium. It can be traded anonymously.
The extraction of highly sought minerals, metals and precious metals are becoming a main source of recent foreign investment in many countries. Even when a majority of mining companies are reputable and apply proper business and legal practices, money launderers and terrorists are finding ways to discreetly enter within this lucrative industry and business.
An enhanced due diligence is a factor of utmost importance that, if conducted appropriately, may deter these criminal elements from using you and your company as a vehicle to disguise, place, layer and launder illicitly obtained funds. We offer a robust due diligence service that will prevent your company from potential legal, reputational, operational and concentration risks.
All the mining projects have a life cycle. Each of the phases of the cycle present its own risks and should be analyze independently. A proper risk assessment and a proper Anti-Money Laundering consultant or analyst will highlight all of the risks in the process and recommend improvement actions.
We have developed a checklist that we use every time that we develop a risk assessment for a client or do consulting service. From the checklist we can highlight the following:
In the first phase, it is extremely important to determine who owns the project. Enhanced Due Diligence on the owners, the licensees, and the sources of funds. In the second phase, it is important revise that all permits are legally obtained and up to date and that all contractors have proper licenses. In the third and fourth phases revise all leases, contracts, providers, personnel involved and source of funds. In the fifth phase, the closing of a mine with proper documentation and filings is important, because there is a lot of money laundering being done using closed mines.
For your clients that are buying from you, always identify who will be the final user of the gold you sold (Know you Clients' client), examine the sources of funds you client used to buy your gold, and revise the geography where your client is established and its clientele.