Categories: physical gold

Gold Supplier Due Diligence in Congo and Uganda: A Buyer’s KYC Checklist

International buyers considering physical gold from the Democratic Republic of Congo (DRC), Uganda or elsewhere in East Africa need more than a product description. A credible transaction begins with identifying the people and entities involved, tracing the material, and independently checking the documents before funds or goods move.

1. Identify the seller and the people behind it

Ask for the seller’s registered legal name, jurisdiction, company number, business address, authorized signatory and beneficial owners. Check those details against the relevant registry and request an explanation of any intermediary’s role. A broker’s introduction is not proof that the broker owns the gold or can export it. The FATF guidance for precious-metals dealers describes a risk-based approach to customer and transaction due diligence; the exact legal obligations depend on the jurisdictions and the parties’ roles.

2. Map the gold’s origin and chain of custody

Request a coherent account of where the material was mined or acquired and how it passed through aggregators, traders, transporters and refiners. Note every change in custody and every border crossing. “East African gold” is a broad description, not an origin record. A shipment routed through Uganda, for example, should not automatically be described as Ugandan-mined gold. The OECD mineral supply-chain guidance sets out a five-step framework for risk-based due diligence, including identifying and assessing supply-chain risks.

3. Match documents to the proposed lot

Request the proposed lot’s description, gross and net weights, form, stated purity, assay method, packaging identifiers, ownership evidence and any relevant origin, tax, export and transport documents. Names, dates, quantities and identifiers should agree across the contract, invoice, packing list and official records. Verify purported government documents with the issuing authority through independently obtained contact details. The documents required for a particular movement depend on origin, transit route, destination, product form and applicable law.

4. Arrange independent verification

Agree in writing who selects the inspector or laboratory, where sampling happens, how samples are sealed, which assay method is used, and how a disputed result is resolved. A photograph or a seller-supplied assay alone cannot establish that the offered lot and the delivered lot are identical. Record seals, weights and custody at handover. The LBMA’s responsible gold guidance discusses location, supplier and material risks, although its refiner standard is not a certification of any particular seller.

5. Review payment and sanctions exposure before commitment

Use qualified local counsel and your bank or compliance team to assess the parties, route, source of funds, sanctions exposure and contract terms. Be cautious if a payment beneficiary differs from the contracting seller, documents change at the last minute, or a party discourages independent checks. Specify in the contract when title and risk pass, what constitutes an acceptable assay, and how a failed inspection or permit issue is handled.

Questions to bring to a supplier

Who legally owns this specific lot, and who is authorized to sell and export it?
Which records support origin and each transfer of custody?
Which independent inspection and assay can the buyer arrange?
Which authorities and professional advisers have checked the proposed route?
What written conditions must be met before payment and shipment?

If you are evaluating a physical-gold purchase, send your specifications and destination through Get a Quote or contact the team. Conduct your own legal, financial and technical review before entering any transaction.