This policy outlines the framework implemented by Gold Bank to ensure that all precious metals purchased by the business are sourced ethically, responsibly, and legally.
Gold Bank operates as a secondary market bullion dealer,purchasing previously owned precious metals from private individuals and businesses. The company does not purchase newly mined materials directly from mines or mining intermediaries.
This policy applies to:
Gold Bank is committed to maintaining a supply chain that does not contribute to:
Because the company operates exclusively in the secondary market, the metals we purchase have already been refined and circulated. This significantly reduces risks associated with conflict minerals or unethical mining practices.
Nevertheless, robust due diligence procedures implemented to ensure that all purchases are legitimate.
Gold Bank’s responsible sourcing approach follows the five-step framework outlined by the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals.
Gold Bank maintains internal policies and procedures designed to ensure ethical sourcing, including:
Management maintains oversight of the sourcing framework and periodically reviews risk exposure.
As purchases occur directly from individuals or businesses in the secondary market, risk assessments are conducted for each transaction.
Where elevated risk is identified, additional due diligence may be performed or the transaction declined.
Where potential risk indicators arise, Gold Bank may:
Transactions suspected of involving illicit material will not be completed.
Detailed transaction records are maintained to ensure traceability of purchased items.
Records are retained securely in accordance with legal and regulatory requirements.
This policy and related procedures are reviewed periodically to ensure alignment with:
To mitigate financial crime and stolen goods risks, Know Your Customer (KYC) procedures are applied where appropriate.
These checks ensure transactions are conducted with identifiable and verifiable individuals.
Handling stolen property is a criminal offence under UK law. Gold Bank implements several safeguards to mitigate this risk.
Where required, the identity of sellers is verified before completing transactions.
Staff are trained to identify potential red flags, including:
Suspicious transactions may be declined.
Precious metal products are inspected where possible to identify:
Any goods suspected of being stolen will not be purchased.
Gold Bank cooperates fully with law enforcement authorities.
Where there is reasonable suspicion that goods may be stolen or linked to criminal activity, the company may:
Gold Bank complies with applicable UK sanctions regimes, including regulations administered by the Office of Financial Sanctions Implementation (OFSI).
The company does not knowingly conduct transactions with:
Where appropriate, sellers may be screened against relevant sanctions lists.
To reduce financial crime risk, transactions may be subject to enhanced scrutiny where sellers are identified as:
Additional due diligence may be conducted before proceeding with such transactions.
Gold Bank operates in accordance with UK legislation including:
Payments for purchased goods are conducted through transparent and traceable financial channels where possible.
Gold Bank seeks to avoid practices that may increase financial crime risk, including:
Employees involved in purchasing precious metals receive periodic training covering:
Transaction and due diligence records are maintained securely for a period consistent with applicable legal requirements.
These records support:
This policy is reviewed periodically to ensure it remains consistent with:
Gold Bank is committed to operating a transparent, responsible, and compliant precious metals business.
Through strict due diligence procedures, secondary market sourcing, and alignment with recognised international frameworks, Gold Bank aims to minimise risks associated with illicit precious metals while maintaining trust with customers, partners, and regulators.
Last updated: 11 January 2026
Gold Bank is committed to improving ethical, social, and environmental standards within the precious metals trading sector in London
✓ We maintain a zero-tolerance approach to modern slavery and human trafficking in compliance with the Modern Slavery Act 2015, and we fully adhere to the UK Bribery Act 2010, ensuring integrity and transparency in all our business activities.
✓ We also operate in strict compliance with our Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy, which outlines our procedures for preventing financial crime and ensuring regulatory compliance. This policy is available to view on our website.