Compliance
Responsible sourcing is the price of market access
Gold that cannot evidence its chain does not reach the financial markets that price it. This is how the frameworks that govern this trade actually work, and what Nelum does at each point in them.
Why this decides market access, not just conscience
The London Bullion Market Association's Responsible Gold Guidance sets the standard refiners must meet to remain on the Good Delivery List. A refiner that cannot meet it does not simply face criticism — its gold stops being accepted by the financial markets that set the price. Market access is the enforcement mechanism.
That pressure travels backwards down the chain. A refiner that must evidence its sourcing needs its suppliers to evidence theirs, and those suppliers need the same from the producers behind them. By the time it reaches a doré consignment leaving a producing country, responsible sourcing is not an ethical preference — it is the condition of being able to sell at all.
Due diligence is a process, not a certificate
The OECD guidance is explicit that it does not deliver certainty about conflict-free status, and is not intended to. It asks for a risk-based process: identify the risks, act on them, document the decisions and the reasoning, and improve progressively through engagement with suppliers rather than through disengagement.
This matters for how a platform should be built. A system that issued a binary clean or unclean verdict would be misrepresenting the standard it claims to follow. What the guidance actually requires is a record of what was known, what was decided, and why — which is what a per-consignment archive provides.
Conflict-affected and high-risk areas
Where material originates in a conflict-affected or high-risk area, the expectation is enhanced due diligence rather than automatic refusal. Blanket withdrawal from producing regions is a documented failure mode of this regime: it removes legitimate livelihoods without reducing the harm, and pushes the same material into less visible channels.
Artisanal mining is the sharpest case. For many producers it is the only available livelihood, and the objective set out in the guidance is to keep legitimate artisanal production inside the formal market while protecting workers and the environment — not to exclude it.
Technology capacity varies, and the standard has to absorb that
Producing countries do not have uniform capacity to implement documentation-heavy frameworks. A requirement that assumes enterprise systems and full-time compliance staff excludes producers who are otherwise legitimate, which serves nobody — least of all the market, which still needs the metal.
That is the practical argument for putting the process in software: the structure, the document set, and the record-keeping are supplied by the platform rather than assumed to exist at each participant. A producer who can complete verification and file the required documents can meet the standard without first building a compliance department.
The five steps, and where the platform sits in each
The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas defines five steps. Each row below states what the framework asks for, and what the product actually contributes to it.
Step 1
Establish strong management systems
What the framework asks
Adopt a supply chain policy, structure internal management to support due diligence, establish a system of controls and transparency over the mineral supply chain, strengthen engagement with suppliers, and establish a grievance mechanism.
What Nelum contributes
Company verification, role-based authority, and a per-deal record that survives staff turnover. Every stage advance and document upload is attributed to a named representative of a verified company, which is what a control system means in practice rather than in a policy document.
Step 2
Identify and assess risk in the supply chain
What the framework asks
Identify the circumstances of extraction, trading, handling and export, and assess them against the risks set out in the OECD model policy — including finance of armed groups, serious human rights abuses, and bribery or misrepresentation of the origin of minerals.
What Nelum contributes
Origin is captured per consignment as structured data, not as a line in an email. Because the origin travels with the deal record, the assessment attaches to the specific parcel rather than to the counterparty in general.
Step 3
Design and implement a strategy to respond to risk
What the framework asks
Report findings to senior management, devise a risk management plan, implement it, monitor performance, and undertake additional fact and risk assessments for changed circumstances.
What Nelum contributes
Verification status and company details are live state, not a one-time check. When a verified company changes its registered details, settlement is paused and the change is flagged for review while the rest of the process continues — a proportionate response rather than an all-or-nothing block.
Step 4
Carry out independent third-party audit
What the framework asks
Audit of the refiner's due diligence practices by an accredited independent third party, at defined points in the supply chain.
What Nelum contributes
The assay that establishes what the metal is comes from an independent refinery, and is recorded against the tolerance in the contract. Nelum does not perform, replace, or substitute for an accredited audit — we hold the records an auditor asks for.
Step 5
Report on supply chain due diligence
What the framework asks
Publicly report on due diligence policies and practices, with due regard for business confidentiality and competitive concerns.
What Nelum contributes
The sealed deal archive is the reporting substrate: every document, decision and timestamp for a given consignment, retrievable years later without depending on anyone's mailbox.
The controls we apply
Applied to every company on the platform, before it can trade with you.
Business verification (KYB)
Incorporation and registration documents, tax registration, proof of registered address, ownership and control structure, beneficial ownership, bank confirmation, and trading or export licences. Collected and checked before a company can post demand, make an offer, or sign — enforced at the database level rather than in the interface.
Representative identity (KYC)
Every individual acting for a company is identity-checked and holds a credential showing their photograph, name, role, company, and that company's verification status, with a QR code a counterparty can scan at a meeting. This trade is still conducted face to face, and the credential is built for that specific moment.
Sanctions and PEP screening
Companies, their beneficial owners, their representatives, and the wallet addresses used for settlement are screened against applicable sanctions lists, with politically exposed person and adverse media screening treated as separate obligations rather than folded into the same check.
Ongoing rather than one-time
Designation lists change. A company clean at onboarding can be designated the following month, so screening is repeated on an ongoing basis against updated lists rather than performed once and filed. A single check at onboarding provides false assurance.
Record keeping and retention
Every stage advance, document upload, role change, and verification decision is recorded with its actor and timestamp. Verification records are retained for the periods anti-money-laundering law requires — at least five years after the end of a business relationship, and longer in some jurisdictions.
Change detection
When a verified company alters its registered details, the change is flagged and settlement is paused pending review while the rest of the trade continues. Verification is treated as live state that can lapse or change, not a permanent badge awarded once.
The limits of all this
Nelum applies anti-money-laundering, sanctions-screening, and responsible-sourcing controls modelled on financial-institution practice. These are voluntary standards adopted as a matter of policy; they do not constitute regulatory authorisation or supervision of Nelum by any authority.
We describe frameworks published by the OECD, the LBMA and other bodies because they govern this trade. Nelum is not accredited by, a member of, or endorsed by any of them, and describing a standard is not a claim to certify anyone against it.
Verification tells you that a company's registration documents were checked and its representative's identity confirmed at a point in time. It is not a credit assessment, not a guarantee of performance, and not a warranty about any consignment. The assay that establishes what the metal actually is comes from an independent refinery, not from us.
Verification comes first
No company trades on Nelum before it has been verified — including the one on the other side of your deal.