Why AML lands hardest on field buyers
Brokers, traders, and aggregators sit at the point where informal production meets formal money. Banks and refiners downstream apply their own controls, but they rely on the field's records to do it — a trading operation without credible KYC and purchase logs is un-bankable, whatever the quality of its material. AML discipline is therefore market access, in exactly the way an assay certificate is.
Know your counterparty
- Identity. Record who you buy from — name, photo identification where available, and the license or registration under which they operate.
- Legitimacy. A registered miner or cooperative with a verifiable credential is a different risk from an unknown walk-in seller. Registration status should be checked, not assumed.
- Beneficial ownership. For companies, know who actually stands behind the counterparty — front entities are the oldest trick in commodity laundering.
Source of funds and source of goods
Two questions anchor every clean transaction: where the money comes from and where the material comes from. On the goods side, an origin claim should be consistent with the seller's registration, geography, and production capacity — a seller offering more gold than their region plausibly produces is a red flag regardless of paperwork.
Red flags in artisanal sourcing
- Prices meaningfully above or below market with no explanation.
- Pressure to settle in cash, in a third country, or through unrelated parties.
- Origin claims that shift between conversations, or material inconsistent with the claimed source.
- Counterparties who resist identification or appear on behalf of undisclosed principals.
- Volumes inconsistent with the counterparty's registered capacity.
Records: the control that proves the others
Every control above only counts if it is written down. A defensible field operation keeps, per transaction: counterparty identity and credential reference, date, weight, price, origin claim, and payment method — retained and retrievable when a downstream buyer, bank, or auditor asks. This is precisely the record set the OECD five-step framework expects of management systems, and the reason we build tools like Ledger Lite for the field rather than for the back office.
A note on proportionality
AML expectations scale with risk — the framework logic of the OECD guidance applies here too. A small cooperative selling to one registered aggregator does not need a bank's compliance department; it needs consistent identity records and purchase logs. The goal is a chain where every actor can show who they dealt with and on what terms, at a cost proportionate to their scale.