Miners are onboarded and monitored in accordance with international responsible sourcing standards, Peruvian law and Swiss anti-money laundering requirements. The chemical signature of each ore batch is compared with the reference profile registered for its mine of origin.
Over 20 per cent of the world’s gold comes from artisanal and small-scale mining, yet this production remains marginal in institutional supply chains. Refiners and banks cannot accept the legal and reputational risks associated with uncontrolled sourcing. This void is the compliance gap.
OCIM has developed a compliance pathway: an architecture through which artisanal and small-scale gold can reach institutional markets under documented, auditable and traceable conditions. OCIM retains full control over every check in this chain, from supplier onboarding to delivery to the refiner
Upstream
Ocim
Downstream
Stakeholder confidence is based on verifiable facts: our requirements are documented, and their implementation can be demonstrated. Each pillar combines an onboarding stage with ongoing monitoring.
Every mining partner undergoes KYC and due diligence aligned with the OECD Guidance, the LBMA ASM Toolkit and the Swiss Better Gold framework. No ore is purchased before this process is complete.
As in banking, due diligence continues throughout the relationship. Each supplier file is updated as needed and reviewed annually. Any adverse information or incident triggers a review, which may lead to the suspension of purchases.
A baseline profile is recorded for each mining partner, covering expected volumes, mining site and the geochemical signature of its ore.
Every purchase is checked against this profile, and the supplier’s registration in Peru’s mining formalisation register (REINFO) is confirmed as still valid. Any discrepancy triggers a review.
Supplier files, purchase records and geochemical analyses are documented and retained in line with Swiss AML record-keeping requirements.
Geochemical data are secured on aXedras’ blockchain-based platform. Records are available for review by auditors and authorised counterparties.
Two voices, one framework
Doctrinal voice · OCIM Metals and Mining SA
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We bring Swiss banking-level compliance to artisanal mining
Group Head of Compliance
Fifteen years at Credit Suisse and UBS, where she served as Executive Director and Deputy Head of Compliance for Geneva and French-speaking Switzerland. Co-founder of Unravel One, a firm specialising in AML, OSINT, asset tracing and compliance advisory. Joined OCIM in 2025 to design the Group’s compliance and risk management framework.
Operational voice · Soleil Metals SAC
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Compliance is an opportunity to transform small-scale mining on the ground.
Compliance Officer
Over 20 years of experience in the mining sector and Peruvian capital markets. His career has focused on business development in the mining and financial sectors, alongside compliance responsibilities.
Geneva
Arequipa region
Consolidated risk management
Compliance and risk management are the responsability of OCIM Metals & Mining SA.
OCIM Metals & Mining SA is a Swiss legal entity subject to the Swiss Anti-Money Laundering Act and supervised by ARIF, a FINMA-recognised self-regulatory organisation. In line with Article 6 of the FINMA Anti-Money Laundering Ordinance, the Group conducts consolidated risk management across all entities, including Soleil Metals’ operations in Peru.
Operations in Peru are governed by the same framework as in Geneva. Where Swiss and Peruvian requirements differ, the stricter standard prevails.
This means that the framework governing the traceability and control OCIM’s trading operations in Geneva applies directly to operations at field level in Peru. Where a conflict arises between local practice and Swiss obligation, Swiss obligation prevails.
Developed by Swiss software company aXedras, xTrace is OCIM’s traceability backbone. It uses advanced chemical fingerprinting paired with AI to confirm whether a shipment of mined metal truly originates from its declared source.
The system is built on blockchain, a decentralised ledger that no party can alter retroactively. Once a transaction is recorded, it cannot be modified or deleted. It is this architectural property that makes the compliance pathway independently verifiable by any counterparty at any point in the chain.
xTrace is currently being deployed across Soleil Metals’ operations in Peru. Full implementation is underway.
Technology partner
aXedras AG · Switzerland
Status
Deployment in progress
Sourcing gold from artisanal and small-scale miners carries specific risks, widely documented across the sector, notably in Annex II of the OECD Due Diligence Guidance. The three principal risks for our activity, and the controls OCIM applies to each, are set out below.
Ore from unauthorised mines or protected areas, false declarations of origin, and substitution or commingling during transport and processing.
Every mining partner undergoes KYC and due diligence covering mining rights and formalisation status, complemented by field verification visits. Before every purchase, the supplier’s registration in Peru’s mining formalisation register (REINFO) is confirmed as valid, and every ore delivery is analysed against the supplier’s geochemical reference profile. Where a risk is identified, purchases can be suspended.
Buyers receive gold from ore whose supplier, mining rights and geochemical consistency have been verified.
Gold’s high value and fungibility make it attractive for money laundering. Layered ownership, undocumented cash flows upstream and the absence of provenance evidence expose buyers to proceeds of crime channelled through the supply chain.
OCIM applies KYC and due diligence standards equivalent to those required of Swiss financial intermediaries under the Swiss Anti-Money Laundering Act. Every mining partner is subject to identity verification, beneficial ownership documentation and screening against UN, EU, OFAC and Swiss (SECO) sanctions lists. Purchases are monitored for anomalies against the supplier’s baseline profile.
Buyers deal with a supplier that is itself accountable under Swiss AML law. Every source is known, anomalies are identified and addressed, and the documentation required for their own due diligence is available.
Child and forced labour, unsafe working conditions, mercury contamination and environmental damage at mine sites, exposing buyers to legal and reputational risk.
Every mining partner is checked for child and forced labour, and mining sites are assessed against the environmental criteria of the LBMA ASM Toolkit. Our operations are mercury-free, and mercury-free processing methods are required as a condition of partnership. During field visits, our technical team also advises miners on working conditions and safety equipment. Compliance is monitored throughout the relationship.
Buyers source from mining partners checked for child and forced labour, assessed against environmental criteria and supported in improving their working conditions.
Substitution or contamination of compliant ore during transport and processing, internal collusion at the plant.
Soleil Metals' employees are bound by procedures that prevent metal diversion during processing. Transporters are certified, parcels are sealed, customs operations are internalised. There is no intermediary in the chain between the mine and the plant.
OCIM can certify that 100% of the doré produced by its plants is delivered to identified accredited refiners, without blending with unverified sources.
OCIM holds the following memberships and certifications. Each is subject to admission criteria, ongoing reporting and periodic renewal.
Member of the ASM Task Force. Based in London, the LBMA is the international standard-setting body for the gold market.
Full Member
Step 1 accreditation for both processing plants. This accreditation covers requirements related to fair pricing, support for miners or upstream mining practices.
Step 1 accreditated
Extends independent verification to our due diligence and grievance systems, under a protocol recognised by downstream industrial buyers.
Audit in progress
Collaboration as part of the Gold Processing Initiative to jointly develop an international standard for ASM gold processing facilities.
Collaboration agreement
Member since July 2026, within a membership of Swiss refiners, traders and banks. OCIM joins as an integrated producer sourcing from ASM mining.
FULL MEMBER
FINMA's supervision of all of the group's activities under the Swiss Anti-Money Laundering Act.
AMLA regulated
The compliance gap is the mismatch between ASM production, accounting for over 20% of the global gold, and its presence in institutional supply chains, which accounts less than 1% of LBMA Good Delivery throughput. It exists because upstream compliance costs miners without immediate compensation, while downstream refiners cannot accept undocumented sourcing. A compliance pathway closes this gap: by providing qualifying miners with access to institutional markets via a mid-chain operator that carries the compliance function. At OCIM, this pathway is implemented through its subsidiary Soleil Metals.
OCIM’s Compliance Path comprises five components. Upstream KYC anchors the legitimacy of counterparties. xTrace provides transaction by transaction traceability with real time alerts. Swiss Better Gold Phase 1 certifies practices at the plant, through independent audit. LBMA Full Membership recognises compliance with the Responsible Sourcing Programme. Swiss AMLA supervision applies regulatory oversight, regular reporting and external audits.
OCIM Metals & Mining SA is incorporated under Swiss law and regulated under the Anti Money Laundering Act. It reports to the supervisory authority and undergoes yearly external audits. Pursuant to Article 6 of the FINMA Ordinance, risk management is consolidated across all group entities. The control framework applied to Geneva trading extends to operations in Peru, with country risk managed at group level.
Peru is classified as a higher risk jurisdiction in Swiss and European AML mappings. OCIM’s compliance framework is designed to absorb country risk before it reaches downstream partners. Operating zones are selected with geographic granularity. Political instability may affect operational productivity but not the compliance chain, which rests on international standards independent of local politics.
REINFO, Peru’s Registro Integral de Formalización Minera, allows plants to source from miners in the process of formalisation. Its limits are documented: some billing agents rent their REINFO status to informal operators, and REINFO alone does not guarantee operation legitimacy. OCIM treats REINFO as necessary but insufficient. It is the plant that closes the loop, by operating the physical point where the miner’s identity, the ore’s origin and the declared volumes converge and can be cross-checked in real conditions. Each supplier undergoes the 22 document onboarding, on-site verification of the mine, and continuous cross-check between declared concession and produced volumes.
OCIM cross-references three independent sources at every stage. First, documentary verification at onboarding: KYC file, mining title, sanctions screening, on site visit. Second, chemical fingerprinting through xTrace at every ore intake, matched against the supplier’s registered profile. Third, continuous cross-check against external provider data throughout the chain. Any inconsistency across the three sources stops the process before the material enters the plant.
Compliance and traceability address two different questions. Compliance verifies the counterparties: who they are, whether their mining title is valid, whether they meet regulatory and ESG standards. Traceability verifies the material: whether the ore delivered matches the profile recorded at onboarding. Compliance without traceability cannot confirm that the material corresponds to the qualified supplier. Traceability without compliance documents an unverified flow.
OCIM applies banking due diligence standards to its supply chain: KYC of counterparties, AML monitoring, sanctions screening. The automated alert system, designed with aXedras and inspired by monitoring tools adopted by banks, flags anomalies in real time. The difference is the object monitored. A bank flags unusual transactions. OCIM flags origin discrepancies: material whose chemical fingerprint does not match the supplier’s registered profile at onboarding.
Onboarding is completed before the first purchase. The process was developed with Swiss Better Gold and incorporates the requirements of the LBMA ASM Toolkit. Twenty two documents cover identity, the validity of the mining authorisation, sanctions screening against OFAC, EU and UN lists and ESG requirements including health and safety at the mine. Enrolment is based on the REINFO registry, supplemented by additional documentary evidence and verification points.
After onboarding, risk profiles and the validity of mining authorisations are reviewed periodically. Field visits are conducted independently of the sales teams. Each incoming batch is verified against the supplier’s file and cross-checked with the REINFO registry that anchors the miner’s formalisation status. Any inconsistency triggers investigation.
xTrace is the traceability layer of the framework. Developed by Swiss company aXedras, it combines chemical fingerprinting with AI and connected analytical devices. At every ore intake at the plant, it compares the obtained profile against the reference profile recorded at supplier onboarding. Discrepancies are flagged in the same way a bank flags unusual transactions. Records are immutable, held on blockchain and shareable with downstream refiners through the Bullion Integrity Ledger.
OCIM’s refiner clients require every ounce sourced from ASM to come from a traceable, audited and responsible supply chain. The compliance framework is what enables that guarantee: onboarding files aligned with the LBMA ASM Toolkit, continuous monitoring, chemical fingerprinting through xTrace and Swiss Better Gold Phase 1 certification obtained through independent audit.
Partnership aims to support ASGM formalization, strengthen supply chain integrity, and expand pathways to market for responsibly produced gold
Oscar Pezo, Head of Compliance at Soleil Metals, explains banking-grade compliance is applied to miners: twenty-two onboarding documents, upstream KYC files, on-site audits, scientific ore traceability...
On April 16, 2026, Vanessa Hungerbühler, Head of Legal and Compliance at OCIM Metals and Mining, took part in Session 3 of the Bullion Integrity Forum, organised by aXedras in Zurich. The panel, entitled “Enhancing Integrity with xTrace: Perspectives from the Early Adopters”, brought together four early adopters of the xTrace traceability system, including two refiners.
