Banking-grade Compliance

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 acocunts 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.