Welcome everyone uh to another flash learning session from the college of national security. Um with this session today looking at gold uh strategic asset or security risk. For those who've not joined us before, Flash Learning provides a quick and expert knowledge uh session on key national security areas from experts inside and outside government. Everyone on the call should have their cameras and mics turned off. If you have any questions throughout the session for our speakers, please do use the chat function and I will direct these questions or as many of them as possible to the speaker at the end of the session. We are absolutely delighted today to be joined by Andrew Naylor and Levy Pazulu from the World Gold Council, which is an international organization that champions the role gold plays as a strategic asset. They will talk about the governing role that the WGC holds in securing the future of a responsible and accessible gold supply as well as discussing gold as a national security vulnerability. And I'll now pass over to Andrew and Levy to get started. Thank you very much. Thank you. Thank you, Josh. And um very nice to uh well, thank you to the college for inviting us to uh to present. Um I'm going to share my my screen and then we'll get into a bit of introduction and then get into the presentation. Um so if I could ask Josh just to confirm that you can see this. >> Yeah, I can see the slides. If anyone can't, please do put in the chat, but I can see them. So hopefully everyone can. >> Okay, great. Um well, thank you again. Um so the the topic is gold and national security. Is it a strategic asset or a a national security risk? Um uh no surprises. I mean the gold council we uh strongly believe that gold is a strategic asset. It plays a huge role in the global gold market. But there are uh there are certain risks associated with gold that can be effectively managed and hopefully uh uh today's session will just be to touch upon uh some of those before I get into the the presentation uh just an introduction. So I'm Andrew Naylor. I've been with the World Gold Council for 10 years. uh used to run our Singapore operations now based in Dubai uh which is a major hub uh for the the gold market. Um so I run the Middle East operations but I also look after policy issues globally. Uh and a big focus of mine is uh is artisal gold and uh elicit finance and I'm joined by my colleague Levy. Levy do you want to introduce yourself? >> Thanks. Thanks. My name is Levy Pesulu and I'm sitting in UAE Dubai office and I'm leading on issues to do with AMLCFT. Thanks. >> Thanks Levy. Um so before I talk about um gold specifically just very quickly about the World Gold Council uh we are headquartered in London uh with offices worldwide in uh New York, Singapore, Shanghai, Mumbai and the UAE. Uh we're a membership organization. Uh so the world's largest gold mining companies uh sit on our board established us and they established us to essentially champion the role that gold plays. Uh but uh to do that really focusing on strengthening market integrity and we do that in a number of ways. Um we uh produce standards uh for the gold market. We make investments in uh new technologies or initiatives that could improve uh the gold market. Um we are pretty well resourced. Uh even though we're a trade body, a nonprofit trade organization, uh we are also the sponsors of uh two gold ETFs uh GLD and GLDM. Um and they uh are collectively the largest gold ETFs in the world. So we derive an income from those products but as a nonprofit uh our role is to disperse that income to improve how the gold market uh functions and we have a lot of different activities. Uh I'm just going to focus on our market integrity activities but if you're interested in in in more of our work um it's all on our website but we produce a lot of research. Uh we're working with um uh the authorities in the UK um to digitalize the wholesale gold market. Uh we've made or put capital behind new trading venues around the world uh and uh do a lot of product development as well. But I'm going to focus on on our um uh initiatives to do with um uh uh gold market integrity primarily today. Um first of all a bit of background and I'm going to move through these slides quite quickly because we don't have a huge amount of time. Um but the gold market is very global. Uh emerging market demand is about uh 3/4 of demand now. It's gone up um quite significantly. 40 years ago very different. It was very much a a a commodity or financial asset um that was consumed primarily in western markets. That has changed. It's a global market, but it's also diverse in terms of what it's used for. So about a third is used for jewelry. 6% 7% is technology. So it's used in high-end electronics for example. And the rest is investment. Gold is a financial asset. And that can be commercial investment. So pension funds, high- netw worth individuals, asset managers allocating to gold as an investment or central banks uh who use it as we all know as a reserve asset. This is very important though for understanding the risks uh not just the the role of gold but the risks associated with it because all of these different areas of demand mean that gold is constantly transformed. And what that means uh at its most basic is that gold is re-refined and when you refine it you lose uh traceability and that creates an opportunity for elicit actors to participate in the in the gold supply chain. It's traded internationally. I wanted to show this slide just to emphasize the role that the UK plays because sometimes in the UK gold can seem a little bit obscure or abstract. Uh but London is the the world's largest uh trading center for gold. Um over $ 160 billion dollars of gold is traded every single day in the London market. Uh New York is number two, Shanghai is number three. This is where gold is traded and because London is the the largest and most liquid market uh for gold, it's where the price is set. So the international price that you see uh that is um for a very specific metric, it's basically 1 ounce uh of a 400 ounce bar sat in a vault within the M25 around uh London. So the UK does have a role to play despite it not being a producer. uh production is global. Again, this has changed over time. 40 years ago, South Africa uh was the world's largest producer and dominated supply. Now, production is very global. China, Russia, number one and two producers in the world, but it's diverse as well. Africa is a huge uh gold production center. 75% of that production is from mining. Um 25% is recycling. But then within that mind production you have large scale mines. So that's primarily our members who are big industrial mining companies mining gold or you have a smaller scale or artisal uh gold mining and a lot of the vulnerabilities around gold are centered on artisal gold production. I'll talk about why in a minute. Um I must say though of that uh the 200 plus billion dollars of gold that's traded every single day the vast majority of that meets very high uh standards. Um so I don't want to leave you with the impression that uh the gold market is is hugely vulnerable. Uh there are very high standards of operation. Um the UK because of its role as the terminal market for gold as a financial asset uh through uh an organization called the London Bullion Market Association or LBMA set the standards for international refiners and those standards uh encompass a lot of things but one of which is the due diligence that they have to do on where they get the gold from. So standards do exist but that doesn't mean it's not without risk. And there are four broad national security risks associated with gold. Gold being used to fund conflict and terrorism. So that's where a criminal uh or a terrorist organization takes control of gold production and they do that they use gold uh to fund uh their activities. Second risk is sanctions evasion. We've seen Iran and Russia uh and um not just sanctioned countries but sanctioned individuals or entities using gold to evade sanctions. They uh it's attractive because it's very easy to liquidate. It's easy to transport around and it's priced in US dollars. You can sell it pretty much anywhere for US dollars. So, it's an attractive asset for a sanctions evasion. There's the environmental crime site more centered on production, but artisal gold uses mercury. Uh there's a lot of deforestation. Uh there's serious challenges around child labor, sexual exploitation at mine sites and so on. And the indirect national security risk emanating from that is one of societal breakdown in uh producer countries. Uh Ghana for example is doing a lot of work to formalize ASGM artisal gold mining. Um but there are estimates that 70% of water there is now contaminated with with mercury and if the price goes up uh that will make it more attractive and that could exacerbate the the problem and could potentially lead to to instability. And the final risk is the money laundering and organized crime risk associated with uh gold as an asset class. And those risks exist because of the informal production that accounts for 20% of supply. Gold is fungeable. It's easily transformed. If you melt it, takes on a new identity. You lose the trading, the chain of custody, the production history, the ownership history of gold when it's melted. Um, so it can easily be transformed. It's highly valuable. So a kilogram of gold, which is about the size of an iPhone, that's around about $160,000. It's portable. An iPhone, which is about the size of a kilogram, get it in your pocket. You can easily transport it in in hand carry. It's a universal currency. It's priced in US dollars. It's sold uh for international uh currencies. Um there's a market for it everywhere. You can take gold to Bangkok, Thailand very easily. Uh sell it in the uh in the jewelry quarter there. You can come to Dubai, the gold souk, you go to Hatton Garden in London, uh and so on. Um it's very very easy to to sell. It's cash intensive which creates other vulnerabilities around traceability. It's got a very complex supply chain uh which makes it easy to to mask origins and it's subject as well sometimes to to trade-based money laundering and invoice manipulation. It's hard to value or validate gold shipments unless you're checking absolutely everything at customs and valuing it and understanding the purity uh and so on. it's easy to over or underinvoice which creates further money laundering risks. We're trying to address these. Uh we've got a partnership um uh with the international compliance association uh to raise AML uh standards specifically in the banking sector. Uh we're working with FATF style regional bodies. I've put Mina Fataf on there. Uh but we are also and Levy I'm sure we'll talk about this working with Isamlag uh the uh fataf style body for east and southern Africa. Uh we're also doing some UAE specific stuff because the UA is a big um processing hub for gold and takes a lot of informal supplies but we've got a partnership with the UA Ministry of Economy um and uh we're working to harmonize accounting practices in the gold market. That's important because um accounting guidance for gold is inconsistent globally. It's not a UA problem. This is a global issue. That um discourages banks from participating. If banks don't participate, that creates a vacuum that's formed by filled sometimes by illicit actors. and we're working very strongly with the UN office on drugs and crime uh to develop uh recommendations for the supervisors of the sector and then a technical assistance program as well. So our work on this area is quite quite broad. I'm sorry I'm running through these quite quickly, but there's quite a lot we wanted to get through. And we'll share these slides later, and our Levy and myself, our contact details will be uh on the slides, and you're more than welcome to to reach out to us for more information. Next five minutes before I hand over to Levy, I'm going to talk quickly about artisal gold mining. This is one area where there are significant risks. Um it counts, as I said, for 20% of supply. um some of that will make its way into the London market through informal uh channels. Now, I want to stress that artisal gold um is not in in and of itself bad. Um it's important that legitimate artisal gold mining and responsibly produced artisal gold has access to to formal markets. So we are not calling for a ban on artisal gold mining but there are serious challenges associated with the sector. Mercury is used uh to extract gold from the ore that has huge health and environmental consequences. There's a significant challenge around the use of child labor in uh in supply chains. But then I think more relevant for this conversation on national security, you find that sometimes elicit actors get involved in artisal gold uh production. They either buy the gold and turn a blind eye to uh to bad uh practice and they they buy the gold to potentially smuggle wealth out of a country to evade sanctions. um or sometimes they might take a controlling interest in uh in gold production to generate funds. The narcotics trade uh is is known especially in Latam to take controlling interests in artisal gold sites to generate funds. Um and then you find as well uh that in uh conflicts around the world in Myanmar and Sudan both sides of those conflicts are being funded by uh gold production. Um after the invasion um of of Ukraine uh the um the Vagnner group or now the Africa gold corps they have been very active uh in many markets to get access to gold and that gold is put on private jets and often flown directly into Russia where it's used uh to fund uh the Russian war machine. We uh published a report on this which is on our website which goes into a lot more detail but we estimate that the ASGM uh related elicit economy could be valued at about $120 billion per year. So it's really important that um there are greater uh controls in place but also incentive mechanisms to make sure that that ASGM isn't funding conflict, isn't funding elicit activity and is contributing to uh economic uh development. So something that we're focusing on which is more upstream and Levy is going to talk more about the downstream which is perhaps more specific to to where the UK sits in the gold supply chain. Um but on uh ASGM we're looking to work with uh producer countries to introduce centralized processing plants, origin verification technology and then working with responsible buyers including domestic central banks to make sure that the capital uh that is going into the sector is from a responsible origin. and centralized processing plants are key to this because at the moment a lot of the challenges associated with the sector the mercury use for example the dry milling which creates a lot of respiratory problems that's the processing of the ore not the extraction of the ore so by giving artisal miners access to centralized processing plants uh you can increase their yield uh because you're not using mercury which is very inefficient you're using more sophisticated technology but you're also So um deploying an element of control um that gives the authorities greater oversight as to what is going on and where the gold is coming from and ultimately where it is going to. Um that's a very very quick overview of the project. We're working very closely with the World Bank and the Intergovernmental Forum on on mining on this and other and other partners. Um, I'm going to uh send a link to this or we'll send this presentation out so you can go into into it in more detail. But the final thing I'll say before handing over to Levy is I would look at um a recent report that we we commissioned uh silence is golden which sets out a lot of the national security challenges and a pathway uh to address some of those challenges uh in a report that was published um uh about 18 months ago. So I' I'd urge you to to have a look at that. Um I'm going to stop there. I'm going to hand over to Levy now who's going to talk more about um money laundering and the regulations and how uh perhaps the UK regime could be uh could be strengthened. Um Levy has a uh a long background in anti-moneyaundering. Uh joined us recently from uh the um the FIU of Zambia. Uh so as an AML practitioner um so Levy um over to you. I'll control the slides. just let me know when you want me to to move them on. >> Thanks Andrew and thanks everyone. I'm very happy to speak to most of you. Um I can see about 164 persons that have joined in. This is very good for us. Uh we're very happy to engage with you. uh so I'll speak more on AML CFT and what we are doing in terms of AML CFT as the world go council and trying our best to mitigate um any vices of MLS uh in the value chain of gold. So in terms of go uh gold I'll speak to what money laundering first actually is um most of you know from the word laundering I think it immediately speaks to washing. So we are talking about washing dirty money making it clean and be part of the financial system. So in terms of moneying the definition there so many definition but the definition that is acceptable so far is that money laundering is the process of making illegally obtained uh funds uh which is dirty money itself and appear legal and so so many stages which I'll speak to next slide Andrew. So uh so many stages about three stages um which speaks to issues to do with money laundering. Um I want you to um look at this from your work your daily work. For example, if you're a public servant and you happen to be in charge of issues to do with the uh procurement, you're sitting on a procurement committee and so on and you tend to have uh a way to influence a word of contract and then you are given a kickback, a corruption of some sort and so on. So that would is what we we are going to call a predicate offense. So in most cases for money laundering to occur first you would notice that uh what happens first is that there will be a predicate offense that is going to occur and some of these predicate offenses could be fraud, could be uh corruption, could be any anything that happens for example and and it all goes all the way to um even the gold space where you would be mining illegally, you would be using crime criminally obtained funds and so on. So the first thing that happens first is that actually you would find yourself uh committing a predicate offense. That does not mean that if no predicate offense occurs then money laundering can can't occur. I'll give you I'll site examples. Um you can go to internet you look you can look for names such as faith mus. It's a case in Zambia. It's already determined. this a determined case in in court where this lady was found by the law enforcement agency with about $64,000. Uh and the offense committed was that she was only found with money that she could not explain exactly to what the source of those funds were. Similar you can be found for example with the things such as gold without explaining how you actually acquired such gold and so on. So predicate offenses may not necessarily actually occur first, but sometimes you can find yourselves with the proceeds that you can't explain what they are. So the first thing that would happen then is that if a predicate offense doesn't occur, there would still be another way money laundering can still occur by finding yourselves with resources that you can't explain. And the challenge that you then have is that you now want to place these funds so that they can be part of the financial system. You want to transact. So when you transacting, you first want to place the funds that you've illegally obtained either through a corruption, as a as a as a public servant or whichever way you may have obtained those funds. And so the placement aspect becomes key in terms of the the process of money laundering. The next part that will happen is that you you have what we call layering in money man money laundering. At that stage you're trying your best for example to use legal means to ensure that the flow of money starts changing with what is illegal together with what so you're in in short trying to mix uh illegally obtained funds with what is legally obtained and at that at that moment you are trying to confuse the trail. You don't want a trail to exist in terms of the law enforcement if they come to you and they want to find out how you obtained those funds. So that process is what we are going to call layering. Once you have layered and this is an example that I always give in in most cases especially public officials. Once you have layered, you will now notice that this public official is now able to uh to confidently uh fund lavish uh travels uh holidays, pay for tuition fees for their child, their family members at the most expensive schools because then they know that they've completely closed the trail by layering. And so now they have they integrate the funds. So they are now able to put the funds into into uh treasury bills, bonds, they can buy property in whichever uh location and so on because they are a bit confident at that point. So in terms of the stages of money laundering, that's how the stages actually occur in terms of money laundering and this also applies. God finds itself in that context. Why is money laundering a story? Why do we actually need to speak to money laundering and why is it important for this conversation? Every government faces challenges of uh funds that are actually diverted, misused, corruptly gotten and so on. But the person who suffers at the end of the day is a a poor person by the end of the day who has uh gets affected because at the end of the day roads that are supposed to be constructed in a certain jurisdiction, hospitals, social service sector gets affected because the funds that should have actually gone to that direction uh do not end up in those locations because one or two people selfishly have ended up obtaining those funds and pocketed for their benefit. Next slide. So in terms of uh after speaking to why it's very important governments have looked at how they can find ways to mitigate this vice of money laundering that comes all the way into even into the space of gold in the space of minerals and so on. What has happened then is that the financial system had to come together. So many other institutions are looking at this aspect of money laundering. And one of the the the in terms of history, you will look at the bank secrets act which speaks to the conversation to do with money laundering. But at the same time, those that have done Arkhams will tell you about the EU directives that speak to issues to do with uh how the money laundering aspect could be mitigated. But that's not the end. A big giant entity then came on board which is the financial action task force the one that we call fatif. This is the mother then the parent of AML CFT. This entity uh next slide. This entity was established uh by the G7 and so many other countries have now joined this entity called FATIF and it has remained for many years and its role is very simple. Well, what it forms are what we call um um recommendations. They sound as the word is says recommendation but in real sense they are not recommendations. The the four recommendations that the financial action task force actually comes up with does not in real sense act as just a recommendation. If you violate the recommendation, you find yourself either grrey listed or if not lucky, you can end up blacklisted. And what happens is that these 40 recommendations have been agreed upon by the financial action task force to which almost every other country is a signator, is a member and so on. Two uh ways in which you can become a a financial action task force member. Some countries are direct as financial action task force members but many other countries have joined the financial act action task force through regional bodies which we call fatify regional bodies such as the Isamlag, the APG, uh the Gaba, the Menafatiff where we are in this region and so many other regions have formed groups which are part of financial action task force and they are called financial action task force style regional bodies. So that is where the history is and that's where we are this uh fatif which works with financial action task force star regional bodies then uh make sure that there is consistence in policy direction on anything that is to do with CTF and recommendations are jointly done together if there are any updates that are to be done in that space for example uh right now they are looking at issues to do with virtual assets it's a new story that is happening in the financial service. How can they go about virtual asset provider? For example, in many other countries, you find that they don't even have regulations on how to ensure that they participate in the virtual asset space. But the the FATIF will find a way to ensure that it works with those fertive style regional bodies in those countries to ensure that they become part of the the financial ecosystem. Next slide. In terms of the typologies uh mostly most mostly I I just highlight say a bit on this in terms of the typologies this will speak to what actually happens how what opportunities exist what could be the loopholes that exist in terms of both upstream and downstream and and that's exactly what it looks at so I'll leave this slide for you to look at uh there are so many that we've listed and so on so so that I go straight to recommendation and so on because of the time next slide. This I'll spend a bit of time because it speaks to you most of you in terms of the common regulatory gaps. This is where most of you actually are very very um uh are required to look at what you can do from your country in terms of the government and so and I'll start with the first one the dealers DPMS sector oversight. What it means DPMS is the dealers in precious metals and stone sector oversight. Many other countries do not have regulation in this space. Okay. And if you don't have regulation in how to supervise the dealers in precious metals and stone, everyone is going to do what they want. And when they do what they want, it becomes very difficult. illegally obtained funds will find its way into the mining sector into the dealers in precious metals. Uh stones will find themselves crossing from one country to the other. they will be shipped from one place to the other without following any procedures and so on. So the first key is that this space actually needs to have a designated supervisor. If it doesn't have let it then be pushed to the financial intelligence unit in that country because usually the financial intelligence unit in that country becomes the parent of all regulation on AMLCFT. The next item would be licensing regime. If your country doesn't have a licensing regime that can actually license the dealers in precious metals and stones, how do you supervise them? Because the licensing part is going to enable them to be able to trade. They'll be able to have license licenses that can actually enable them to to bank, to be able to transact, to be able to look at uh what the sources of the minerals that they're transacting such as gold and so on. Customs regime for example. Um sorry Levy, do you mind if I just say something on this as well? Um that's UK specific. Um so uh licensing regime we think is very important and in the UK even though the UK through the LBMA sets the international standards for uh refineries including how they do diligence on where the gold is coming from. So, making sure it's not funding conflict, making sure uh the gold hasn't come from a mine that's controlled by the narcotics trade. Those rules are voluntary um and they apply to international refiners. In the UK, there isn't a licensing regime. So, that means that anybody can can refine gold. And this is something that we've had a lot of discussions with the foreign office um the NECC and others have created a gymlet on uh um looking at the UK gold uh sector but I just wanted to to emphasize that point and also in the UK the DPMS sector isn't um it's clearly defined but doesn't have a a single uh regulator and and DPMS as Levy said it stands for dealers in precious metals and stones But it's quite a broad categorization. It also includes jewelry retailers for example. It includes jewelry manufacturers and also uh the refiners as well. So I just wanted to um just to make that sort of UK specific point. Um sorry Levy >> that that's fine. That's fine. In terms of customs regime, I'll give you an example again a practical example in terms of Sami. So you will see that in in terms of uh country specific some countries will have very weak uh uh customs regime in terms of how the hand carry of gold actually takes place in that country and while some other countries will have very strict rules and so on and because of this you will notice when you look at uh most producing countries such as in the African context you find gold crossing from say for example Zimbabwe crosses into into the Zambian uh into Zambia and finds its way to the to the to the trading hubs such as UAE and so on. So so the hand carry conversation in terms of the customs regime becomes very important. How what kind of regime do you actually have as a country when gold enters your country or when gold leaves your country? Uh do you have certification that can be provided to these traders? Can they easily carry gold from one point to the other? Carrying in their bags, in their pockets. Remember that gold is something that is very very easy to carry. I always give an example of a phone to say if I had my own phone in this context or I had one gold bar, one bar which is obviously maybe valued at 1.8 million US and so on. Most of the time, most of you and me may may immediately want to knock off from this this uh this session that we are having because of just one bar. That is how much value gold has. So, so how do you ensure that you actually have a licensing regime that can enable you to mitigate hand carried carried gold for example responsible sourcing? What procedures do you have in your country to enable to ensure that you mitigate the responsible sourcing aspect? Lack of mandatory responsible sourcing rules do are they there? Do you have them or not? Do they follow the OECD rules that are the due diligence rules that have been established? Let's speak about the last one which is information and intelligence sharing. This speaks most of the times it speaks to the intelligence the FIUs. uh how much of information is the law enforcement able to share in that country? Are they working in silos? Do they have as much framework that can enable them to share information? Does the revenue authority have much information that can be shared to the financial intelligence unit that can be shared to the police and so on. So that is very important when you are looking at uh some of these issues in terms of information and intelligence sharing so that you are able to capture if you don't have for example a a conflict affected and high-risk uh areas list in your country. How are you looking at ensuring that you mitigate some of those issues? Do you have a local list that is going to ensure that it captures those traders who are politically exposed? For example, traders in the gold space for example. Do you have that list that you can use to be able to identify some of these issues? Next slide. In terms of red flags, again I'll leave this for you to look at. These are many there are a lot of red flags that you can look at uh which I would advise you to read through. They are coming from all the way. You can look at them in terms of origin of gold. You would have red flags in that space. You would have red flags in terms of form of gold. how it actually then it comes to change its formation at the refining processing. You would have red flags on customs and importation. How it is moved from one country to the other. Red flags exist at this stage. You will have red flags in terms of customer profile and behavior. Are you able to actually look be able to actually identify who are the beneficial owners in terms of this gold value chain that takes place when the gold is mined or mined especially through the artisano small scale gold mining in one of these countries and it finds itself in your country. Do you have this information that you can look at that you can actually comfortably say you have a compliance program in place through the through the banks that are playing in this space that they've put in place and is able to identify who is the beneficial owner who is the person who's actually trading in terms of the KYCs and so on. Next slide. >> I think um Levy I'm just sorry to interrupt I'm just we've only got five minutes left I think. So, I think um perhaps we'll pause and see if there are any questions and we can get back to it if if not if that's all right. >> Thanks. >> Thanks, Andrew. >> We will send this uh um presentation out. So, I'm sorry we we were both rushed. We've got a lot of material on this as um >> as you can imagine and we' um we've tried to sort of condense it into into this flash session, but hopefully you found it a useful introduction. >> Thank you so much, Andrew. It's definitely been um fascinating for me. Um just before we go to a couple of questions before we hit time, I just wanted to um uh remind everyone to use the chat function to ask any questions and if we don't um get to them uh in this last few minutes, we can kind of follow up to those in writing. Um just before we ended, just wanted to highlight a couple of other things that the college has got coming up. Um on the 8th of September we have a hybrid seminar on uh how disinformation undermines democracy with a focus on state propaganda and gendered threats. Uh in person sign up for which closes on Friday. Uh and our next flash learning session is on the Middle East and energy security and why and what happens in that region is still important to our national security and that is on the 2nd of September. Uh I will now have a look at some we've definitely got some questions in here. uh looking at. So, I'm going to have a look at what's this one here? Um we've got a question from Amy um who says that you mentioned that gold laundering generates 120 billion pounds annually. Do we have an estimate of how much of that passes through London? How do our anti-gold laundering processes compare to other major gold trading hubs? Yeah, it's a very um very uh important question. Um and there there are two parts to it. On that 120 billion, how much of that passes through London? Unfortunately, it's impossible to know. And it's impossible to know because of how gold is transformed. Um what I would um what I would say is that key is expanding anti-money laundering um controls uh to include more of those red flags that Levy set out but specifically uh where the gold has come from and in what form because at the moment most of the DPMS sector globally is regulated primarily through an AML lens which is about due diligence on the counterparty. and due diligence on the currency leg of the transaction. But with gold, you've got to consider where it has come from. Has it come from a conflict affected or high-risisk area at the moment that due diligence burden is placed on the refineries once they refine it and then it goes to another refinery, they refiner it, it goes to a a trader, um it's very very difficult to uh to trace. I would suggest though the UK has you know is at risk because the uh the responsible sourcing rules are uh voluntary now for the large banks that play in this space they are absolutely not going to deviate from uh the responsible sourcing obligations but then the parallel market that exists hand carried gold is permitted into the UK um that's very hard to to detect. And there is a risk that some of that material that's coming in has emanated from a a problematic source that could uh be funding conflict that could be controlled by uh the narcotics trade or could be uh being used for for sanctions evasion. >> Brilliant. Um just to ask Andrew and are you happy for we've got because we've got lots of questions coming in. Are you happy for uh us to kind of collect these questions and send them to you and then for us to then distribute answers back out after the session? >> Yeah, absolutely. Yeah, that's fine. >> Brilliant. Okay, I think in which case I will uh we've got one more minute and I think obviously people can drop off if they are uh needing to go, but let's see if we can squeeze in one more quick question. Um, Brian Applebee asks, "Do you think countries like New Zealand, I presume NZ, is naming gold as critical material will assist with the need for tracking and certification?" >> Um, yes it will. Um, because it just focuses um policymaker minds. Um, gold unfortunately doesn't typically meet the definition of a critical mineral and it goes back to my my first slide or one of the first slides which was that the production of gold is very uh global. It's not dominated by one particular geography. Yes, China and Russia are number one and two producers in the world but Australia, Canada, uh um Ghana, um the United States are big producers as well. So it's not subject to the same concentration risk as some of the uh uh critical minerals where uh you know one particular country dominates supply. The other challenge with gold as well is the industrial use case for gold is actually quite low. It's about six 7% of demand for gold. A lot of the critical minerals uh motivations are also around um the minerals being an essential input into critical technologies. Now whilst gold does play a very important role in technology, there are substitutes. So its use case is a little bit different and supply is quite diverse. So I wouldn't expect that gold uh in many other countries and the two you know the two jurisdictions that are important for this US and the European Union um we have had conversations with authorities in in both and it's unlikely at this stage that gold would be designated critical but if it were um in other markets that would certainly assist because it focuses policy maker minds. >> Thank you so much Andrew. Um, and I think that unfortunately is all we have time for questions wise. Um, as I can see people are kind of having to leave and return to work. But thank you so much to Andrew and Levy for joining us today and everyone for joining us. Please do um, keep an eye out for what we've got coming up and we will um, kind of collect all those questions and hopefully get answers out to people. Thank you very much and have a good afternoon everyone. >> Thank you. Thank you Josh. Nice to meet you all. Thank you.