Ethical supply chains, traceable minerals, and global integrity.
Trust is the fundamental asset in international commodities trading. At Burlcore Trading, every transaction undergoes thorough due diligence to guarantee full compliance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Our strict compliance framework prevents illicit financing, enforces strict chain-of-custody tracking, and ensures that every ounce of precious metal we distribute is sourced ethically and transparently. We subject our network to continuous independent audits to uphold absolute market integrity.
OECD Due Diligence, applied end-to-end
The five-step OECD framework is embedded across our operations, from producer onboarding through to final delivery. Risk identification, mitigation, and reporting are documented, dated, and independently verifiable.
LBMA responsible sourcing alignment
Our procedures mirror the LBMA Responsible Gold Guidance, aligning our practices with the same rigorous framework applied by the world's accredited refineries and their institutional counterparties.
Independent audit and reporting
We commission continuous independent review of our compliance posture. Findings inform ongoing improvements and are made available under NDA to qualifying counterparties as part of the onboarding process.
Counterparty onboarding and screening
Onboarding establishes corporate identity, ultimate beneficial ownership, source of funds and regulatory standing, screened against sanctions, politically exposed person and adverse media data. Screening is refreshed periodically and on any material change, so an approved file does not become a stale one.
Record keeping and audit readiness
Each transaction closes with a complete file: onboarding records, origin evidence, sampling and assay certificates, transit and customs documents, and settlement confirmations. Files are retained in line with Spanish and European anti-money-laundering requirements and can be produced for a counterparty's own compliance function on request.
Escalation and declined business
Where a red flag cannot be closed out with evidence, the transaction is escalated internally and, if unresolved, declined. Declining business is treated as a normal operating outcome rather than a failure, because a corridor accepted on an unresolved flag is a liability carried indefinitely.
At a glance
- Primary framework
- OECD Due Diligence Guidance for Responsible Supply Chains of Minerals, five-step model
- Market alignment
- LBMA Responsible Gold Guidance and good delivery expectations
- Regulatory basis
- Spanish and EU anti-money-laundering obligations, including 5AMLD-derived requirements
- Screening scope
- Identity, ultimate beneficial ownership, sanctions, politically exposed persons and adverse media
Common questions
What does the five-step OECD model require in practice?+
A documented management system, identification and assessment of supply chain risk, a strategy to respond to identified risk, independent third-party audit of due diligence at defined points in the chain, and public reporting on that due diligence.
How long are transaction records retained?+
Records are retained in line with Spanish and European anti-money-laundering requirements, which mandate retention for a minimum period after the end of the business relationship, and are indexed so a full file can be reconstructed on request.
Will you share audit findings with a counterparty?+
Yes. Qualifying counterparties may review the current governance dossier and independent audit findings under mutual non-disclosure as part of onboarding.
What causes a transaction to be declined?+
Unverifiable origin or title, sanctions exposure, refusal of independent inspection, or any red flag that cannot be closed with documentary evidence.
Related reading
The sourcing policy that sits beneath this governance framework.
ReadWhere compliance checkpoints sit in the transaction sequence.
ReadThe corridors and legal environments in which we operate.
ReadKYC, chain of custody, good delivery and related terms defined.
ReadReview our compliance frameworks
Qualifying counterparties may request the current governance dossier under NDA.