LBMA accreditation - facts, not myths

Today we’ll try to answer some sectoral interesting questions: How can a mint/refinery get LBMA accreditation? What weight does it carry? What does it even mean? How is accreditation different from LBMA membership? Is it applicable into smaller products? And should mints/refiners without such are to be treated.... Different?

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To make an introduction

We’ll begin our analysis by explaining basic terminology and distinguishing, so that it is clear:

Precious metal refinery, is a processing plant engaged in smelting precious metals in pure form, from natural raw materials supplied in form of scrap, recycled materials and, above all, from doré bars (precious metal mix) that mines supply. It is from here that we get cast bar, with an uneven surface and heavier weight - 50 g upwards. It is refineries that produce LBMA-compliant 400 ounce (12.5 kg) bar.

Precious metals mint is usually located directly next to refineries, and if not part of same company, it is with refinery or refineries that mints contract for supply. Mints, are involved in production of bullion, smaller bars and medals and decorative collector products. This is where surface smoothing and laser engraving of bullion takes place. Mints also supply minted bars (smooth surfaces, sharp cut lines, holding weight and size with minimal deviations) ranging in size from a gram all way up to 1.000 grams.

Since text will deal with LBMA accreditation requirements - 400-ounce gold bars and 1000-ounce silver bars - we will rely primarily on example of gold precious metal refiners.

‘To LBMA? Follow M25 ring, then left, downtown, past Bank of England.’

Depending on sources and date of publication, we can infer from available data there are at least 92, and more realistically at least 125 gold refineries operating worldwide whose products are acceptable as "Good Delivery" to at least one or more precious metals associations or exchanges. Operating scale can vary dramatically - from yellow metal processing giants like Switzerland's Valcambi (1,600 t. annually), through medium size, which for our purposes would include Australia's Perth Mint (300 t.), to relatively small operations like Japan's Tokuriki Honten (10 t.). Figures in brackets are maximum capacities for 2023, although from technological point of view, this would probably have to be reduced to 80-90% due to planned and unplanned production downtimes. After all, precious metal refineries, despite a nimbus surrounding, associated with exclusivity of final product, are first and foremost, highly specialized production facilities.

Of course, there are more gold refiners operating in world, but here (and for now) we discuss "Good Delivery" affiliation for at least one or more precious metals associations or exchanges. Given value of daily turnovers, this landscape will be dominated by London Bullion Market Association (LBMA), followed by CME Group (COMEX) and Shanghai Futures (SHFE) and Gold Exchange (SGE).

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In doing so, we must not forget on other, more regional, albeit reputable and with relatively large turnovers gold trading centres. From overall landscape, let us mention Singapore Bullion Market Association (SBMA), Chinese Gold & Silver Exchange Society, Hong Kong (CGSE), Tokyo Commodity Exchange (TOCOM), Dubai Multi Commodities Centre (DMCC), Multi Commodity Exchange of India Ltd (MCX), and Istanbul Gold Exchange (IGE).

Above graphic should clearly prove importance of LBMA both in terms of trading, but also in terms of creating and enforcing market standards for precious metals markets. Admittedly, this is data for 2021, and world has changed since, so we also have more recent numbers at our disposal. After all, LBMA has been presenting properly adjusted set of data to public for several years, although one would have to go to Nymex for most detailed. But for Q3 2023, based on a moving average of price of all transactions from period, weekly turnover was $325.65 billion. Dividing by five business days (we ignore all bank holidays), we’d get a daily turnover of $65.13 billion.

Gold opened that quarter at $1919 and closed at $1848 per ounce. So very casually assuming an average of $1883 per ounce, quarterly turnover, (all buying and selling) on LBMA amounted to 5.3k t.

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To put another dot finishing sentence, let's check further - in period 2020-2021, LBMA-accredited gold refineries, spread around world, processed a total of 5,038 t. of yellow metal. Above figure consisted of respectively: 2,271 t. of yellow metal from mining, 2,746 t. from recycling, and 21 t. from small/artisanal mines. To realize scale, for same period World Gold Council (WGC) reported mining and recycling numbers as in table below. And, of course, we are aware of imbalance in data for recycling from WGC and LBMA, but this is result of different methodology adopted by two organizations.

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It is an undeniable fact that gold refineries accredited by LBMA have processed most of gold supplied to markets each year. As of June 15, 2024, list includes 65 items. In addition, we have a 125-item list of former and non-existing accredited entities. Due to London’s market dominance, as well as dominance of LBMA’s accredited gold refiners and its position as a financial and bullion centre, LBMA-accredited refiners are automatically accepted by Istanbul, India, Shanghai and Hong Kong. Dubai, lists them as separate, special category. This approach only confirms, that granting accreditation by LBMA, is treated, as most important sectoral laurel.

About requirement of exactly 400 ounces (or 400 ounces-ish)

Sector relies heavily on refiners, whose gold bars are accepted for transaction settlement by associations and exchanges. Set of requirements to be met for such product is known as, "Good Delivery." Each association or exchange usually has its own and therefore requires exact size, weight and possible deviation from above to be as less as possible. Thus, for London market, this would be a standardized 400-ounce (12.44 kg) cast bar. To be precise, its weight oscillates between 350-430 ounces with a purity of at least 995. Length of top flat surface is to be 250 mm (margin of difference +/- 40 mm), and its width is to be 70 mm (margin of difference +/- 15 mm). Height of bar should be 35 mm (+/- 10 mm). Shape of LBMA Good Delivery bar should be inverted trapezoidal with slope of sides narrowing by 5-25%. Of markings, bar should include serial number, logo identifying refinery, purity designation in 4-digit format, of which one is decimal (e.g. 995.0 or 999.9), and a 4-digit number indicating year the bar has been cast. Latter point applies to bars being delivered from July 2008 onward. All markings are placed on larger - top - flat surface. .

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But above requirements and especially possible deviations cause some unanswered questions, like “why”. Let’s provide some explanations.

Above standard was created and maintained virtually unchanged, as a historical convention dating back to first half of 1930s. Let's look at some of London’s accreditations - Norddeutsche Affinerie was accredited before 1934 and re-accredited in 1953, while accreditation of Belgium's Umicore is estimated at 1934. LBMA website gives even older examples - 1921 for Rand Refinery and 1919 for Royal Canadian Mint. Technology used at time could’ve caused some inaccuracies for weight of bars produced. However, since thousands, (if not millions) of such bars have been delivered to London and then distributed globally among central banks and institutions over past 90 years or so, it was better not to change already set parameters and margins. This causes theoretically same 400-ounce bar from two different manufacturers to differ in dimension even significantly. An example of two extremes - AngloGold Ashanti located in Brazil supplies bars conforming to "Good Delivery" standard with a size of 212 x 95.38 mm high and a base of 195 x 76 mm. South Africa's Rand Refinery, supplies 260 x 80 x 40 mm bars with a 240 x 60 mm base. Both refineries supply both 995+ and 999.9 fine bars.

Gold is dense metal - one of densest known to man, yet relatively malleable in its pure form. And bar of "Good Delivery" standard has dimensions as above and corresponding weight. So even a slight decimal change in size parameter of a 400-ounce bar will effectively change its weight. Same will happen if, for example, we’d change 999.9 purity to 999.5. Therefore, ‘standardized’ LBMA bar, may vary depending on manufacturer. But 400-ounce dimension remains target. Each bar is therefore individually weighed to determine what multiple of 0.025 ounces it represents, with weight being rounded to nearest whole number. Only then is ‘gold content’ aka purity, taken into account, and it is now, when vaults do record number of ounces up to three decimal places – i.e.. 399.865 fine. Each association or exchange has its own "Good Delivery" requirements for weight and appearance of final product. London - which is a recurring theme of this analysis - 400 oz. Comex 100 ounces, although since pandemic, special contracts have also been opened for 400-ounce bars made in UK and 1 kg from across Pacific. Shanghai accepts 50 and 100 g in minted form, as well as 1000 g, 3000 g and 12.5 kg (400 oz.) cast. Examples can be multiplied, and technical specifications could be found on websites of respective entities'.

In order to become a supplier to absorptive LBMA market and be able to deliver product to liquid and perpetually gold-hungry market, accreditation is needed. And to obtain one, refiners must meet a wide range of criteria, about which in a moment. And yet, getting one from LBMA means automatic acceptance on several or markets, as mentioned. Other benefit is that of course we would deliver product in least costly form per ounce processed, so we cut processing cost per ounce and establish presence on strong wholesale market.

However, in case of LBMA, accreditation applies only to 400-ounce bars (1000 ounces in case of silver), product required by large-volume London market. If a refiner / mint offers other products – i.e. one-ounce bars or 100 g bars with a high-quality finish and design that would put in shame Renaissance master sculptors, accreditation does not apply to these, as it is not size expected by LBMA. Yes - an accredited manufacturer can put "LBMA accredited supplier" logo on its website and corporate correspondence. He can put it on invoices, company correspondence, email footers, advertising publications... After all, it is prestigious and customer perceives it as a sign of quality. But accreditation for 400-ounce LBMA bars formally isn’t applicable to bars or bullion at different weights. Ergo: For these there is no standardized design, marking and imposed standardization here.

And if evidence is needed for above, it can be found in official requirements for using LBMA-accredited refiner's logo:

"Specifications of gold and silver products and accompanying documentation relating to large products, 400 oz gold products and 1,000 oz silver Bars. However, logos should not be used on certificates for any or gold and silver products in such a way that suggests approval, acceptance or endorsement of such products and/or services by LBMA."

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LBMA market accreditation requirements

Now let's try to answer of how to obtain such "Good Delivery" accreditation from LBMA? London defines five main points, which we cite below and will try to describe and comment on them. A candidate for accreditation should:

Exist as an entity for at least five years and refine metal that is basis of accreditation application for at least three years. "Basis" because, after all, one can apply for accreditation for gold or silver. Or both metals, if requirements are being met. This point itself seems logical, because it excludes existence of newly established plants.

A slightly different consideration is given to point above when applicant is already accredited for one type of precious metal and is now applying for another, which is by-product of its main production. For example - a refinery belonging to a mining and smelting conglomerate specializing in copper and silver processes doré bars, thus obtains corresponding precious metals. It meets LBMA's volume requirements for silver, and is accredited for white metal, but to obtain one for gold, it must meet minimum requirement as follows:

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On the other hand, if it is accredited for gold and wishes to obtain accreditation for silver, requirement is simpler - a minimum of 20 t. of production per year.

Have a set annual production. For gold accreditation this will be 10 t. each year, three years in a row and for silver 50 t. yearly, for three years. Production does not have to be specifically in form of standard bars. This requirement can also be met by a significant and steady increase in production, taking place over course of said three years, with annual increase range as below:

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To have a production capacity for 10 t. / 50 t. of bullion, you need to have contracted suppliers, but also contracted customers. This also requires adequate production capacity and therefore appropriate investment of capital resources for longer period. So again, it's a matter of demonstrating that you are an active, stable entity with a base of established business contacts. An accredited LBMA bar is 400 ounces, or 12.44 kg. For rounding, let's assume that our production process is set at 402 ounces, or 12.5 kg equally. Assuming 10 t. gold requirement, we are looking at 800 LBMA bars.

Tangible net worth of not less than equivalent of 15 million GBP. Nod to pound sterling, circulating currency of UK, jurisdiction in which LBMA operates. It is required that sum of our real estate, land, machinery, cash, precious metals, etc. less our financial liabilities, must be net 15 million GBP. This way, we show LBMA we have capital, relative liquidity and are in position where we are not a zombie company delaying its demise over time. Is £15 million a lot? Assuming £1.830 per ounce, that would leave us with 20.5 bars in LBMA's 400-ounce standard.

Financial position and reputation that would meet due diligence checks practiced in London Loco market. In addition, applicant must have an owner, whose position would also meet requirements of LBMA. What does LBMA check? Whether applicant has implemented risk mitigation policies that cover following key areas: financial, reputational, logistical, sanctions, money laundering, bribery and corruption, and force majeure. Then, whether applicant has a sufficient level of insurance for precious metals held, and whether its declared ownership, financial position and reputation meet requirements.

Applicant must apply for LBMA's Responsible Sourcing Program and pass an independent audit before submitting its application. LBMA confirms that it seeks compliance with OECD's indications on transparency in sourcing and processing of raw materials, and that it expects accredited members to do same. By extension, applicant remains at the same time in compliance with EU Conflict Minerals Regulation based on above indications. Admittedly, due to length and complexity of Brexit transition period, EU Conflict Minerals Regulation is not adopted in whole of UK but only in Northern Ireland. But UK is a member of OECD, and UK Foreign, Commonwealth & Development Office has made it clear - it expects importers of commodities operating in its territory to act in accordance with above OECD designation. LBMA has expressed a desire to bring its requirements in line with above EU legislation and has taken steps in this direction. Hence world class diligence in screening gold sourcing.

LBMA also requires accredited entities to meet appropriate environmental, social, and governance (ESG) measures in gold supply chain, extending this of course, to ASM, or small-scale, independent, artisanal mining, and remaining consistent with or formalized requirements, such as Sustainability Principles that LBMA has developed in conjunction with WGC, London Platinum and Palladium Market (LPPM), and with input from relevant UN agency.

Sieve in action - application procedure

Application procedure requires submission of an application form downloadable from LBMA website, along with a set of prepared corporate and financial documents. Requirements are numerous, but allow LBMA to obtain virtually all information about applying organization, its supply chain and production process. A glance at requirements below is enough to conclude that applicant has to stand before LBMA dressed only in honesty and sincere intentions:

• A letter confirming financial position of refinery from local central bank for country in which refinery is located. If this is not possible, LBMA may accept an alternative document issued by another entity, but this should be agreed beforehand. This type of document can be issued by a regulated exchange on which refinery operates. Here, however, it will be necessary to confirm applicant’s participation in two or more - clearing, trading and delivery/storage.
• An independent audit report confirming compliance with Responsible Sourcing Program, as well as a management report.
• Description of risk management policies.
• Certificate of insurance for precious metals.
• Incorporation documents or commercial certificate.
• Latest available set of annual financial statement - auditor's letter, balance sheet and profit and loss statement.
• Detailed description of company's structure, and if multiple companies and a parent company are involved, preferably with an organisational chart.
• A description of shareholder structure. If there are a number of them, at least top five should include mailing addresses and number of shares held.
• List of company's directors as of date of application.
• Exact location of refinery, history of refining work, general description of main supply sources, production processes, assaying & marking methods, and presentation of customers.
• Statement of commitment to demonstrate compliance with Global Precious Metal Code.
• Proof of production for last three years to verify that applicant meets minimal production limits, along with estimates of what production looks like for the next two years.
• Accurate photos of 2700 x 1800 pixels in jpg format, illustrating bar itself and all markings. This has to be accompanied by technical drawing of product, along with a similar for markings and logos. Applicant also needs to explain meaningfulness of serial number sequence. This is to help detect gold-coated tungsten counterfeits.
• A video - about 10 minutes in length, explaining production process, recorded in presence of designated "Good Delivery" Supervisor.

To someone outside industrial-manufacturing industry, it may seem like a huge amount of "paperwork." However, from point of view of someone familiar with a manufacturing-industrial enterprise (even not necessarily from precious metals), this is usual set of documentation needed when attempting to obtain a supply contract from large customer. Though perhaps it's better to say "standard, though deepened," because after all, we discuss liquid financial market, so there's also strong due diligence requirement, deepened by strong set of rules on ethical metal sourcing.

To above set of requirements we can now add "field research." LBMA sends applicant samples of bullion made by so-called LBMA judges drawn from "Good Delivery" governing body. It includes serious recognizable brands. Applicant will have to perform assaying activities on samples received. We are discussing about twenty-four samples of gold or ten of silver - depending on metal for which applicant applied for accreditation. To determine purity of samples, applicant has 10 local working days for gold, or five for silver. This helps to confirm that applicant is able to effectively determine purity content, and so its quality structures should be able to find possible problems in 400-ounce bars.

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At next stage, applicant must provide eleven silver or gold bars (depending on metal in application). These have to be bars as per LBMA's 400-ounce requirements, albeit tightened for purposes of testing (narrow margin in weight) and with different, test markings, as defined by LBMA. This way, applicant demonstrates ability to make product for which accreditation he seeks. At same time, he incurs cost of preparing appropriate manufacturing process, which, by definition, should take place under conditions as close as possible to standard process. Applicant has four weeks to deliver bars to designated vault. There, they are measured and weighed in presence of a specialized crew and designated judges and then assayed, re-melted and subjected to spectrographic analysis.

Of course, in addition to cost of production process implementation - to meet LBMA needs - and cost of auditors, during process applicant incurs overall costs of application process containing as follows:

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If accredited, ex-applicant, now member of "Good Delivery" list, has to reckon with corresponding member annual costs and periodic quality testing, but that's another story. He also receives right to use "LBMA Good Delivery Refiner" logo, which is an LBMA-accredited refiner, in accordance with corporate requirements.

Final thoughts

So what is it all for?

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By obtaining LBMA accreditation for 400-ounce gold bars or 1.000-ounce silver bars, refiner proves that it meets high production and quality requirements, including responsible sourcing. Even though accreditation does not apply to smaller bar sizes, applicant's supply chain is screened holistically to prove above. And by being committed to issue of ethical and responsible precious metals sourcing, LBMA produces high market standard that its members are expected to adhere to.

Accrediting organizations - like LBMA - bring together major players involved in sector. LBMA itself has 83 full members, 71 affiliates and 11 market makers. Among them are brokers, major banks, dealers, fabricators, consultants, bullion-backed ETF managers or logistics and security agencies. Thus, if a group of top-tier specialized entities chooses to implement and adhere to high standards, this should be welcome. Especially, since they will be – via OTC LBMA – buyers of 400-ounce bars manufactured by us.

Having LBMA accreditation should therefore be seen as a guarantee of legality and compliance with law, and confirmation that bullion used comes from sources that have highest regard for hard work but also human freedom.