Table of Contents

Among the world’s major gold trading hubs, Dubai is a relatively new player. Yet it is savvy enough to pursue previously untapped markets and ambitious enough to frequently cut corners to bring gold to the market. The UAE’s share of world gold trade in 2018 is evidence of just how successful this strategy has become.1 As late as 1996, the UAE did not even appear among the world’s top one hundred gold-importing countries. Two decades later, the UAE ranked among the top four, above Hong Kong and the United States (see Table 2).

Of the eleven gold refineries in the UAE, the majority are located in Dubai. This accords with the Dubai Multi Commodities Centre’s (DMCC) own statistics, which show that Dubai is responsible for about 80 percent of the total UAE gold imports and exports (measured either by volume or value).2

 

Table 2. Top Gold-Importing Countries in 2018, by Weight
Rank Reporting Entity Weight (kilograms) Trade Value Unit Value (per gram)
1 Switzerland 2,248,611 $63,321,203,855 $28.16
2 China 1,121,317 $45,805,882,835 $40.85
3 India 945,060 $31,756,390,865 $33.60
4 United Arab Emirates 923,247 $27,672,052,091 $29.97
5 China, Hong Kong SAR 665,575 $23,627,497,773 $35.50
6 United Kingdom 629,049 $25,564,378,411 $40.64
7 Singapore 338,389 $13,514,112,543 $39.94
8 Turkey 299,556 $11,300,396,230 $37.72
9 USA 232,441 $9,641,469,104 $41.48
10 Italy 158,703 $4,056,681,077 $25.56
Source: UN Comtrade Database, accessed April 17, 2020, https://comtrade.un.org/data/; data reflects the gold classified under HS Commodity Code 7108.

Laundering Artisanal Gold

What is most problematic about the UAE’s strategy is where it gets its gold. Other major gold hubs source the bulk of their gold from relatively few countries, typically either other gold hubs or other major gold-producing nations. According to UN Comtrade data, for example, in 2016 the United Kingdom (UK) imported about 1,208 tons of gold from just six countries (listed in descending order): Switzerland, Canada, South Africa, Hong Kong, Australia, and the United States.

By contrast, in 2016, the UAE imported gold from more than one hundred countries, mainly located in Africa, South America, or South Asia. Less likely to be engaged in traditional large-scale gold mining, many of these countries are better known for artisanal and small-scale gold mining (ASGM). Characterized by low capital inputs, the use of traditional technologies, heavy demand for labor, and poor or absent government regulation, ASGM is nonetheless an important source of income for the rural communities.

Shawn Blore
Shawn Blore, previously a journalist, is now an independent consultant specializing in the areas of natural resources, supply chains, smuggling, and clandestine financial flows.

Yet in some parts of the world—notably the Democratic Republic of Congo, Sudan, and Venezuela—ASGM gold is sometimes taxed by, or otherwise used to benefit, illegal armed groups conducting insurgencies or is implicated in gross human rights violations. For this reason, ASGM gold is sometimes characterized as a conflict mineral. Even in countries that are not afflicted by civil conflict or atrocities, ASGM is often impacted by weak or nonexistent government oversight, illegal exportation, and smuggling.

For these reasons, gold is subject to many different—and often overlapping—sourcing, chain of custody, and due diligence standards.3 The specific elements of these standards vary, but all of them require that—at a minimum—those countries sourcing ASGM gold be able to determine whether the gold originated in a conflict-affected or high-risk country or is otherwise associated with gross human rights violations. Some tighter standards add additional criteria, such as the absence of child labor, holding of a legitimate mining title, and proof of legal export. Given the difficulties in assuring the clean origins of ASGM gold, reputable refiners tend to avoid it altogether.

ASGM [artisanal and small-scale gold mining] gold hand carried into Dubai is almost always sold in the emirate’s gold souk . . . rather than by major refineries.

In practice, Dubai follows few, if any, of these standards. ASGM gold hand carried into Dubai is almost always sold in the emirate’s gold souk—a compact area of a few city blocks where hundreds of small dealers compete to buy and sell gold in all its myriad forms—rather than by major refineries. Officially, the DMCC requires gold dealers operating in the emirate to have a written due diligence policy that aligns with standards of the Organisation for Economic Co-operation and Development (OECD), but there is little or no enforcement of this requirement.4 Dealers buying gold to sell in the souk require only a single document—a UAE customs form—that proves the gold was legally declared to customs officials upon arrival at an Emirati airport. The form does not require information about the gold’s origin.5 These dealers therefore accept gold originating from any country, regardless of the production circumstances, no questions asked.6 They habitually record their purchases of ASGM gold as “scrap,” a practice that even some refineries have exhibited.7 This accounting sleight of hand completed, souk dealers can then sell this gold to DMCC buyers or UAE refineries, having sufficiently clouded its origins to satisfy their auditing requirements.8

This lack of due diligence and Dubai’s efforts to cater to ASGM producers helps explain the UAE’s rapid rise as a major global gold hub. Far from competing with the traditional gold centers, Dubai does what other hubs will not—or legally cannot—do. It accepts ASGM gold from producer countries that—because of OECD and other standards—more respectable hubs avoid. An analysis of the UAE’s imports in 2016 showed that at least 46 percent of its gold supply came from countries that would be “red-flagged” by the OECD as being conflict-affected or high-risk countries had their country of origin been recorded rather than the country through which the gold transited. For example, gold from the Democratic Republic of Congo (DRC) and South Sudan are both commonly trafficked through Uganda, thus disguising its origins and resulting in it being considered Ugandan gold from a regulatory standpoint.

The process of reselling ASGM gold freely exported from red-flagged sources to Dubai jewelers and refiners (via the emirate’s bustling souk) essentially launders illicit ASGM gold into a refined product that is acceptable to the world’s most reputable gold hubs. As shown in Table 3, Switzerland and India imported a total of more than 200 tons or just over $8 billion in UAE gold doré in 2016.

Table 3. Gold Exported by the UAE in 2016, by Weight
Rank Reporting Entity Weight (kilograms) Trade Value Unit Value (per gram)
1 Switzerland 148,423 $5,922,940,937 $39.91
2 India 59,548 $2,136,789,719 $35.88
3 Turkey 42,952 $1,444,004,799 $33.62
4 Bangladesh 42,808 $306,054,164 $7.15
5 Morocco 39,714 $1,089,176 $0.03
Source: UN Comtrade Database, accessed April 17, 2020, https://comtrade.un.org/data/; data reflects the gold classified under HS Commodity Code 7108.

A second and comparably large portion of UAE gold is exported as jewelry, often to developed countries where conflict minerals laws should be more rigorously enforced. As shown in Table 4, the UAE exported just over 323 tons of gold jewelry worth some $11.5 billion in 2016. Most of this jewelry went to Iraq and India, but almost $500 million worth of jewelry made its way to the United States and a total of nearly $700 million worth made its way to Italy, the UK, and Germany—countries with legislation regulating the import of gold from conflict-affected countries.

Table 4. Gold Jewelry Exported by the UAE in 2016, by Weight
Rank Destination Weight (kilograms) Trade Value Unit Value (per gram) % of Total Weight
1 Iraq 79,459 $2,600,224,360 $32.72 25%
2 India 53,292 $1,600,353,586 $30.03 16%
3 Iran 19,815 $594,195,871 $29.99 6%
6 Italy 13,136 $354,293,022 $26.97 4%
11 USA 8,553 $468,594,559 $54.79 3%
17 Switzerland 4,648 $530,450,196 $114.12 1%
19 UK 3,585 $211,440,949 $58.98 1%
20 Afghanistan 3,030 $100,422,757 $33.13 1%
24 Germany 1,590 $52,963,233 $33.31 0.5%
27 Canada 1,478 $38,962,628 $26.34 0.5%
Source: UN Comtrade Database, accessed April 17, 2020, https://comtrade.un.org/data/; data reflects gold jewelry classified under HS Commodity Code 711319.

In summary, the UAE imported over 971 tons of gold worth some $32 billion in 2016, and nearly half of this gold came from red-flagged sources. It also exported 846 tons (jewelry and gold combined) worth $28 billion—much of it to countries that would have been prevented from directly purchasing this problematic gold because of domestic laws (for example, the United States’ Dodd-Frank Act and the EU Conflict Minerals Regulation) or other standards (for example, those set by the OECD and London Bullion Market Association). These statistics make clear that Dubai is a conducive place for laundering ASGM gold.

The DMCC: Is It a Serious Watchdog?

Established in 2002, the DMCC is Dubai’s quasi-private regulatory body for precious metals and gems. A fundamental challenge to the DMCC is its dual role of regulating the sector and promoting and facilitating trade. There is an inherent conflict of interest when efforts to increase trade involve relaxing regulation.

The DMCC established the Dubai Good Delivery (DGD) standard in 2012 and the DMCC Rules for Risk Based Due Diligence in the Gold and Precious Metals Supply Chain in 2016. These actions brought the DMCC’s standards closer in line with the core principles of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals From Conflict-Affected and High-Risk Areas. The DGD standard includes technical standards for gold purity and now also a requirement for the responsible sourcing of gold in accordance with the DMCC rules.9 Refineries wishing to achieve or retain DGD status must pass a periodic audit and publish a public assurance report.

Unfortunately, the DMCC’s [Dubai Multi Commodities Centre’s] sourcing and due diligence requirements are entirely voluntary and thus easily ignored.

Unfortunately, the DMCC’s sourcing and due diligence requirements are entirely voluntary and thus easily ignored. Only three of eleven refineries in the UAE have made themselves DGD compliant. The other eight refineries operate without any independent check on their sourcing. Yet these noncertified refineries all claim on their websites to adhere to DGD or OECD due diligence rules on sourcing; many also post compliance reports by auditors of some stripe purportedly showing their compliance (in Table 5, these are labeled as self-certified).

Table 5. Gold Refineries in the UAE
Refiner Location Current Accreditation Former Accreditation
Al Etihad Gold Refinery Dubai Dubai Good Delivery Not available
International Precious Metal Refiners Sharjah Dubai Good Delivery Not available
Emirates Gold Dubai Dubai Good Delivery Limited assurance report up to 2018
Dijllah Gold Sharjah Self-certified Removed from Dubai Good Delivery status in 2018
Gold Standard Dubai Self-certified Not available
Gulf Gold Refinery Sharjah Self-certified Removed from Market Deliverable Brand status in 2017
Istanbul Gold Refinery Precious Metals (Dubai) Dubai Self-certified Not available
Kaloti Precious Metals Dubai Self-certified Removed from Dubai Good Delivery status in 2015
Al Ghurair Gold Refinery Dubai Self-certified Removed from Dubai Good Delivery status in 2010
VGR Gold Refinery Sharjah Self-certified Not available
Fujairah Gold Fujairah Self-certified Removed from Market Deliverable Brand status in 2019
Sources: DMCC, Dubai Good Delivery Status List, https://www.dmcc.ae/application/files/4915/8729/0026/DGD_List-_Gold_Alphabetical_-Final-16-04-2020_Version_22.pdf, accessed April 18, 2020; DMCC, Market Deliverable Brand Status List, https://www.dmcc.ae/application/files/5215/7795/6905/MDB_list_-_Gold_Alphabetical_-_Final-V7.pdf, accessed April 18, 2020.

Given this patchwork of standards and the dubious practice of self-certification, the rigor of local audit processes remains questionable. In 2013, a whistleblower alleged that his then employer—international auditing firm Ernst and Young—colluded with Kaloti Jewelry International and the DMCC to conceal the sourcing of gold from high-risk or unknown sources.10 Under newly revised rules, Kaloti Jewelry International subsequently passed that audit but was later removed from the DGD list in 2015.11 The firm has strongly denied media reports about these allegations, asserting that they are “full of contradictions and inaccuracies” and rejects “any implication relating to regulatory non-compliance in the gold trade.”12 Nevertheless, in April 2020, a UK judge awarded almost $11 million in compensation to the whistleblower, finding that his former firm had breached its professional duties in its handling of the 2013 audit of Kaloti Jewelry International; Ernst and Young says it will appeal the ruling.13

Dubai-based refineries also frequently trade with each other, creating yet another loophole in global supply chains. This self-regulation appears to satisfy their customers. This is perhaps because, with one exception, the noncertified refineries all make it clear that they do not source mined gold.14 All of their gold, they claim, comes from jewelry, scrap, and sources within Dubai. But this likely means that these refineries only buy gold through the souk—of which most is considered laundered. For these refineries’ buyers, though, the claim appears to be enough. The identity of these buyers—for example, which firms in India or Switzerland purchase from which Dubai refineries—remains a mystery.

Marcena Hunter
Marcena Hunter is a senior analyst at the Global Initiative Against Transnational Organized Crime, where she has worked since 2012.

These problematic practices therefore beg the question: does the DMCC give false legitimacy to gold flowing through the jurisdiction from high-risk sources?

Fly by Night: How Gold Is Smuggled Into Dubai

Figure 4 shows the cumulative contribution of the most significant African sources of the UAE’s gold imports from 2008 to 2016.15 Particularly notable—in addition to the vast growth in volumes of UAE-bound gold—is the lack of any geographic pattern. Gold travels to Dubai from all regions of Africa—basically from anywhere with an airport. Gold bound for the UAE travels overwhelmingly by air.16 Most of this gold is hand carried by individual couriers, who usually carry 2–20 kilograms, with 10 kilograms being a typical parcel.17

Dubai airport is now the world’s busiest by passenger volume. Many, if not most, African capitals are serviced by direct flights to the UAE. Even better, these flights are often under five hours in duration and generally cost less than $500, meaning a gold courier can reach Dubai in a single day’s travel for the cost of approximately 10–12 grams of gold. The UAE’s geographical position and extensive air links to Africa are one of Dubai’s legitimate competitive advantages in the gold trade.

The UAE’s laissez-faire customs process is a second, somewhat less legitimate, competitive advantage. As noted above, most gold is hand carried to the UAE by air. Gold couriers, like other air passengers, are subject to security screening, including x-rays, which make gold ingots exceedingly obvious. Given this, African nations that serve as export points for gold would seem to be in a position to enforce their export laws and regulations, particularly those pertaining to royalties. And yet the opposite appears to be the case.

The UAE’s laissez-faire customs process is a second, somewhat less legitimate, competitive advantage.

Figure 5 compares the volumes of gold legally declared and exported from the eleven nations of the International Conference on the Great Lakes Region (ICGLR) (blue columns) with the volumes of gold arriving in the UAE from these same nations (red columns).18 According to the results shown, the price of gold quadrupled between 2003 and 2011 from some $12 per gram to over $50 per gram, and the volume of gold imported to the UAE (red columns) shot up in tandem from some 4 tons in 2003 to more than 28 tons in 2011. Mysteriously, however, gold legally declared and exported from these same countries declined precipitously year over year during that same period.

The difference between the blue and red columns—in other words, the volume of gold legally exported and the volume of gold arriving in Dubai—represents the volume of gold smuggled from these nations to Dubai. In 2011, the difference amounted to some 22.5 tons, or $1.1 billion dollars in smuggled gold. Assuming an export royalty rate of just 2 percent, this represents a tax loss to these countries of about $22.5 million per year.

This figure illustrates African exporters’ increasing expertise at evading export controls. While techniques vary from one country to another, the need to pass gold through airport x-ray machines depends on some sort of arrangement with the airport security staff at the exporting airport. Several gold couriers who regularly make the trip from Bunia in the DRC to Entebbe in Uganda and then on to Dubai informed the author that these arrangements are put in place beforehand by the courier’s boss, who deals with officials at a higher level than frontline airport security staff. The couriers reported that x-ray machines at Entebbe airport have indeed detected their gold, but the gold was subsequently passed on to a supervisor who then facilitated the couriers’ passage (and the gold) through to the airport departure lounge.19 These couriers were not privy to the details of whatever financial arrangements might have been made to facilitate this passage.20

Once past security and on the plane, all need for deception is past. On arrival in the UAE, couriers declare their gold to customs authorities (there is no tax) and fill out and sign a gold import form, listing, among other things, an unverified self-reported claim about the gold’s country of origin. Sometimes couriers are asked to show their boarding pass as proof of the gold’s origin, but this is rare.21 Form in hand, couriers are free to sell the gold wherever they want in Dubai or elsewhere in the UAE. Typically, the gold is sold in the Dubai gold souk. As noted above, souk dealers record these purchases as scrap gold, which provides a suitable paper trail for selling this gold on to one of Dubai’s gold refineries.

Dubai: A Smuggler’s Gateway?

Dubai’s role as a financial center and its lax regulation of the gold trade, favorable geographic position between Asia and Africa, and access to free trade zones have all contributed to Dubai’s growing reputation as a node of corruption. This is evidenced by the increasing crossover of smuggling, gold laundering, and TBML activities involving Africa and Dubai. Gold is smuggled to Dubai, and the profits are used to purchase goods for import to Africa (often after being misinvoiced) and then sold for a profit, creating double the opportunity to raise illicit funds. Globalization is exacerbating the problem, as many countries are struggling to update regulations in line with the exponential growth of global trade.

Meanwhile, free trade zones help criminal actors take advantage of the regulatory loopholes. A 2010 FATF study identified a number of endemic weaknesses that make free trade zones vulnerable to money laundering, including relaxed oversight, lack of transparency, absence of trade data, and limited systems integration.22 Dubai’s gold-oriented free trade zones are thriving; in 2018, the DMCC welcomed 1,868 new companies to its zone, marking a 12 percent growth.23 Gold traders use the hawala system extensively for the purposes of TBML.24 The hawala system is a centuries-old informal financial system that allows money to transit countries without currency actually moving, usually by linking money flows with the import and export of goods. A combination of loosely regulated gold imports, poor oversight of free trade zones, trade misinvoicing, and the flow of currency via informal systems like hawala are a boon to trade-based money laundering networks.

The hawala system is a centuries-old informal financial system that allows money to transit countries without currency actually moving, usually by linking money flows with the import and export of goods.

Dubai’s illicit and licit traders alike also enjoy favorable tax rates. In 2017, the UAE levied a 5 percent value-added tax on gold and diamonds at the wholesale level. However, after gold traders subsequently had their worst months ever—reported sales fell 30 to 40 percent from the year before—the UAE rolled back the tax in 2018, restoring Dubai as a leader in global gold trading.25

Negative Impacts of the Illegal Gold Trade

Numerous harmful impacts stem from the illegal gold trade, which is heavily facilitated by how easy it is to launder gold through Dubai. In particular, protection economies—where the state, businesses, community actors, and organized crime are all interlinked and use corruption and violence to secure illicit rents—are especially problematic. They undermine the rule of law, stability, and security. Corruption is nearly ubiquitous in the ASGM space, but violence can also be found, often in some combination with corruption.

Unsurprisingly, corruption at the highest levels inflicts the most damage to governance and rule of law. Politicians may use proceeds of gold-related corruption to fortify political patronage, thereby securing power and the ability to continue to profit from the gold trade. For example, in Zimbabwe, the benefits of ASGM are not just enjoyed by high-level members of Zimbabwe’s ruling party but are also allocated to its core supporters. The result is a mutually beneficial relationship, with politicians seeking to gain the support of AGSM operators. This prevents members of the opposition party from engaging in the ASGM sector. This has a particularly strong impact in Zimbabwe, where gold is an important sector of the economy and few comparable alternative livelihoods exist, forcing individuals to support the ruling party in order to eke out a livelihood. High rates of corruption enable actors to exploit the gold sector with impunity and make it difficult for interventions, such as those aimed at formalization, to penetrate the ASGM sector.26

There is also evidence of gold being sold either indirectly or directly via Dubai, contributing to insecurity and conflict in Africa. This benefits conflict actors in the region, many of whom are increasingly profit-motivated rather than ideologically driven. Persistent insecurity spurred on by these armed groups enables them to continue to profit from illegal activities—including the illicit gold trade—unimpeded. Thus, because it is easy for conflict actors to move gold to and find buyers in Dubai, the trade continues to contribute to insecurity and conflict. For example, there is evidence of direct illicit gold trade between Sudan and the DRC and Dubai. In the DRC, numerous reports by the UN Group of Experts find that ASGM provides the most significant and continual financial benefit to DRC-based armed groups and organized criminal networks. They have also identified the central players responsible for the organized smuggling of Congolese gold to Dubai. But these players continue to export gold without the imposition of administrative or legal sanctions by either the exporting countries or Dubai.27

Likewise, since 2011, ASGM has been closely linked to conflict and competition for illicit rents in the Darfur region of Sudan. In 2016, the UN Group of Experts estimated that the Jebel Amir mines—Darfur’s largest gold field—were yielding 8,571 kilograms of gold per year, valued at $422 million. Today, the gold mines are controlled by Mohamed Hamdan Dagolo (“Hemeti”), deputy chairman of Sudan’s ruling Sovereignty Council. Investigative journalists found that a minimum of 57 tons of gold were exported from Sudan to Dubai during 2012. The mined gold was reportedly classified as scrap gold to disguise the high-risk source of the mineral.28

Policy and Enforcement Remedies

Dubai is entitled to be a major world gold hub. The emirate’s ideal geographical location, excellent access via air, and competitive marketplace allow its gold dealers to offer higher prices and faster turnarounds—to the benefit of both buyers and sellers.

However, Dubai’s role in the global gold trade is problematic due to Emirati authorities’ lackadaisical approach toward traders’ due diligence and responsible sourcing obligations. Without requiring any kind of export license or certificate of origin for hand carried parcels, the UAE has essentially allowed gold smugglers to try and avoid legitimate government royalties or export taxes. As a direct result, smuggling of African gold has become the norm, not the exception, depriving African nations of millions of dollars of needed revenue.

The UAE’s lax due diligence policies have also made Dubai the destination of choice for African exporters looking to launder conflict gold.

The UAE’s lax due diligence policies have also made Dubai the destination of choice for African exporters looking to launder conflict gold. These include armed groups from the DRC, Sudan, and, to some extent, the Central African Republic and the Sahelian countries. This, in turn, has unnecessarily exacerbated or prolonged a number of African civil conflicts.

Fortunately, feasible technical measures exist to address these problems:

  • To deter smuggling, the UAE could demand that couriers hand carrying gold produce legitimate export documents (export licenses, certificates of origin) and proof of payment of export taxes/royalties from the purported country of export.
  • To deter the laundering of conflict gold, the UAE and Dubai authorities could work with African nations—particularly ICGLR countries—to develop a system that requires mineral exports to have a certification attesting to their conflict-free status.
  • To further deter the illicit gold trade, the UK and United States could impose discretionary travel and financial sanctions on those Dubai-based businesses and individuals that facilitate it.
  • To foster the adoption and implementation of the OECD due diligence standards, Dubai could demand that refineries adhere to the DGD standard as a condition of operation.
  • To discourage laundering of smuggled and conflict gold through the Dubai souk, the DMCC or another appropriate Dubai authority could develop an OECD-type system of due diligence for souk dealers and insist on its adoption as a condition of operation.

Most of these technical measures would be relatively easy for UAE authorities (for example, customs departments and the DMCC) to implement. What is lacking is the political will to attempt them. Numerous entities, ranging from nongovernmental organizations to the OECD, have tried to constructively engage UAE and Dubai authorities on these issues, with limited to no effect.

The reasons for the UAE’s reticence to take action are not entirely clear. Certainly, the current laissez-faire model is working, if gold volumes are the yardstick. But a UAE that insists that exporters pay taxes and that importers perform due diligence would still be a UAE with comparative advantages, including its geographical location, access via air, and established marketplace.

Unfortunately, UAE authorities appear untroubled by the fact that Dubai has become a major hub for laundering ASGM gold. Instead of becoming a responsible member of the world’s gold community, the UAE is essentially facilitating tax evasion and indirectly perpetuating conflict within its supplier countries. Disabusing the UAE of its current business strategy ultimately will require some degree of external pressure.

Notes

1 Figures in this section are drawn from the UN Comtrade Database. Gold here refers to HS code 7108, including its three sub-components: 710811, 710812, and 710813. For most countries, the bulk of the traded gold falls into the 710812 categories. The United Kingdom, however, classifies the bulk of its gold imports under 710813. Using the global 7108 category captures all of this trade.  

2 “Our Gold Services,” Dubai Multi Commodities Centre (DMCC), https://www.dmcc.ae/gateway-to-trade/commodities/gold.

3 Chief among these are the OECD Due Diligence Guidance for Responsible Mineral Supply Chains, the measures outlined in Section 1502 of the U.S. Dodd-Frank Act, the Responsible Jewelry Council Certification Standards, the Conflict-Free Standard of the World Gold Council, and the Responsible Gold Guidance of the London Bullion Market Association.

4 Hunter, “Pulling at Golden Webs.”

5 This is for hand-carried gold. For air-freighted gold, four documents are required: an import declaration, airway bill, delivery order, and original invoice. None of these, however, is an export permit or certificate of origin; in any case, most gold is now hand carried. See Alan Martin and Bernard Taylor, “All That Glitters Is Not Gold: Dubai, Congo, and the Illicit Trade of Conflict Minerals,” Partnership Africa Canada, May 1, 2014, 14, https://www.africaportal.org/publications/all-that-glitters-is-not-gold-dubai-congo-and-the-illicit-trade-of-conflict-minerals/.

6 Shawn Blore, “Contraband Gold in the Great Lakes Region: In-Region Cross-Border Gold Flows Versus Out-Region Smuggling,” Partnership Africa Canada, May 2015, 27, https://impacttransform.org/wp-content/uploads/2017/09/2015-May-Contraband-Gold-in-the-Great-Lakes-Region-In-Region-Cross-Border-Gold-Flows-Versus-Out-Region-Smuggling.pdf.

7 Ibid., 28.

8 “City of Gold: Why Dubai’s First Conflict Gold Audit Never Saw the Light of Day,” Global Witness, February 2014, http://www.globalwitness.org/sites/default/files/library/dubai_gold_layout_lr.pdf.

9 “Accreditation Initiatives,” Dubai Multi Commodities Centre (DMCC), https://www.dmcc.ae/gateway-to-trade/commodities/gold/accreditation-initiatives.

10 According to Global Witness, “Kaloti Jewellery International DMCC (KJI) and Kaloti Jewellers Factory Ltd (the refinery) are subsidiaries of the Kaloti Group. KJI is responsible for the management of all aspects of the physical precious metals business in the UAE.” See Global Witness, “City of Gold”; and Martin and Taylor, “All That Glitters Is Not Gold.”

11 “Active Dubai Good Delivery Members,” Dubai Multi Commodities Centre, https://www.dmcc.ae/application/files/3615/6259/4701/DGD_List-_Gold_Alphabetical_-Final-07-07-2019_Version_18.pdf, accessed February 24, 2020.

12 “Kaloti Response to Media Reports,” Kaloti Precious Metals, undated, http://www.kalotipm.com/Media-Center-PressReleases-Details/13/KALOTI--RESPONSE-TO-MEDIA-REPORTS.

13 Jane Croft and Tabby Kinder, “EY Ordered to Pay $10m to Dubai Whistleblower,” Financial Times, April 17, 2020, https://www.ft.com/content/ff29cc66-d77b-472e-bf5f-fb364e82333a.

14 The exception, Kaloti, admits it sources gold dore from mined sources worldwide.

15 Hunter, “Pulling at Golden Webs.”

16 Hunter, “Pulling at Golden Webs”; and Blore, “Contraband Gold in the Great Lakes Region,” 22.

17 Blore, “Contraband Gold in the Great Lakes Region,” 22. Air freight was in common use, at least from Entebbe airport, until one trader had over 14 kilograms of gold stolen from a Dubai-bound air freight container. Since then, traders in East Africa have largely relied on hand carrying gold. Author communication with a Kampala gold trader, Kampala, September 2014.

18 Blore, “Contraband Gold in the Great Lakes Region,” 22.

19 Author communication with Bunia gold couriers, Bunia, May 2015.

20 A supervisor for Aviation Security claims that security staff regularly detect gold in small amounts (1–5 kilograms) and that gold that is not declared is seized. However, he could provide no corroborating data on gold seizures. This supervisor also admitted that collusion with gold smugglers does sometimes occur but that management was working to eliminate this problem. Author communication with an aviation security official, Entebbe Airport, September 2014. See also Gregory Mthembu-Salter, “Baseline Study Four: Gold Trading and Export in Kampala, Uganda,” OECD, May 2015, https://www.oecd.org/daf/inv/mne/Gold-Baseline-Study-4.pdf.

21 Author communication with Bunia gold couriers, Bunia, May 2015.

22 “Money Laundering Vulnerabilities of Free Trade Zones,” 15–17.

23 “DMCC Has Welcomed 1,868 New Companies to Its Free Zone in 2018,” Gulf News, June 23, 2019, https://gulfnews.com/business/dmcc-has-welcomed-1868-new-companies-to-its-free-zone-in-2018-1.64790921.

24 Shedrofsky, “Remittances and Trade-Based Money Laundering.”

25 Manoj Nair, “VAT Charges Removed on Gold at Wholesale Level,” Gulf News, May 1, 2018, https://gulfnews.com/business/vat-charges-removed-on-gold-at-wholesale-level-1.2214957.

26 Hunter, “Pulling at Golden Webs.”

27 Ibid.

28 Ibid.