Gold Traceability in Africa and Compliance with the LBMA: What the 2026 Debate Means for Miners, Refiners and Buyers

By: Gold Miners Club Published 12 November 2026

Introduction: why gold traceability in Africa is the defining issue of 2026

With gold trading well above $4,000 an ounce this year, the incentive to move metal outside official channels has never been stronger. Africa sits at the center of that tension. It supplies a large share of the world’s gold, much of it from artisanal and small-scale mining (ASM), and it is where the argument over provenance, enforcement and market access is most intense.

This article uses 2026’s key developments to explain the wider debate on gold integrity, and what LBMA compliance now demands from African producers, refiners and the banks and traders who buy from them. One note on terminology: we found no single formal LBMA program called the “Gold Great Debate”. The label is best read as shorthand for the broader argument over how far traceability must go, and who carries the cost, so that is how it is treated here.

The illicit gold problem in 2026: the data behind the debate

The Global Initiative Against Transnational Organized Crime (GI-TOC) published a major assessment in June 2026. It concluded that Africa sits at the centre of a fast-evolving global gold economy where criminal groups, insurgents, foreign governments and international traders intersect, and that illicit gold is an “accelerant economy” feeding deforestation, mercury pollution, arms purchases and conflict financing.

The numbers coming out of individual countries are striking:

• Cameroon: officials stated that roughly 44 tonnes of gold left the country for Dubai between 2021 and 2025, while customs declared only 148 kg of exports. Separately, the mines ministry said in May 2026 that more than 200 companies were operating illegally in the East and Adamawa regions.
• Ghana: the Ghana Gold Board (GoldBod) bought about 3.1 million ounces from small-scale miners, against 2.8 million ounces produced by large-scale mining. Its CEO, Sammy Gyamfi, acknowledged in August 2026 that, without a formal traceability system, GoldBod cannot say what share of that gold was responsibly mined.
• Sahel: GI-TOC flagged major disruption to gold pricing and flows in West Africa and the Sahel in March 2026, alongside attacks on mining sites in Mali.

In April 2026, a coalition of 34 civil society organisations urged action ahead of the UK-hosted Illicit Finance Summit, calling for full traceability from mine to market and for a process to monitor and validate the procedures of international bullion centres. In November, finance and intelligence officials from 36 countries met in Kampala for the Africa Financial Intelligence Summit to discuss tracing, freezing and recovering illicit proceeds.

What LBMA compliance actually means

Two separate things are often confused, and the difference matters for every African gold business.

1. Good Delivery status. The LBMA Good Delivery List names the refiners whose bars are accepted by the wholesale London market without retesting. The Good Delivery Rules were last published in January 2026. Today, South Africa’s Rand Refinery is the only African refinery on the list.

2. Responsible sourcing. Every Good Delivery refiner must follow the LBMA’s Responsible Gold Guidance (RGG), which is built on the OECD Due Diligence Guidance and its Gold Supplement. Refiners are independently audited against it.

A refinery can reference LBMA prices and sell internationally without being on the Good Delivery List, but it will face extra verification from buyers. That is the practical cost of sitting outside the system.

RGG10: the compliance shift to watch

The LBMA opened its first public consultation on Responsible Gold Guidance version 10 (RGG10) on 10 June 2026, closing on 10 July, and has since run a second consultation on a revised draft. Final publication is scheduled for December 2026.

Based on the consultation materials and LBMA updates, the key points are:

• Secondary gold: a more risk-based due diligence approach, with “recycled gold” renamed secondary gold.
• Investment gold: recognised as a distinct material category with its own due diligence requirements, according to reporting on the draft.
• Folding in existing tools: the ASM toolkit, Disclosure Guidance (including monthly country-of-origin reporting to the LBMA) and assurance provider guidance become part of the core standard.
• EU alignment: the update aims to support alignment with European requirements.
• Timeline: conformance is expected from Good Delivery refiners from 1 January 2027, with implementation running through 2027 and first audits for the year ending 31 December 2027. Until RGG10 is published, RGG9 still governs.

Because the draft text can still change, refiners and their suppliers should treat these details as provisional until the final version appears.

Ghana as the test case

Ghana shows how hard it is to connect African supply to LBMA standards.

• Pricing: from 1 July 2026, GoldBod introduced a pricing regime based on LBMA pricing windows.
• Domestic refining: a directive issued on 24 August 2026 made refining at home compulsory for aggregators from 1 September, even though none of Ghana’s four licensed refineries holds Good Delivery status.
• Accreditation path: in February 2026, Rand Refinery agreed to mentor Gold Coast Refinery, a step LBMA chief executive Ruth Crowell publicly welcomed. GoldBod says it aims to secure LBMA accreditation for at least one local refinery by 2030.
• Traceability: Gyamfi said in August that a national traceability system would begin rollout this year.
• LBMA engagement: at the Sustainability and Responsible Sourcing Summit in June 2026, the LBMA and World Gold Council invited GoldBod to a roundtable of international bullion centres, and the LBMA pledged to work on traceability systems and ASM standards. Reporting notes these commitments are cooperative, not formal recognition. The LBMA also named Ghana, Côte d’Ivoire and Uganda as emerging African bullion centres it wants to bring closer to London.

The lesson: a licence, a supply contract, real throughput and Good Delivery accreditation are four different milestones. Policy can leapfrog capacity, so refinery readiness has to keep pace.

The core of the debate: how much traceability, and who pays?

Supporters of strict mine-level traceability argue that only verifiable origin data can separate legitimate ASM gold from criminal flows, and civil society wants bullion centres themselves held to account. Producers and refiners counter that heavy documentation can push small miners back toward informal buyers, and that many African refiners lack the finance, power and technical capacity to meet audit standards quickly. The LBMA’s own framing is that responsible ASM gold should be included in formal supply chains, not excluded from them, which is why its ASM toolkit and 2026 ASM report matter.

A practical compliance checklist for African gold businesses

1. Map your supply chain to mine or aggregator level, with documented origin for every lot.
2. Align with the OECD Due Diligence Guidance and its Gold Supplement, the baseline for RGG.
3. Prepare for country-of-origin disclosure, which the LBMA is formalising under its Disclosure Guidance.
4. Invest in digital traceability tools that produce audit-ready records.
5. Plan refinery upgrades for throughput, assaying, safety and environmental controls, since accreditation is as much an engineering and operations challenge as a paperwork one.
6. Engage assurance providers early, because audit methodology is also changing (assurance engagements move to the ISSA 5000 standard for reporting years beginning 2027).
7. Track RGG10’s final text in December 2026 and the 1 January 2027 conformance date.

Frequently asked questions

What is gold traceability? It is the ability to document gold’s journey from mine through trading and refining to the final bar or product, with verifiable records of origin and handling.

Does a refinery need Good Delivery status to export gold? No. But without it, buyers may apply additional verification, and the metal does not enter London’s Good Delivery framework directly.

Which African refinery is LBMA accredited? As of the latest reporting we found, South Africa’s Rand Refinery is the only African refinery on the Good Delivery List.

When does RGG10 apply? Final publication is planned for December 2026, with conformance for Good Delivery refiners from 1 January 2027.

Conclusion

In 2026 the question is no longer whether African gold will need to be traceable, but how quickly and at whose expense. RGG10, the LBMA’s engagement with emerging African bullion centres, and enforcement pressure after the year’s illicit-flow reports all point the same way. Producers and refiners who build traceability and audit readiness now will be better placed to reach premium markets. Those who wait risk being left with discounted, harder-to-sell metal.

Sources

• LBMA, Responsible Gold Guidance v10 consultation pages and Responsible Sourcing Newsletter (June 2026); LBMA GDL Newsletter (October 2026)
• GI-TOC, Commodity, currency, crime (June 2026), and bne IntelliNews coverage (11 June 2026)
• Greenpeace Africa, Cameroon gold press release (16 June 2026)
• The Sentry and Mighty Earth, civil society coalition statement (28 April 2026)
• MyJoyOnline, GoldBod traceability rollout (10 August 2026); GBC Ghana, LBMA Summit (18 June 2026); News Ghana (19 June 2026)
• Africa Intelligence / Rio Times, Ghana refining directive (31 August 2026); Ecofin Agency, West African refineries
• The Peninsula, Africa Financial Intelligence Summit (November 2026)