Banks could face greater scrutiny over their exposure to illicit gold as international efforts to tackle financial crime increasingly focus on cross-border intelligence and fragmented data.
Recent analysis from Consilient, written by chief commercial officer Laurence Hamilton, examines the overlap between the Financial Action Task Force’s (FATF) 2026-2028 agenda and the United Nations Office on Drugs and Crime’s (UNODC) focus on illegal mining and mineral trafficking. The analysis argues that gold sourcing is increasingly becoming a financial crime and AML issue, rather than being treated solely as an ESG concern.
FATF’s latest agenda identifies cross-border data sharing as one of three priorities, alongside tackling fraud and strengthening risk-based supervision. The agenda was launched with an estimate that scams cost the global economy $1tn each year.
UNODC has taken a broader view of illegal mining and mineral trafficking. Under UN General Assembly Resolution 80/227, these crimes were brought before the General Assembly alongside offences involving timber, fisheries and waste. The issue was framed around security, justice and state authority.
The scale of the illicit gold market adds to the concern. An International Institute for Strategic Studies report estimates that illegal gold mining generates between $12bn and $48bn in proceeds annually. Gold prices have also increased by more than 182% over the past five years.
Tracing the commodity can be particularly difficult once gold enters the refining process. Illicit gold can be mixed with legitimately sourced material, making its physical origin harder to establish. However, the financial activity surrounding the commodity continues, with payments moving through banks and other financial institutions.
UNODC identifies five typologies associated with illicit gold trafficking: illegal extraction, origin mislabelling, false documentation, corruption and laundering through supply chains that appear legitimate. It has also identified links between illegal gold mining and organised crime, including drug trafficking organisations in Latin America and armed groups in parts of Africa.
These challenges can expose limitations in existing trade-based money laundering controls. Monitoring systems that concentrate on pricing, transaction volumes and invoices may not identify cases where the underlying commodity has already been made to appear legitimate before the financial transaction occurs.
Correspondent banking, trade finance and onboarding teams could therefore face particular exposure. Banks handling payments for refiners, exporters or commodity traders may need to assess whether the activity and documentation presented by a client align with its established trading history and supply chain.
The issue also highlights the importance of connecting information held by different institutions. Signals relating to gold extraction, documentation, trade and payments can be distributed across multiple organisations and jurisdictions, meaning individual institutions may only see part of the picture.
FATF’s focus on information sharing and public-private partnerships provides one response to that fragmentation. Consilient’s analysis similarly points to the value of enabling institutions to learn from signals held elsewhere, rather than simply accumulating more information within individual organisations.
As the two agendas continue to develop, gold sourcing could increasingly become relevant to AML, financial crime and trade finance functions alongside its existing ESG considerations.
Read the full Consilient analysis
Copyright © 2026 RegTech Analyst
Copyright © 2026 RegTech Analyst
