In DMMA’s ongoing efforts to engage in continued dialogue with internal and external stakeholders, we’d like to share information (see below a link) Janice Ayala, DMMA Chief Compliance Officer presented during this year’s International Precious Metals Institute (IPMI) Winter Meeting (February 2026). The information centers on adapting your Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) compliance program to an AML/CFT & Supply Chain Due Diligence (SCDD) program and includes some of the following:
- Some of the similarities and differences, between programs, and their associated policies, and procedures that are required by regulation (domestic/international/state/county, etc. law) versus Responsible Sourcing Recommendations made by International Organizations/Associations or Markets.
- How DMMA worked with NPGM USA, Inc. (a DOWA group network company) to develop an enhanced comprehensive program that meets the Requirements of AML/CFT Law/Policies/Procedures, and also Organization for Economic Cooperation and Development (OECD) London Bullion Market Association (LBMA) and London Platinum & Palladium Market (LPPM) Responsible Sourcing Recommendations focused on SCDD.
- DMMA and NPGM USA roles, distinct differences and overlap in SCDD.
The presentation slides attempt to provide a side-by-side comparison of the Compliance/Responsible Sourcing Programs, that utilize their own distinct language generally, and in its articulation of audit, communication, framework, risk, and specific requirements, etc. At the end of the day, the language can at times be confusing and misinterpreted.
For those of you who don’t know much about LBMA/LPPM/OECD, or how any of this may apply to you, DMMA requires the completion of a LBMA/LPPM Onboarding Questionnaire as a starting point to establish a formal business relationship. The questionnaire contains questions related to those organizations and a link to the OECD website. Why it matters? Many of the smelters/refiners that touch your materials, at different stages throughout the Supply Chain, follow or take into consideration standards those organizations have set for the industry.
Whether you are designated as, or consider yourself a Precious Metal Dealer (PMD), Designated Non-Financial Business and Profession (DNFBF), Non-Banking Financial Institution, etc., or do not, the odds are you are subjectto AML/CFT domestic/international or laws/policies/regulations. Considering/incorporating:
- Financial Action Task Force (FATF) Best Practices
- Responsible Sourcing Recommendations by entities that utilize OECD Annex II guidance, primarily based on UN Human Rights Principles, Conflict Afflicted High Risk Areas (CAHRA) and Environmental and Social Corporate Governance (ESG).
As this will assist you in building an effective AML/CFT/SCDD program and at the same time, meet many of the requirements of Assurance Engagements, Good Delivery Certificates, and Independent Testing.
Should you have any questions, need further information, or have feedback (welcomed) on the presentation slides, please contact us.