Export Compliance Policy
World Gold Diamonds adheres to all applicable export control regulations, sanctions regimes and customs requirements governing the international shipment of gold, diamonds and precious minerals.
Effective Date: January 2024 | Last Reviewed: August 2026Purpose & Scope
This Export Compliance Policy establishes the controls and procedures applied by World Gold Diamonds to ensure that all international exports of gold, diamonds and associated minerals comply with applicable export control legislation, customs regulations, sanctions regimes and commodity-specific international standards.
The policy applies to all shipments originating from or transiting through any jurisdiction in which the Company operates, to all personnel involved in arranging, processing or executing export transactions, and to all freight agents, customs brokers and logistics partners acting on behalf of the Company.
Regulatory Framework
- Republic of Mali Mining Code and Export Regulations (Loi No. 2019-013)
- ECOWAS Trade Liberalisation Scheme and regional customs protocols
- United Nations Security Council commodity sanctions and arms embargo provisions
- OFAC Regulations — Export Administration Regulations (EAR) where applicable
- EU Dual-Use Regulation and mineral-specific export controls
- LBMA Responsible Gold Guidance for gold export documentation
- Kimberley Process Certification Scheme for rough diamond exports
- WCO Harmonised System classifications for precious metals and stones
- IATA Dangerous Goods Regulations (where applicable to air freight)
Export Licensing
No export will proceed without all required licences, permits and authorisations being in place prior to shipment. For gold and diamond exports from Mali, this includes:
- Valid mining licence or purchasing permit issued by the Malian Ministry of Mines
- Export permit issued by the Direction Nationale de la Géologie et des Mines (DNGM)
- Kimberley Process Certificate of Origin for all rough diamond shipments
- Certificate of Origin for all gold and mineral exports
- Phytosanitary or other commodity-specific certificates where required by the destination country
The Company maintains a register of all export licences, their validity periods and renewal dates. Expired or suspended licences will result in immediate suspension of all affected export activities.
Export Documentation
Every export consignment is accompanied by a complete documentation package. Standard documentation includes:
- Commercial Invoice — accurately describing the goods, quantity, purity, unit value and total declared value
- Packing List — detailing the number, weight and description of each package
- Certificate of Origin — confirming the mineral's country of extraction
- Certificate of Analysis (Assay Report) — confirming purity and composition from an independent laboratory
- Export Permit — issued by the relevant national authority
- Bill of Lading or Airway Bill — issued by the carrier
- Insurance Certificate — confirming cargo insurance coverage
- LBMA Weight Note (gold) or Kimberley Process Certificate (diamonds)
Sanctions & Restricted Parties
The Company operates a zero-tolerance policy for export transactions involving sanctioned persons, entities or jurisdictions. Pre-shipment screening is conducted against the UN, OFAC, EU and UK consolidated sanctions lists for all buyers, agents, carriers, freight forwarders and financial institutions involved in the transaction.
Exports to the following are permanently prohibited without exception: countries subject to comprehensive UN arms embargoes; jurisdictions subject to full OFAC or EU sectoral sanctions affecting precious metals; and any entity appearing on the UN Security Council Consolidated List.
Customs Compliance
All exports are declared to customs authorities in the country of export, in accordance with the applicable Harmonised System (HS) tariff classifications. Declarations are made by qualified customs brokers appointed and supervised by the Company. The Company does not engage in or condone any form of customs fraud, mis-declaration or under-valuation of exported goods.
Shipping & Logistics Controls
All precious metal and gemstone shipments are transported by approved carriers with specialised precious cargo handling capabilities. Logistics controls include:
- Use of tamper-evident, sealed packaging with unique reference numbers
- Mandatory cargo insurance at full replacement value for all shipments
- Chain-of-custody documentation maintained from point of sealing to point of receipt
- Armed escort or secure courier as required by the value and risk profile of the shipment
- Real-time shipment tracking and milestone notifications to the buyer
- Notification to the Company's compliance officer of any diversion, delay or incident during transit
Gold Export Standards
Gold exports must be accompanied by an independent assay certificate from an accredited laboratory confirming purity. The LBMA weight note format is used where the consignment is destined for an LBMA-accredited refinery or vault. All gold is exported in its declared form — doré bar, dust or nugget — and reclassification during transit is prohibited.
Diamond Export Standards
All rough diamond exports are accompanied by a valid Kimberley Process Certificate of Origin issued by the competent authority of the country of origin. The certificate must accompany the shipment throughout its transit and be presented to the importing authority upon arrival. Diamonds may only be traded to KP participant countries in good standing. Split shipments, consignments with broken KP seals or diamonds without full chain-of-custody documentation will not be accepted.
Violations & Reporting
Any actual or suspected violation of this policy — including discovery of a sanctions match, documentation discrepancy, attempted fraud or regulatory breach — must be reported immediately to the Compliance Officer. The Company will cooperate fully with all regulatory and law enforcement investigations. Employees who knowingly participate in export compliance violations face immediate dismissal and potential criminal referral.
Policy Review
This policy is reviewed annually. For export compliance and documentation queries: info@worldgolddiamonds.com