Criminal syndicates have embedded themselves so deeply in the global gold supply chain that the regulatory frameworks designed to contain them are fundamentally inadequate, according to a new report by the Global Initiative Against Transnational Organized Crime (GI-TOC).

The report, “Commodity, Currency, Crime: How Illicit Gold Markets Are Outpacing Global Responses,” describes illicit gold as among the most consequential criminal markets globally. The think tank argues that the prevailing regulatory framework has failed to capture the full scope of the threat, which now extends across financial markets, international bullion centers, and commodity trading desks in jurisdictions long considered low-risk.

The problem has been accelerated by the dramatic rise in gold prices since 2023, with criminals increasingly controlling complete supply chains rather than exploiting isolated weaknesses, according to the report. 

In 2025, gold worth an average of $361 billion was traded daily through international bullion centers (IBCs)—including the UK, UAE, Switzerland, and China—with limited transparency and oversight, the report says. Because IBCs lack adequate oversight relative to their systemic importance, they remain one of the sector’s most significant blind spots, GI-TOC said. 

The financial sector’s exposure is also a central concern, the think tank said. A 2026 study cited by the report found that nearly 40 percent of financial institutions surveyed do not assess illegal mining risks as part of their due diligence processes. Bullion banks routinely treat supply chain due diligence as a reputational afterthought rather than a compliance obligation, relying instead on industry certifications the report describes as structurally compromised. 

The London Bullion Market Association (LBMA), whose Responsible Gold Guidance is widely regarded as the sector’s standard, explicitly does not guarantee that illicit gold is absent from supply chains it certifies, and a case currently before the UK courts challenges whether the LBMA breached its duty of care by certifying gold from a Tanzanian mine despite documented human rights abuses, according to the study. 

The misuse of scrap and recycled gold categories is a persistent laundering pathway. “You can call anything scrap gold,” a trade expert told GI-TOC researchers. Once relabeled, gold can move through closed-loop refining systems with minimal provenance checks, allowing illicit material to enter formal markets with a new chain of custody.

GI-TOC researchers separately found the stablecoin Tether (USDT) being used to pay for Guyanese gold smuggled to Venezuela through decentralized wallets, with proceeds converted into local currency through Chinese trading networks operating in Guyana. 

The think tank called for mandatory and internationally binding due diligence standards that cover the full gold supply chain, including IBCs and financial markets. It also urged the Financial Action Task Force to update its 2015 thematic review on gold to reflect current threats and to formally recognize gold as a monetary instrument, rather than treating it solely as a commodity under existing regulatory guidance.