What the rules actually require, and what they do not.
National laws and market rules, international instruments and voluntary frameworks that reach gold, each status-tagged from the official record.
No law bans conflict gold globally. What exists is a patchwork: disclosure rules, import bans, market-entry rules and one treaty, each with a scope narrower than its reputation.
Status chips are computed from the official record: proposed, in consultation, agreed but not in force, in force, suspended or voluntary. Nothing is upgraded by press release.
Where a figure is self-reported or a claim is contested, the card says so and names both sides.
Mind the gap
What does NOT apply.
"Dodd-Frank banned conflict gold"It did not. Section 1502 is a US-listed-company DISCLOSURE rule; its due-diligence prong has sat under SEC no-action relief since April 2017, and a 2024 GAO finding says it has not reduced violence.
"The EU Conflict Minerals Regulation covers the gold chain"It covers IMPORTERS above volume thresholds only, has no harmonised penalties, and recognised its first due-diligence scheme (RMI RMAP) only in October 2025.
"The OECD Guidance is the law"The OECD Due Diligence Guidance is NOT law: it binds only where a regulator or market standard hard-wires it, as the EU CMR, LBMA RGG, the UAE rules and Türkiye do.
"You can look every bar up in the LBMA database"No: LBMA’s Gold Bar Integrity database is industry-confidential, not a public registry.
National & market rules
National laws and market rules.04
The binding layer closest to the trade: state monopsony in Ghana, due-diligence filings in the UAE, exchange gates in Türkiye, and a draft in India.
Ghana Gold Board Act 2025 (Act 1140)GoldBod
In force
Ghana· 2025
Adopted 2025-04-02: GoldBod is the sole buyer, assayer, exporter and regulator of ASM gold, with a licence registry online; a blockchain track-and-trace procurement was announced in November 2025 for end-2026.
For goldSelf-reported US$8.06bn of small-scale exports Jan-mid-Oct 2025 and over US$10bn full-year (per GoldBod, unaudited); independent criticism includes a GH¢9bn Bank of Ghana loss analysis (MyJoyOnline) and warnings that monopoly pricing invites smuggling.
Export figures are self-reported (per GoldBod, unaudited); the monopsony model is contested.
Version 1 dates from August 2022; Ministerial Decree 68/2024 extends OECD steps 1-3 to broader gold-chain entities, with annual third-party audits filed with the ministry.
For goldApplies OECD-style duties in the market where, per Swissaid (2024), 80-85% of undeclared African ASM gold lands; context: the UAE exited the FATF grey list in February 2024.
The EU regulations, the US disclosure rule, sanctions, the regional certification mechanism and the mercury treaty: what each one actually obliges, and on whom.
EU Conflict Minerals Regulation2017/821
In force
European Union· 2017 (applies 2021)
Mandatory OECD-aligned due diligence for EU importers of tin, tantalum, tungsten and gold, including doré, above volume thresholds; full application since 2021-01-01, first Article 17 review adopted 2024-09-24.
For goldRMI RMAP became the first recognised scheme on 2025-10-16. The Commission intends a "list of global responsible smelters and refiners", not yet published as of 2026-07-02.
Covers IMPORTERS above volume thresholds only, and has no harmonised penalties; its first scheme was recognised only in October 2025.
EU Corporate Sustainability Due Diligence Directive (post-Omnibus I)CSDDD
Agreed, phasing in
European Union· 2024, deal rev. 2025
The Council-Parliament deal of 2025-12-09 cut the scope to companies with 5,000+ employees and EUR 1.5bn turnover, with a tier-1 focus; first obligations are expected in July 2028.
For goldA horizontal duty that will reach the largest gold-using companies once it applies; agreed but not yet in force (P7).
US Dodd-Frank Act §1502 / SEC conflict minerals rule
In force
United States · SEC· 2010
A disclosure rule for US-listed companies on conflict minerals, gold included; the CY2025 Form SD was due 2026-06-01 and the rule is "largely unchanged since April 2017".
For goldIts due-diligence prong sits under SEC no-action relief since April 2017; a 2024 GAO finding says it has not reduced violence, and SEC Commissioner Uyeda was publicly critical in May 2025. A possible §13(p) national-security waiver has been discussed, none signed.
Does NOT ban conflict gold: it is a disclosure rule for US-listed companies, with its due-diligence prong under no-action relief since April 2017.
A ban on Russian-origin gold imports since 2022-06-28 (EO 14068, FAQ 1029), plus targeted designations of gold networks.
For goldPattni network designations 2024-12-09 (28 persons and entities, with the UK); Gasabo Gold Refinery (Rwanda) designated 2026-06-25 over M23-controlled DRC gold (at least 60 kg moved early 2026; precedent: Alain Goetz / African Gold Refinery, 2022).
Annex C National Action Plans are mandatory where artisanal and small-scale gold mining is more than insignificant.
For goldCOP-6 (Geneva, 2025-11-03/07) requested the Secretariat explore supply-chain transparency and certification to cut mercury use, and asked for a COP-7 report on NAP implementation.
Guidance and transparency layers that are not law, starting with the OECD baseline that everything else hard-wires.
OECD Due Diligence Guidance + Gold SupplementOECD DDG
Voluntary
OECD· 2016 (3rd ed.)
The five-step due-diligence framework for minerals from conflict-affected and high-risk areas, with a dedicated Gold Supplement; the global baseline. Stakeholder requests for an update are on record, none issued.
For goldThe baseline that regulators and market standards hard-wire: the EU CMR, LBMA RGG, UAE rules and Türkiye all build on it.
NOT law: it binds only where a regulator or market standard hard-wires it (EU CMR, LBMA RGG, UAE rules, Türkiye).
The baseline is voluntary; the binding layer is patchy.
The OECD Guidance binds only where a regulator or market standard hard-wires it. The EU has recognised exactly one scheme; the US rule is disclosure-only, with its due-diligence prong under no-action relief; the sharpest instruments in practice are sanctions.