Conflict-Free Gold from DRC — OECD Due Diligence Explained

For any international refinery, institutional buyer, or compliance-conscious investor, the question is unavoidable: is this gold conflict-free? The Democratic Republic of Congo has a complex history with mineral wealth and armed groups — and any serious buyer of DRC gold must understand how responsible sourcing works in practice.

The good news: a robust, internationally recognised framework exists. The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas sets out a clear 5-step process that legitimate operators follow. This guide explains that framework, how it applies to DRC gold specifically, and what documentation buyers should expect.

Why "Conflict-Free" Matters for DRC Gold

Eastern DRC has experienced significant armed conflict, and various non-state armed groups have historically taxed or controlled artisanal mining sites. This created the "conflict minerals" problem — where mineral revenue funds violence. International regulations emerged in response:

• US Dodd-Frank Act Section 1502 — requires US-listed companies to disclose use of conflict minerals (3TG: tin, tantalum, tungsten, and gold) from DRC and adjoining countries
• EU Conflict Minerals Regulation (2021) — mandatory due diligence for EU importers of 3TG minerals
• OECD Due Diligence Guidance — the global standard for responsible sourcing, adopted by major refineries and the LBMA (London Bullion Market Association)
• LBMA Responsible Gold Guidance — all LBMA-accredited refineries must conduct OECD-aligned due diligence

These regulations mean that if your refinery is LBMA-accredited or EU/US-regulated, they must have conflict-free sourcing documentation for DRC gold. Buying through a non-compliant broker creates legal and reputational risk downstream.

The OECD 5-Step Due Diligence Framework

The OECD's guidance is the backbone of responsible gold sourcing from conflict-affected regions. Here is how each step applies to DRC gold:

What "Conflict-Free" Documentation Looks Like

When you buy DRC gold through a compliant broker, you should receive a documentation package that includes:

• Mine-of-origin declaration — identifying the specific province, cooperative, or mining site
• Chain-of-custody record — documenting each handoff from miner to exporter
• OECD risk assessment — confirming no red flags were identified at the sourcing level
• DRC export permit — government-issued permit from the Ministère des Mines
• Assay certificate — third-party purity and weight confirmation
• Supplier KYC documents — identity verification of the selling party

Which DRC Provinces Are Lower Risk?

Not all of DRC's gold-producing regions carry the same risk profile. The OECD and industry bodies assess risk at a granular level:

• Ituri Province — historically lower conflict risk in mining areas; significant formal cooperative presence
• North Kivu — higher historical risk; buyers should require specific mine-site documentation and cooperative certification
• Maniema Province — generally lower risk; more remote, less conflict exposure

Congo Gold Connect sources primarily from Ituri and Maniema, where supply chain traceability is more reliable. For North Kivu sourcing, we apply enhanced due diligence.

The iTSCi and Better Gold Initiative

Several industry programmes specifically support conflict-free sourcing from DRC:

• iTSCi (ITRI Tin Supply Chain Initiative) — a bag-and-tag traceability system used across DRC and Rwanda to track minerals from mine site to export. Some of our supplier cooperatives participate in iTSCi.
• Better Gold Initiative (BGI) — Swiss-backed programme supporting formalisation of artisanal gold mining in DRC and other African countries
• CRAFT (Code of Risk-mitigation for ASM engaging in Formal Trade) — a due diligence standard designed specifically for artisanal and small-scale miners in conflict-affected areas

What This Means for Buyers in Practice

For refineries and institutional buyers, the key takeaway is straightforward: DRC gold can be sourced compliantly, but only through brokers who have invested in the documentation and supply chain infrastructure to support it.

Buying from unverified sellers, Facebook groups, or brokers who cannot provide mine-of-origin documentation creates regulatory exposure and reputational risk — regardless of price. The compliance documentation is not optional for serious buyers; it's the cost of access to the market.