Publication Summary

Gold remains a global safe haven asset; but behind its glitter lies a dark undercurrent of financial crime, corruption and exploitation. SovereignWealth Funds (SWFs), despite their scale and sophistication, face growing exposure to the illicit gold trade through indirect investments in mining companies, ETFs and commodity-backed instruments.

This exclusive Themis briefing note reveals how illicit gold operates asa financial crime convergence point, linking money laundering, organised crime, human trafficking and terrorism financing. It explores how these risks are often hidden in complex supply chains and layered financial products, exposing institutional investors to:

• Financial losses through stranded assets and devalued equities
• Reputational fallout tied to environmental destruction and human rights violations
• Legal liability, including sanctions breaches and non-compliance with AML or OECD standards

Written by Themis experts in financial crime and ESG, the note combines exclusive intelligence with step-by-step guidance for risk mitigation. It is designed to help SWFs and institutional investors navigate rising scrutiny from regulators, media and civil society; and position themselves ahead of emerging expectations.

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What’s Inside

This report examines:

• The mechanics of the illicit gold trade and how it infiltrates global markets.
• The intersection of financial crime, environmental crime and human rights abuses in gold supply chains.
• Case studies from Sudan, Venezuela and global gold hubs that show how illicit flows destabilise economies and threaten investor capital.
• The role of artisanal and small-scale gold mining in both legitimate livelihoods and illicit finance networks.
• Why gold is a leading vehicle for money laundering, sanctions evasion and terrorist financing.
• The risks posed to SWFs via ETFs, private equity, mining equities and opaque joint ventures.

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What You’ll Learn

• Clarity on hidden risks: How illicit gold flows move through supply chains and can expose even well-governed portfolios to criminal, reputational and ESG harm
• Due diligence strategies: Practical steps for identifying red flags, including shell companies, supply chain anomalies and exposure to high-risk jurisdictions
• Risk mitigation frameworks: Tools to enhance traceability, UBO transparency and compliance across gold-related investments
• Best practice insights: How to implement OECD-aligned due diligence and strengthen AML/CFT controls
• Strategic foresight: Why illicit gold is not just a financial crime risk, but a systemic threat to environmental sustainability, human rights and long-term licence to operate

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Who Is This For?

This report is designed for:

• ‍Sovereign wealth funds & institutional investors managing long-term national capital.‍
• Risk & compliance teams seeking frameworks to address exposure to illicit resource trade.‍
• Policy makers & regulators monitoring the convergence of financial crime, environmental crime and human rights abuses.‍
• ESG and responsible investment leaders working to align capital deployment with ethical and sustainable practices.‍
• Financial crime & AML professionals tracking high-risk commodities and sanction evasion risks.

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