Yansura is the Program Director for Environmental Crime and Illicit Finance at the FACT Coalition in Washington, DC., where her work focuses on illegal gold. Taylor is the Deputy Director of Spotlight on Corruption in London, where she leads the charity’s programme on ending impunity for corruption.
Ahead of International Anti-Corruption Day on December 9th, the UK’s Foreign Secretary Yvette Cooper unveiled plans for the upcoming Illicit Finance Summit to be hosted by the UK on 23-24 June 2026. Bringing together leaders from a broad coalition of countries, the summit will prioritise collective action on three key themes: real estate, crypto, and gold.
These three high-risk asset classes pose critical illicit finance threats that operate across borders and can only be effectively tackled through international cooperation. The Summit provides a significant opportunity for countries to better understand these threats, commit to meaningful policy reforms, and forge partnerships for sustained international cooperation on concrete actions.
Why gold?
The UK government conservatively estimates that the global illicit gold market is worth at least $80 billion (UK£60 billion) annually. Some experts believe that it may be even higher. Researchers from SwissAid told us that they estimate at least 900 tons of illicit gold enter the market each year, including 300 tons of Russian conflict gold, amounting to $117 billion (UK£87 billion).
Gold is difficult to trace, easy to transport, and subject to much less stringent anti-money laundering and counter-terrorism financing safeguards when compared to other assets such as cash or banked funds. The price of gold has increased by over 50 percent this year, reaching record highs and attracting the attention of both legitimate investors as well as criminal networks.
Local challenges, global impacts
One of the challenges that the summit may face is that illicit gold poses very different threats to different regions of the world. In the UK, gold is often used to launder the proceeds of crime. Earlier this year, for example, UK prosecutors convicted four individuals in a £200 million gold case considered to be one of the largest money laundering prosecutions ever brought to the courts in England and Wales. Another primary concern for the UK and other European nations is Russia’s ability to evade sanctions programs through gold-for-cash trades that enable access to Western currency.
Meanwhile, in the African continent, concerns over gold are more often linked to issues with illegal mining, poverty, and environmental degradation through the use of mercury, one of the most toxic substances on earth. Many countries in the Western Hemisphere share these problems. Yet in the Americas, the most violent region on earth, there are also very acute concerns with how illegal gold fuels violence, armed conflict and organized crime.
As part of the UK government’s global leadership on this issue, it should consider aspects of the illegal gold trade that may not be as visible in the UK domestically, but nonetheless have profound global impacts.
Opportunities for action
- Close down opportunities for airline smuggling
Faced with such a complex issue, one simple yet meaningful reform that the UK should promote at the Summit is requiring international travelers to declare gold the same way that they do cash. Dirty gold can be transported via international trade, smugglers, or even private aircraft, but many would be surprised to learn that one of the most common methods is to simply send gold with passengers on commercial aircraft. Many countries, including the US and the UK, do not require the same level of declaration for gold as they do for cash, opening up a loophole that international gold traffickers have exploited.
- Disrupt transnational networks through an international gold task force
At a more operational level, the UK should use the Summit to improve information-sharing and reduce barriers to international law enforcement cooperation around gold. The UK should consider creating an international taskforce to address illegal gold, with participation from international partners including countries in Africa and Latin America that are directly impacted by illegal mining. Law enforcement often struggles to address the transnational aspects of illegal gold mining, gold trafficking, and gold-based money laundering, even when they see clear international linkages in a criminal case – sometimes simply because they can’t be sure which international counterpart to reach out to.
- Expose the real corporate owners involved in the illicit gold trade
To uncover the individuals driving and benefitting from illegal gold, the UK should raise the very real issue of shell and front companies in relation to illicit finance and gold. Research by FACT on illegal gold mining has shown that anonymous companies are the single most prevalent vehicle used to move illegal gold – and to launder the proceeds.
The policy solution to this pervasive problem, well established by the Financial Action Task Force (FATF) and other international standards-setting bodies, is to require companies to declare their real, or “beneficial” owners. Despite technical consensus about what should be done, progress has been slow, especially in the British Overseas Territories where major secrecy havens like the British Virgin Islands have dragged their feet on implementing long-promised transparency reforms.
Many UK allies have also faced setbacks. In the EU, “legitimate interest” access requirements are being used to deny access by journalists and civil society watchdogs to vitally important company information. Meanwhile in the U.S., the Treasury Department recently announced that it will not implement a beneficial ownership law passed by the U.S. Congress.
This is a challenging moment for corporate transparency globally, and UK leadership is needed. But the UK’s credibility in championing best practice hinges on taking concrete action at home and ensuring the Overseas Territories and Crown Dependencies implement open corporate registers that are vital for tackling the flow of dirty gold.
The UK should use the Summit to raise the importance of beneficial ownership and discuss methods for international data exchange (since not all countries have public registries). This is vital not only to addressing illicit gold, but to combatting illicit finance and transnational organized crime more broadly.
- Mobilise the private sector to help prevent and detect illicit gold flows
In 2015, the FATF published guidance on the risks and vulnerabilities associated with gold that make it an attractive vehicle for money laundering and terrorist financing. Yet despite the staggering scale of illicit flows from gold, the global anti-money laundering watchdog has not updated this guidance for over ten years or made gold a priority on its agenda. As a result, the evolving risks and current red flags for illicit gold may be easily missed by financial institutions and other professionals doing due diligence on clients and transactions in this area.
With the UK currently holding the Vice-Presidency of the FATF (and facing its own Mutual Evaluation Review in 2027), the summit offers a crucial opportunity to raise the profile of gold as an illicit finance threat. Through its leadership at the FATF, the UK should urge member countries to prioritise and resource targeted work to update the 2015 thematic review on gold and develop a framework for assessing the compliance and effectiveness of international hubs against key performance indicators. This should give particular attention to the vulnerabilities in relation to dealers of precious metals and stones as well as the role of refiners and international trading hubs, setting out red flag indicators to improve due diligence on supply chains.
But private sector actors have an important role to play beyond doing proper due diligence to ensure they don’t enable illicit gold flows. They hold valuable information which can help regulators and law enforcement agencies disrupt illicit gold networks. The summit is a valuable opportunity for governments to work with industry stakeholders to establish gateways (such as the UK’s Joint Money Laundering Intelligence Taskforce) for sharing information about malign actors and organised crime groups, gold-smuggling patterns and hotspots, and emerging risk areas. These mechanisms should allow for the sharing and analysis of real-time intelligence and information that could help prevent and detect illicit flows from gold, as well as provide an evidence base for government and industry to develop joint risk assessments.
- Refine proposals for centralized gold processing plants
The Illicit Finance Summit will also need to grapple with other policy suggestions, including from the gold sector itself. The World Gold Council has advocated for centralized gold processing plants, majority owned and controlled by governments, which would purchase gold directly from artisanal miners, process the gold using cyanide, and sell to international markets.
Among the benefits of this plan are the elimination of middle men – often associated with organized crime and human rights abuses in mining regions – and the transition from the current indiscriminate use of mercury to the more controlled use of cyanide. Among its potential challenges are significant requirements for institutional capacity, technical expertise, and capital – “a tall order in many of the 80 countries where artisanal and small-scale gold mining thrives, particularly in sub-Saharan Africa, Southeast Asia and Latin America,” notes Robert Muggah of the Igarapé Institute. From an illicit finance perspective, there are also risks of corruption that must be considered when significantly expanding government control over a tremendously valuable, difficult to trace asset.
Finally, it is worth noting that this type of program would not address the illicit finance risks associated with gold from non-cooperative jurisdictions, such as Russia and Venezuela. As long as Russia, Venezuela and similar countries are producing conflict gold, stronger illicit finance measures are needed. The UK government should evaluate the gold sector’s proposals with clear eyes, noting what these reforms seek to address – and what they do not.
Global leadership on gold
London plays a central role in the global gold trade, being home to the largest over-the-counter gold bullion market and the headquarters of both the London Bullion Market Association (LBMA) and the World Gold Council. This means that the UK is well placed to provide global leadership on issues of illicit gold flows.
As the UK brings world leaders together in London for the Summit, it has a unique opportunity to elevate the issues of illicit finance and the gold trade on the global stage – and to champion meaningful reforms. And with analysts warning that the price of gold could reach US$10,000 an ounce in the next three years, the stakes could not be higher.