There is a paper trail for miners to prove the source of their gold
Dear Editor,
I refer to the online article captioned, `US keeping eye on gold smuggling from Venezuela –Kozak’ (Demerara Waves, October 19). On the whole the news item was where it should be, except for one sentence that was found troubling; indeed, alarming. I elaborate.
The sentence reads as follows, “Well- placed sources have told News- Talk Radio 103.1FM/ Demerara Waves Online News that there is no paper trail for gold miners to prove the source of the gold that they sell to the Guyana Gold Board or intend to export.” Let me say this most clearly: there is a paper trail required to “prove the source of gold” that is declared, sold, or exported through the Gold Board.
That paper trail - robust and detailed - has been implemented since during the time that I was part of the Gold Board. Also, that was put in place when I had just started in late March 2017, and in response to the fallouts from money laundering charges brought against a significant Gold Board customer, which imperiled the operations of this state entity. Further, that paper trail has been amended and enhanced on a continuing basis to reflect: 1) developments in the gold sector that posed risks to the Gold Board and Guyana; 2) measures that are embedded in universal risk assessment practices and that aligned with Enhanced Due Diligence procedures for the Guyana Gold Board specifically, and the gold sector in general (I should mention that the latter was determined to be medium to high risk); 3) guidance shared by both local and foreign regulatory entities, inclusive of national high-level risk assessment bodies, alongside intelligence gained from
CFATF recommendations on policies and procedures, and still others, which were then incorporated into the Gold Board procedures; and 4) an in-depth document trail from those declaring and exporting as to the source(s) of what they presented to the Gold Board.
Editor, I must mention that specific significant contributors to gold declarations at the Guyana Gold Board complained bitterly, protested vigorously, pushed back constantly, and escalated doggedly; they were both major and minor presences. I can attest here and now that the directorate of the Gold Board, during my 3-year tenure did not budge. Where there was latitude for discretion, and the required personal confidence present that nothing was breached or impeachable, that was
granted; when neither was present, then what was in place took immovable hold. Comers to the Gold Board had to comply with what was on the books, or business was not done, conversations were over. In fact, and for whatever it is worth, I should mention that it was made clear to those who formed part of the Gold Board’s oversight mechanism that they had to conduct their business to the letter, were held to the highest standard, and that there were going to be no exceptions. There was none, as the minutes and people themselves (from representative associations) can testify.
Given the escalations and pressures brought to bear during my time over regulations and processes and procedures, I would be shocked if the same, if not more, is not happening now with the new government in power. The president himself, in the runup to national elections made no bones about his determination to dismantle what he described as “onerous” regulations. I am unsure as to how much he has delivered on that commitment to the mining sector and at the Gold Board per se, but as all Guyanese know by now, there has been demolishing of people and regulations in other areas. I am confident that the General Manager, a highly principled professional and a stickler for protection of the agency and the country, would do what is right to the point of even refining further what was there when I left some eight months ago.
So, for it to be said that “there is no paper trail” as to the source of gold is highly inaccurate and found personally highly objectionable. There is, and that is part of what the history of the fierce pushbacks that characterized interactions with those who do business with the Gold Board, particularly the more powerful presences. As to how the current government will decide to do the business of the people at the Guyana Gold Board, that is its business. I wish its leaders the best and trust that they will do what is right for this country and not that which pleases its donors. Bottom line: there was and should be still in place a robust paper trail. Yours faithfully,
GHK Lall