CITY OF GOLD - Global Witness
global witnessFebruary 2014global witnessCITY OF GOLDWhy Dubai’s first conflict gold auditnever saw the light of day
City of Gold February 2014CONTENTSINTRODUCTION2what is conflict gold and how canit be stopped?4major compliance failures by kaloti5The dmcc: regulating tradeor promoting business?8ernst & young’s role10conclusion12recommendations13endnotes14Front cover photo: A soldier from the Congolese Rebel Army FPC watches artisanal miners on their way to work at the Musia Gold Mine.Credit: Panos/James Oatway1
2City of Gold February 2014IntroductionThe global accountancy firm Ernst & Young turned ablind eye when the Dubai metals regulator changed itsguidelines during the course of an audit at the MiddleEast’s largest gold refinery, according to a formerErnst & Young partner, with the result that a reportof serious failures at the refinery went unpublished.The unreported audit findings pointed to anincreased risk of money laundering and of dirtygold from the Democratic Republic of Congo andother conflict zones entering the refiner’s supplychain during 2012.The matter has come to light thanks to Amjad Rihan,the partner at Ernst & Young Dubai who was in chargeof the audit of Kaloti Jewellery International.1 Ouranalysis is largely based on detailed documentationshown to Global Witness by Mr Rihan.The documents suggest that the regulator, the DubaiMulti Commodities Centre (DMCC) altered its auditguidelines after becoming aware of the negativefindings in Ernst & Young’s report. The changesenabled Kaloti to keep the results confidential.According to Mr Rihan, the Ernst & Young GlobalExecutive body was aware that critical audit findingswere sidelined following the DMCC’s changes to theguidelines. Mr Rihan maintains that the firm turned ablind eye, despite his repeated requests that the findingsbe reported to relevant stakeholders, with the effectthat damaging results were swept under the carpet.Following Ernst & Young’s failure to disassociatethe firm from the DMCC’s actions, and its decisionto agree a new audit engagement with Kaloti, MrRihan refused to sign the audit report and steppedaway from the project.The refiner was being reviewed against supply chaindue diligence guidance developed by the DMCC, basedon standards set by the Organisation for EconomicCooperation and Development (OECD) and the UnitedNations to prevent gold revenues from funding conflictand human rights violations in Congo and elsewhere.In 2012, the DMCC made it a condition of membershipfor Dubai Good Delivery refiners to do due diligenceon their activities and suppliers. The audit carried outby Ernst & Young was part of a first round of reviewscommissioned by Dubai-based refiners to assess theirimplementation of the DMCC guidance.The leaked audit report prepared by Mr Rihan’s teamreveals that the refiner: Failed to report suspicious cash transactionsworth in total over US 5.2 billion in 2012; Knowingly accepted up to four tonnes of goldcoated with silver exported from Morocco bysuppliers who had used falsified paperwork; and Lacked adequate supply chain information onseveral tonnes of high-risk gold from Sudan.The implications of compliance failures in Dubai’s goldmarket are serious. Dubai is home to over 20 percentof the world’s physical gold trade – worth close toUS 70 billion in 2012.2 The United Nations and GlobalWitness have repeatedly exposed the emirate as a keydestination for gold that funds abusive warring partiesin eastern Congo. The Dubai regulator has a particularresponsibility to ensure that its member companies areThree reports are generatedas part of the audit process1 Ernst & Young prepares a confidentialmanagement report for the client andregulator, including a detailed account of therefiner’s implementation of due diligence.2 The refiner writes a public-facingcompliance report, which should intheory mirror the findings in themanagement report.3 After reviewing the compliance report, Ernst& Young issues a public-facing assurancereport, in which they either agree ordisagree with the refiner’s report and whichincludes a final overall compliance rating.
City of Gold February 2014doing business responsibly. Kaloti alone refines45 percent of the gold processed in Dubai.3A compliance report published by Kaloti in November2013, based on a follow-up review also carriedout by Ernst & Young under the DMCC’s revisedguidelines, indicates that the refiner had takensteps to address the failures identified in its 2012operations. However, the report makes little referenceto the gravity of the initial non-compliance.The apparent cover-up by the DMCC calls intoquestion Dubai’s commitment to ethical commoditytrading and suggests a conflict of interest in theDMCC’s dual role as government regulator andtrade promotion body. Ernst & Young’s willingnessto toe the line was critical to the DMCC ultimatelysecuring clean audit results for a key Dubai refiner.The decisions made by the global leadership in thiscase, which appear to contradict the firm’s ownethical standards and undermine its credibility asan objective third party, warrant further scrutiny.Although the actions of the DMCC and Ernst & Youngwere lawful, any suppression of reports of serious noncompliance hampers efforts to clean up a trade thatfuels brutal conflicts and human rights abuses aroundthe world. Public disclosure is a key incentive toimproving business practice. Nondisclosure of the typeof failures found by the initial audit could misleadthose buying gold, including banks, manufacturers andhigh street jewellers, and could even expose US-basedcustomers to sanctions under a new law designed tocurb the trade in conflict gold.Global Witness wrote separately to Kaloti JewelleryInternational, the DMCC and Ernst & Young to seekcomment on the events described in this report.Their responses are summarised below. Kaloti denied any allegation of non-compliancein its gold business and emphasised that it hadnever been found by Ernst & Young to be sourcingfrom conflict zones, although the same letteracknowledged non-compliance in the initial stagesof a ‘long multi-staged audit process’. Kaloti said thatall disclosure was done in accordance with DMCCrequirements and industry best practice, and thatthe company adhered to all audit requirements. The DMCC rejected any suggestion of a cover-upor improper action. The DMCC denied that itsactions risked misleading purchasers of gold orother stakeholders, or in any way underminedefforts to enhance effective regulation of thegold trade or to suppress adverse audit findings.The DMCC said that all of its processes areconsistent with international best practice, andthat revisions of its guidelines were efforts toconform to international standards. Ernst & Young denied turning a blind eye to thesuppression of audit results and said that thefindings of non-compliance were fully reportedto the client and to the DMCC, whose regulatorystandards it independently applied at all times.The firm refuted any claim that Ernst & YoungDubai acted in a manner not compliant with theErnst & Young Code of Conduct.2013: Timeline of events relating to Dubai gold audits23 July5 June5 JulyMr Rihan firstraises concernsabout the projectwith EY GlobalFebruaryApril26 FebruaryEY signs agreementwith Kaloti to carryout audit againstDMCC and LBMA duediligence standards,covering 2012JuneMr Rihan informsEY Global ofDMCC actionsand his concernsJuly3 JuneMr Rihan receives emailfrom EY saying thatmembers of the GlobalExecutive have takenthe lead and engagedexternal legal advisors17 September21 AugustEY appointsanother auditpartner to replaceMr Rihan on projectAugustSeptember15-19 JulyEY meets DMCCto discuss draftaudit findingsDMCC publishes changesto audit review protocolOctober8 SeptemberMr Rihan meets membersof EY Global in Europe todiscuss case27 JuneEY commences planningfor Kaloti’s follow-upaudit, covering 4 Augustto 4 October 201312 AugustMr Rihan steps awayfrom the projectEY submits finalmanagement reportfor first audit toKaloti and DMCC27 NovemberKaloti publishescompliance andassurance reportsfor follow-up auditNovember3 OctoberEY starts to carryout Kaloti’sfollow-up audit19 NovemberDMCC posts new,undated version ofaudit reviewprotocol on website3
4City of Gold February 2014What is conflict gold andhow can it be stopped?In eastern Democratic Republic of Congo (DRC),foreign and Congolese armed groups and membersof the Congolese army have made millions of dollarsthrough illegal control of the minerals trade in aconflict that has lasted for almost fifteen years. Inrecent years, gold has played a more prominent rolein fuelling conflict in eastern DRC. This is largelydue to a steady reduction in other major sourcesof revenue for armed groups – tin, tungsten andtantalum – following reforms spurred by the USDodd Frank Act’s conflict minerals provision.A recent mapping of tin, tantalum, tungsten and goldmining areas in eastern DRC shows that armed actorsillegally tax the trade in more than half the sites.4Because gold mines are numerous and often remote,and gold is easy to conceal and smuggle, DRC’s goldsector has been largely unaffected by reforms.Global Witness investigations in November 2013showed that Dubai is the main destination forCongolese gold laundered through Burundi. OverIndustry cross-recognitionThe outcome of Dubai conflict gold auditsmay have far-reaching implications. US-listedcompanies required to comply with the DoddFrank legislation are seeking out responsibletrading partners and rely on industrycertification schemes like the ResponsibleJewellery Council (RJC) to support their duediligence efforts. In October 2013, the RJCsigned a cross-recognition agreement withthe DMCC. This means that RJC members –including companies like Tiffany & Co, Cartier,Signet and JC Penney – can automaticallymarket gold sourced from DMCC accreditedrefiners as conflict-free.5 The ElectronicsIndustry Citizenship Coalition (EICC), anindustry association that initiated an auditingprogramme for smelters and refiners, is alsodiscussing cross-recognition with the DMCC.70% of the gold exported from Burundi comes fromthe southern part of eastern DRC, where the majorityof gold-mining areas are controlled by notoriouslyabusive rebels.6 Gold that funds armed groups in thenorthern part of eastern DRC transits via Uganda,and much of this makes its way to Dubai as well.7Sudan’s Darfur province has also recently witnessedoutbreaks of conflict between rival militia over thecontrol of artisanal gold mines. Fighting over theJebel Amer gold mine has reportedly killed over 800people and displaced up to 150,000 others sinceJanuary 2013.8 One report stated that Dubai is oftenthe final destination for Darfur’s gold.9Ensuring that major refiners operating in Dubai arebuying clean metal is an essential part of curbing thetrade in dirty gold. Much of the debate around howcompanies can avoid trading in conflict minerals hascentred on due diligence. By checking their supplychains and dealing with risks that arise – in otherwords, doing due diligence – companies can ensurethat they are not contributing to conflict or humanrights violations through their purchases.The Dodd Frank Act, passed by the US Congressin July 2010, requires US-listed companiesusing minerals, including gold, from DRC andneighbouring countries to show that they havedone due diligence on their supply chains.10Guidance developed by the UN Security Counciland the Organisation for Economic Cooperationand Development (OECD), published just a fewmonths after the US law, spells out for companieswhat this due diligence on mineral supply chainsshould consist of.11The DMCC’s Practical Guidance for MarketParticipants in the Gold and Precious MetalsIndustry, which Kaloti was being audited against,is based on the OECD Due Diligence Guidance.12Both the DMCC and OECD guidance includeprovisions for company management systems, riskassessment and mitigation, independent audits andpublic disclosure.
City of Gold February 2014Major compliancefailures by KalotiThe failures outlined in the leaked Ernst & Youngmanagement report suggest that during the reviewperiod Dubai’s largest gold refiner, Kaloti, did nothave sufficient controls in place to ensure thatconflict gold was kept out of its supply chain or toprevent suspicious transactions.13 The audit, carriedout by an Ernst & Young Dubai team and coveringKaloti’s 2012 operations, was commissioned by therefiner as part of its application of the DMCC’s duediligence guidance.14 The purpose of the auditor’smanagement report is to privately inform the refinerand the regulator of compliance risks.Kaloti is the largest gold processor in the MiddleEast with the capacity to refine 450 tonnes of goldper year, reportedly set to increase to nearly 1,400tonnes when a new factory is completed in Dubaiin 2015.15 With the expansion Kaloti will becomeone of the biggest gold refiners in the world.While implementation of the DMCC’s duediligence guidance is not a legal requirement, itis mandatory for refiners who want to be on theDMCC’s Dubai Good Delivery List.16 ‘Good Delivery’,set by individual gold exchanges, specifies thephysical characteristics of gold bars and acts as abenchmark of quality for buyers. According to theErnst & Young engagement letter, Kaloti requestedto be audited against the London Bullion MarketAssociation’s (LBMA) Responsible Gold Standard,as well as the DMCC’s guidance.17 The LBMA isa London-based international trade associationregulating the London Good Delivery List for gold.Kaloti is an Associate Member of the LBMA anda successful audit would represent a step towardsfull membership and a spot on the much soughtafter London Good Delivery List.18Suspicious cash transactionsAccording to the management report prepared byErnst & Young for Kaloti, nearly 45% of the refiner’stransactions in 2012 by value, worth over US 5.2billion, were cash transactions.19 Several deals wereworth over US 3 million each.20The report also indicates that 1065 cash transactions,amounting to 2.4 tonnes of gold and worth overUS 100 million, were carried out withoutconducting proper due diligence on the suppliers.21Other cash deals involved purchasing hand-carriedgold from high-risk suppliers from Sudan and buyinggold coated with silver from Morocco.22These types of transactions raise risks related both tomoney-laundering and conflict financing and shouldhave triggered additional checks by the refiner. Themanagement report states that the refiner did notassess risk in proportion to the increasing value ofcash transactions. There is no indication in the reportthat Kaloti reported any of its 2012 cash transactionsto the regulator in Dubai.23Dubai and Money LaunderingDubai has emerged as a hub for moneylaundering. For example, a significantportion of the US 935 million looted fromAfghanistan’s Kabul Bank ended up in Dubai.The amount stolen from the bank amountedto approximately 6% of Afghanistan’s GDP.24In another case, some of the money allegedlystolen by Russian officials in a major scandalthat led to the death of the lawyer who hadbeen investigating the theft is thought to besitting in Dubai.25 The US State Departmenthas explicitly pointed to the gold anddiamond trade as being areas in which theUAE is vulnerable to money laundering.26Cash transactions can be linked to money-launderingbecause, unlike bank transfers, they generally requirefar less information about the people involved andwhere the money is being sent. Cash transactionsabove a certain value present a greater risk, whichis why the DMCC’s Anti Money-Laundering Policyrequires member refiners to report suspicioustransactions above AED 40,000 (US 11,000).27 Thisis in line with standards set by the international5
City of Gold February 2014 Mohamed Nureldin Abdallah/Reuters/Corbis6Gold mine workers wait to get their raw gold weighed at a gold shop in the town of Al-Fahir in North Darfur, September 24, 2013.Financial Action Task Force (FATF) in order to reducethe risk of money-laundering and terrorist financing.28The OECD Due Diligence Guidance includes the samerecommendation.29 Cash transactions can also make iteasier for material that has funded conflict or humanrights abuses to enter supply chains.The management report notes that by June 2013,as the initial audit was coming to a close, thecompany was seeking to reduce cash transactions andinforming clients to make bank transfers.30 A followup management report covering the period Augustto October 2013, also prepared by Ernst & Youngindicates that in mid-2013 Kaloti signed an agreementwith a Dubai bank, in order that transfers could bemade from the refiner’s account into suppliers’ bankaccounts and direct cash payments avoided. Kaloticommissioned the follow-up review after being foundnon-compliant in the first audit, as required by theDMCC guidelines.31 No evidence of money launderingwas ever found, rather that the refiner needed totighten procedure to eliminate risk.Red flags ignoredHigh-value cash transactions, the ore’s country ormine of origin, and certain classifications of gold canconstitute risk factors and should prompt refinersto increase due diligence efforts where they arise. Inother words, this is about identifying and respondingto circumstances where gold is more likely to havefunded conflict or human rights abuses. The DMCCdue diligence guidance calls on refiners to carry outan in-depth review of all risky or ‘red-flag’ locationsand suppliers, and to conduct enhanced due diligenceon such suppliers prior to engaging with them.32According to the initial management report and toaudit notes seen by Global Witness, the audit teamfound several instances in which Kaloti apparentlyfailed to do sufficient due diligence aroundsignificant risks which arose in 2012. Kaloti did not carry out proper checks on severaltonnes of gold from Sudanese suppliers, eventhough the company’s own assessment systemcategorised the gold as high-risk.33 According tothe management report, the refiner also failedto carry out enhanced due diligence on another2.4 tonnes of gold, supplied by over the counter‘call customers’ paid with cash.34 The follow-upaudit report indicated that Kaloti had stoppedaccepting gold from these customers and wasconducting enhanced research on high-risksuppliers, including those from Sudan.35 Kaloti classified mined gold (new metal coming outof the ground) as scrap gold (recycled or scrap goldcoming from jewellery or second hand electronics)in 2012.36 Gold mined in conflict-affected areaslike eastern Congo can be concealed in scrap barsin order to disguise its origin. From May 2013,mid-way through the initial audit, Kaloti began tovisually segregate mined gold from scrap metal,though the audit team recommended the useof an X-ray gold tester to ensure accuracy.37 The
City of Gold February 2014follow-up audit report highlighted the incorrectclassification of gold in several instances by therefiner’s suppliers, and noted the inadequacy of thevisual segregation method.38 Audit data shows that one of Kaloti’s main Dubaibased suppliers in 2012 purchased gold from acompany which the UN identified as linked toCongolese conflict gold. Kaloti’s supplier soldthe refiner around half a billion dollars’ worthof gold in 2012, although the audit team onlyidentified one transaction potentially relatedto Congolese supply chains.39 According to MrRihan, the audit team raised concerns withKaloti in March 2013 and recommended thatenhanced due diligence be done on the supplierin question – documenting exactly where rawmaterials come from. The management report forthe follow-up audit shows that in late 2013 Kalotiwas still buying from this supplier although it alsostated that the refiner had provided Know YourCustomer documentation for the supplier.40Global Witness subsequently obtained officialCongolese gold export statistics from eastern DRC’sSouth Kivu province for September to December 2013.The documents indicate that during this time, whichoverlaps with the August to September period coveredby the Ernst & Young follow-up audit, Kaloti’s supplieralso bought gold directly from a Congolese exporterbased in South Kivu, where a significant proportionof gold mines are controlled by armed groups.41Global Witness research in 2013 indicated thatsome gold mining sites in South Kivu can even betaxed by more than one armed group at a time. InMarch 2013, Global Witness met with the Congoleseexporter that, according to the trade statistics, soldgold to Kaloti’s supplier. It was evident during themeeting that the exporter did not fully understandwhat due diligence consists of and, when askedabout supply chain checks said to the GlobalWitness researcher, ‘I don’t get involved in that’.42While there is no evidence that Kaloti boughtCongolese gold that had funded conflict, the findingsoutlined above point to a substantial risk that suchgold could enter the refiner’s supply chains, unlessrigorous checks are in place. This is particularly truein light of the weaknesses in Kaloti’s approach tosegregating scrap and mined gold identified duringboth audits, and underscores the importance of therefiner commissioning regular independent auditsand ensuring that the results are fully transparent.Silver-coated gold barsErnst & Young’s original audit found Kaloti to be in zerotolerance breach of the DMCC guidance for knowinglyaccepting gold coated with silver, exported by suppliersfrom Morocco who had used falsified documentation.43According to audit notes seen by Global Witness,Kaloti’s management explained to the audit teamthat receiving silver-coated gold bars from Moroccowas ‘normal’, due to gold export limits apparently inplace in the country. The refiner reportedly accepted upto four tonnes of silver-coated gold.44A zero tolerance breach is defined in the DMCC andLBMA audit guidance as ‘evidence of falsificationof documentation by the auditee and/or any supplychain participant, with the knowledge and acceptanceof the auditee’. According to the guidance, thediscovery of this type of non-compliance shouldtrigger certain actions, including notification of theregulator – within 24 hours in the case of the LBMA.45Mr Rihan urged the Ernst & Young global leadership tomake contact with appropriate stakeholders, includingthe LBMA, but the firm did not do so.According to the follow-up management report,Kaloti did not receive any gold from Moroccoduring the second review period.46Global Witness wrote to Kaloti to seek commenton the issues raised by the Ernst & Young audits.In its response, Kaloti stated emphatically that thecompany was never found by Ernst & Young to befunding human rights violations or sourcing fromconflict zones, including DRC.Kaloti declared that ‘all allegations and implicationsrelating to its non-compliance in the gold tradebusiness are false and without any merit orsubstantiation’ and that the company ‘remains fullycompliant’. The refiner also said that ‘all non-complianceduring the initial audit stage was related to a lack ofspecific Know Your Customer documentation and notto any findings of conflict gold in the supply chain’.Kaloti said that it fully complies with all audit andregulatory requirements imposed by the DMCC.7
8City of Gold February 2014The DMCC: regulating tradeor promoting business?The Dubai Multi Commodities Centre (DMCC) wasestablished by the Government of Dubai in 2002‘to enhance commodities trade flows’ and todevelop Dubai into a global commodities hub.The DMCC is also regulator of the Dubai GoodDelivery standard and has the role of enforcing rules,including the due diligence guidance for refiners.47There appears to be a conflict in the dual role thatthe DMCC plays in both regulating and promotingthe trade in precious metals. The desire to protectthe Dubai gold industry from potential reputationaldamage may trump regulatory concerns, however,and could have provided a motivation for theDMCC’s behaviour during the course of eventscovered in this report.The DMCC strongly rejected allegations that theyhad acted in any way improperly or failed toproperly apply responsible sourcing practices.Moving the goal postsAccording to documents seen by Global Witness,the DMCC amended its guidance to auditors duringthe period in which the audits were taking place.As a result, Kaloti’s compliance report pertainingto Ernst & Young’s initial audit was not published.48The first set of changes to the Audit ReviewProtocol was issued by the DMCC at the end ofJune 2013, after the Ernst & Young audit team hadshared their findings with the DMCC.49 As a resultof these changes:50 The auditor is no longer required to give anoverall compliance rating in its public-facingassurance report; Nonconformities which would previously havebeen deemed ‘non-compliant low-risk’ are nowto be termed by the auditor as ‘compliant withlow-risk deviations’, and refiners are instructedto report low-risk deviations as ‘fully compliant’in their public-facing compliance report; Refiners found to be medium-risk non-compliantcan now wait three years before commissioningtheir next audit, instead of being required tohave one within 12 months; and The DMCC Review Committee, made up ofinternational banks and other stakeholders,no longer takes part in determining the refiner’sfinal rating. This removes another potential layerof scrutiny as the Committee no longer hasaccess to the auditor’s management report asa matter of course.Individually, these amendments are unlikely to havea significant impact on any review process – andsome of them are in line with the LBMA’s guidanceto auditors. Taken together, however, they couldmake the audit process less stringent and serveto reduce potential reputational risk to members.The second and more significant change to theaudit guidance was made after Ernst & Youngcarried out the follow-up review in late 2013.Shortly before the compliance report was publishedin November, a new version of the Audit ReviewProtocol was posted on the DMCC website.This latest version allows refiners to publish a‘consolidated’ compliance report in the eventof a follow-up audit.51Under the earlier version of the audit guidance,both the original and the follow-up compliancereports written by Kaloti would have had to bepublished as separate documents. The change allowsrefiners to keep damaging findings confidential andrisks removing a major motivation for responsiblebehaviour, namely public scrutiny.The motivation for the DMCC to make thesechanges warrants further scrutiny. A representativeof the DMCC sent an email to the Ernst & Youngteam asking whether the audit ratings would bemore positive if the DMCC amended the reviewperiod from 2012, to first quarter 2013.52 While theDMCC did not go through with this, in our view the
City of Gold February 2014approach is emblematic of the conflict betweenthe regulator’s duty to uphold standards, and itsambitions to boost trade in the emirate. At the veryleast, the introduction of less stringent guidelinesby the DMCC midway through the first independentcompliance audit of the Dubai gold sector isunfortunate timing.The LBMA audit guidance, which like the DMCCprotocol calls for a follow-up audit in cases ofhigh-risk non-compliance, makes no reference toa consolidated report. The LBMA audit guidancealso includes the requirement that high-risk noncompliant refiners should commission a follow-upaudit annually until implementation improves.53The DMCC said that the June 2013 changes to thereview protocol were made in order to align it withthe LBMA’s audit guidance and other internationalregulatory standards, following a comparative studycommissioned externally. The DMCC also said thatwith the application of emerging guidelines ‘therewould inevitably be a period of adjustment andareas requiring clarification’ and that the changesmade in November 2013 strengthened the protocoland ‘additionally clarified the report process byintroducing consolidated review reports’.disclosure of these types of failings is very muchin the public interest. Any responsible gold buyerwould want to be made aware of such breachesin order to make informed business decisions.Kaloti said that ‘final findings [ ] were published inaccordance with the requirements of the regulatorand [ ] were consistent with global best practicesand industry norms of compliance reporting.’The DMCC said in a letter to Global Witness thatErnst & Young reclassified Kaloti’s zero tolerancebreach of protocol finding after the managementreport was submitted in September 2013. Accordingto the DMCC, this was as a result of Kaloti disputingthe finding, and led to the submission of another‘final’ management report on 9 November 2013.The 9 November report, which Global Witness hasnot seen, apparently gave the refiner a high-risknon-compliant rating in the place of the zerotolerance breach. The DMCC rejected any suggestionThe DMCC rejected as false any suggestion thatthe changes made to the review protocol wereintended to cover up serious non-compliance oravoid the publication of negative reports. TheDMCC maintained that ‘the amendments do notchange the impact ratings, the review process orthe findings in any way’.A clean bill of healthEven though Kaloti was following the DMCC’supdated publication requirements in shelvingthe original audit findings, the fact remains that Can Stock Photo Inc. / PhilipusThe consolidated compliance report published byKaloti on 27 November 2013 following the DMCC’schanges to the review protocol, outlines the stepstaken by the refiner to meet the requirements ofthe DMCC guidance and refers to, but includeslittle detail about the original non-compliance orits scale. Kaloti makes no mention in the report ofthe zero tolerance breach of protocol related to thesilver-coated gold.54The DMCC is headquartered in the Almas Tower, located inDubai’s Jumeirah Lakes Towers Free Trade Zone.9
City of Gold February 2014tha
A recent mapping of tin, tantalum, tungsten and gold mining areas in eastern DRC shows that armed actors illegally tax the trade in more than half the sites.4 Because gold mines are numerous and often remote, and gold is easy to conceal and smuggle, DRC’s gol
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The credibility of an adverse witness, whether a lay witness or expert, can generally be impeached by demonstrating that: 1. The witness has committed an immoral, vicious or criminal act which affects the witness’ character and tends to show the witness to be unworthy of belief; 2. The witness has been convicted of a crime; 3.
Gold Content 24 Karat pure gold (a color that cannot be duplicated) 18 Karat or marked 750 75 percent gold 14 Karat or marked 585 58.5 percent gold 12 Karat or market 500 50 percent gold Unless you have coinage or a wafer or bar of gold, the dealer usually cheats a little on gold content. Many jewelry pieces are gold plated;
2-KARAT (KT or kt) is a measure of fineness of gold. A gold karat is 1/24th part, or 4.1667 percent of the whole. The purity of a gold alloy is expressed as the number of the parts of gold it contains. An object that contains 16 parts gold and 8 parts alloying metal is 16 karat gold. Pure gold is 24 karat gold. HINT: king/karat
Golden Nugget The purity of gold is measured in carats. Pure gold is 24 carats. 18 carat gold contains 75% gold. 10 carat gold contains just over 41% gold. Native gold from
UNITED HEALTHCARE INS. CO. SMALL GROUP 61021DE0060002 UHC Choice Gold 0 0-14 389.08 61021DE0060002 UHC Choice Gold 0 15 423.66 61021DE0060002 UHC Choice Gold 0 16 436.89 61021DE0060002 UHC Choice Gold 0 17 450.11 61021DE0060002 UHC Choice Gold 0 18 464.35 61021DE0060002 UHC Choice Gold 0 19 478.59 61021DE0060002 UHC Choice Gold 0 20 493.34
Keywords: Artificial intelligence, Modern society, Future impact, Digital world Introduction Artificial Intelligence or AI, as it is popularly known as, was founded in 1955. Since then, it has .
