Miners are onboarded to international standards, every ore batch is chemically matched against the supplier's registered profile and the flows are monitored under Swiss anti money laundering law.
Over 20 percent of the world’s gold comes from artisanal and small-scale mining, yet this production remains marginal in institutional supply chains. Refiners and banks cannot bear the legal and reputational risk of uncontrolled sourcing. This void is the compliance gap.
OCIM build the compliance path: the architecture through which artisanal and small-scale gold reaches institutional markets under documented, audited and traceable conditions. This chain of operational controls is owned end to end.
Upstream
Compliance Path (Ocim)
Downstream
Stakeholders' confidence rests on a framework that exposes itself to verification at every level. Each pillar carries an entry process and a continuous process.
Every miner partner is onboarded through a full upstream KYC procedure aligned with the LBMA Responsible Sourcing requirements and the ASM Toolkit, supplemented by the Swiss Better Gold framework. No ore enters the supply chain before this process is complete.
Risk profiles are reviewed periodically. Sanctions lists are screened on every transaction. Field visits are conducted independently of commercial teams.
From the first transaction, a baseline profile is recorded for each miner partner: expected volume, ore geochemistry, processing site. This profile becomes the operational signature against which every subsequent delivery is verified.
Every purchase is matched against the baseline. Discrepancies trigger an immediate review protocol. Continuous monitoring is the mechanism that makes the first pillar durable.
Every transfer, processing step and quality control point is logged in real time on xTrace, a blockchain backbone developed by Swiss software editor aXedras, and tied to the relevant miner's identity.
Once a transaction is recorded, it cannot be modified or deleted. The compliance path is independently verifiable by any counterparty at any point in the chain.
Developed by Swiss software editor aXedras, xTrace is OCIM’s traceability backbone. It enables objective verification of the source of mined metals (eg, crushed or milled rocks or ore, and doré bars). xTrace uses advanced chemical fingerprinting paired with AI to confirm whether a shipment of mined metal truly originates from its declared source.
The system is built on blockchain technology, a decentralised ledger that no party can alter retroactively. Once a transaction is recorded, it cannot be modified or deleted. This architectural property is what makes the compliance path independently verifiable by any counterparty at any point in the chain.
xTraceTM is currently being deployed across Soleil Metals’ operations in Peru. Full implementation is underway.
Technology partner
aXedras AG · Switzerland
Status
Deployment in progress
Geneva
Arequipa region
Consolidated risk management
Country risk is borne by OCIM Metals & Mining SA.
OCIM Metals & Mining SA is incorporated under Swiss law and supervised under the Swiss Anti Money Laundering Act. Under Article 6 of the FINMA Anti Money Laundering Ordinance, the group conducts consolidated risk management across all entities, including Soleil Metals’ operations in Peru.
This means the traceability and control framework governing OCIM’s trading operations in Geneva applies directly to field level operations in Peru. Where a conflict arises between local practice and Swiss obligation, Swiss obligation prevails.
Sourcing gold from artisanal and small-scale producers carries specific risks, well documented at sector level. OCIM's compliance framework addresses each of them through a dedicated operational mechanism.
Mercury contamination, unmonitored extraction sites, ecological liability transferred to the buyer.
Every miner onboarded by Soleil Metals undergoes an environmental assessment as part of upstream KYC. Operations are confined to pre cleared sites. Mercury free processing methods are required as a condition of partnership. Compliance is monitored continuously, not only at onboarding.
Every gram purchased by OCIM comes from a documented site operating within assessed environmental parameters. The buyer's exposure to environmental liability is eliminated at source.
Gold's fungibility makes it a vehicle of choice for laundering. Layered ownership, undocumented cash flows upstream, and the absence of provenance evidence expose buyers to proceeds of crime channelled through the supply chain.
OCIM applies upstream KYC standards equivalent to those required by Swiss financial intermediaries under AMLA. Every miner partner is subject to full identity verification, beneficial ownership documentation, source of funds review, and screening against OFAC, EU and UN sanctions lists. Transactions are monitored continuously for anomalies against the onboarding baseline.
OCIM eliminates the sector's AML risk through a compliance architecture designed to FINMA standards.
Substitution or contamination of compliant ore during transport and processing, internal collusion at the plant.
Soleil Metals' employees are bound by procedures that prevent metal diversion during processing. Transporters are certified, parcels are sealed, customs operations are internalised. There is no intermediary in the chain between the mine and the plant.
OCIM can certify that 100% of the doré produced by its plants is delivered to identified accredited refiners, without blending with unverified sources.
Two voices, one framework
Doctrinal voice · Geneva
"
We bring Swiss banking level compliance to artisanal and small-scale mining.
Head of Compliance
Fifteen years at Credit Suisse and UBS, where she served as Executive Director and Deputy Head of Compliance for Geneva and French speaking Switzerland. Co founder of Unravel One, a firm specialising in AML, OSINT, asset tracing and compliance advisory. Joined OCIM in 2025 to design the group's compliance framework and risk management.
Operational voice · Lima
"
Compliance is an opportunity to transform small-scale mining on the ground.
Head of Compliance
Oscar has over 20 years of experience in the mining sector and the Peruvian capital market. His professional career has focused on business development in the mining and financial sectors, in addition to carrying out his duties in terms of compliance.
OCIM holds the following memberships and certifications. Each is subject to admission criteria, ongoing reporting and periodic renewal.
Member of the ASM Task Force. London Bullion Market Association, the international standard-setting body for the gold market.
Active member
SBG Step 1 confirmed on the processing plants. Covers many requirements such as ASGM supplier legitimacy, traceability with LBMA Toolkit onboarding and mercury handling.
Step 2 in progress
Extends independent verification to our due diligence and grievance systems, under a protocol recognised by downstream industrial buyers.
Audit in progress
Swiss fedeGold Processing Initiative. First processing plant operator to enter a formal collaboration with the WGC on the formalisation of ASM.ral supervision under the Anti Money Laundering Act. OCIM Metals & Mining SA.
Collaboration agreement
Member since July 2026, within a membership of Swiss refiners, traders and banks. OCIM joins as an integrated producer sourcing from ASM mining.
FULL MEMBER
Swiss federal supervision under the Anti Money Laundering Act. OCIM Metals & Mining SA.
AMLA regulated
Audit reports available to qualified counterparties on request.
The compliance gap is the mismatch between ASM production, which represents over 20% of global gold, and its share in institutional supply chains, less than 1% of LBMA Good Delivery throughput. It exists because upstream compliance costs miners without immediate compensation, while downstream refiners cannot accept undocumented sourcing. A compliance pathway is the architecture that closes this gap: a mid-chain operator carries the compliance function, giving qualifying miners access to institutional markets. At OCIM, this pathway is implemented through its subsidiary Soleil Metals.
OCIM’s Compliance Path comprises five components. Upstream KYC anchors the legitimacy of counterparties. xTrace provides transaction by transaction traceability with real time alerts. Swiss Better Gold Phase 1 certifies practices at the plant, through independent audit. LBMA Full Membership recognises compliance with the Responsible Sourcing Programme. Swiss AMLA supervision applies regulatory oversight, regular reporting and external audits.
OCIM Metals & Mining SA is incorporated under Swiss law and regulated under the Anti Money Laundering Act. It reports to the supervisory authority and undergoes yearly external audits. Pursuant to Article 6 of the FINMA Ordinance, risk management is consolidated across all group entities. The control framework applied to Geneva trading extends to operations in Peru, with country risk managed at group level.
Peru is classified as a higher risk jurisdiction in Swiss and European AML mappings. OCIM’s compliance framework is designed to absorb country risk before it reaches downstream partners. Operating zones are selected with geographic granularity: activity is concentrated in the Arequipa region, continuously mapped and monitored. Political instability may affect operational productivity but not the compliance chain, which rests on international standards independent of local politics.
REINFO, Peru’s Registro Integral de Formalización Minera, allows plants to source from miners in the process of formalisation. Its limits are documented: some billing agents rent their REINFO status to informal operators, and REINFO alone does not guarantee operation legitimacy. OCIM treats REINFO as necessary but insufficient. Each supplier undergoes the 22 document onboarding, on site verification of the mine, and continuous cross-check between declared concession and produced volumes.
OCIM cross-references three independent sources at every stage. First, documentary verification at onboarding: KYC file, mining title, sanctions screening, on site visit. Second, chemical fingerprinting through xTrace at every ore intake, matched against the supplier’s registered profile. Third, continuous cross-check against external provider data throughout the chain. Any inconsistency across the three sources stops the process before the material enters the plant.
Compliance and traceability address two different questions. Compliance verifies the counterparties: who they are, whether their mining title is valid, whether they meet regulatory and ESG standards. Traceability verifies the material: whether the ore delivered matches the profile recorded at onboarding. Compliance without traceability cannot confirm that the material corresponds to the qualified supplier. Traceability without compliance documents an unverified flow.
OCIM applies Swiss banking due diligence standards to its supply chain: KYC of counterparties, AML monitoring, sanctions screening. The automated alert system, designed with aXedras and inspired by monitoring tools adopted by banks, flags anomalies in real time. The difference is the object monitored. A bank flags unusual transactions. OCIM flags origin discrepancies: material whose chemical fingerprint does not match the supplier’s registered profile at onboarding.
Onboarding is completed before the first purchase. The process was developed with Swiss Better Gold and incorporates the requirements of the LBMA ASM Toolkit. Twenty two documents cover identity, the validity of the mining authorisation, sanctions screening against OFAC, EU and UN lists and ESG requirements including health and safety at the mine. Enrolment is based on the REINFO registry, supplemented by additional documentary evidence and verification points.
After onboarding, risk profiles and the validity of mining authorisations are reviewed periodically. Field visits are conducted independently of the sales teams. Each incoming batch is verified against the supplier’s file and cross-checked with the REINFO registry that anchors the miner’s formalisation status. Any inconsistency triggers investigation.
xTrace is the traceability layer of the framework. Developed by Swiss company aXedras, it combines chemical fingerprinting with AI and connected analytical devices. At every ore intake at the plant, it compares the obtained profile against the reference profile recorded at supplier onboarding. Discrepancies are flagged in the same way a bank flags unusual transactions. Records are immutable, held on blockchain and shareable with downstream refiners through the Bullion Integrity Ledger.
OCIM’s refiner clients require every ounce sourced from ASM to come from a traceable, audited and responsible supply chain. The compliance framework is what enables that guarantee: onboarding files aligned with the LBMA ASM Toolkit, continuous monitoring, chemical fingerprinting through xTrace and Swiss Better Gold Phase 1 certification obtained through independent audit.
Peru is rarely cited as a model for responsible artisanal gold. Yet the country offers three structural conditions that make a compliance corridor operationally possible, starting with a mid chain of industrial processing plants that no other ASM jurisdiction can match.
The economic logic that makes a documented chain viable beyond a market niche, and what it implies for refiners and downstream buyers.
Following successful integration at the Aurora site, xTrace blockchain traceability is now operational at the second Soleil Metals processing facility.
