SWISSAID estimates 591 tonnes of illicit gold in the Emirates. But statistical discrepancies, hypotheses and classifications raise many doubts about the method.
SWISSAID estimates that in 2024 they will have entered the United Arab Emirates at least 591 tonnes of illicit goldfor a value of 74 billion dollars. It’s an impressive figure. But it doesn’t come from tracking as many tons or examining each batch: it’s a total reconstructed by combining commercial discrepancies, estimates and hypotheses about the origin of the metal. Presenting it as an established quantity confuses what the data shows with what the report infers. To estimate thesmuggled African goldSWISSAID compares the imports registered by Emirates with exports declared by African countries. The difference is interpreted as undeclared gold in the country of extraction. But a statistical discrepancy alone does not prove either that the metal was smuggled or where the irregularity occurred. A Comtrade points out that asymmetries between imports and exports may depend on several factors: different registration times, passages through third countries, different criteria in assigning the trading partner or divergences in classification. SWISSAID recognizes these methodological limitations. However, when converting the difference between two statistical series into tons of “smuggled gold“, the language becomes more categorical than the data. The discrepancy is a valid reason to investigate; it is not direct evidence of smuggling.
The 591 tons depend on questionable classifications
The total is obtained by adding 453 tonnes of African gold believed to be smuggled to 174.5 tonnes attributed to Russia, Yemen And Sudanthen subtracting 36.8 tons of Sudanese gold already included in the first category. The operation is understandable. It is the categories that compose it that require greater caution. The report classifies the entire volume imported by the United States as “conflict gold”. Emirates from those three countries: 108.9 tons from Russia, 6.6 from Yemen and 59 from Sudan. Coming from a country in conflict may justify enhanced due diligence. However, it does not in itself prove that each batch was mined in an area controlled by armed groups, financed a warring party or was illegally marketed. Here the report overlaps two different assessments: that a flow is high risk and that the gold is illicit. To prove the second you need information on the lots, suppliers, commercial steps and applicable rules. National origin alone does not answer these questions.
Estimates and observed data are not the same thing
When official weights are missing, the report derives them by dividing the commercial value by the average gold price. It’s one way to get an order of magnitude, but it’s not the same as weighing shipments. The result also depends on the purity and form of the metal and the way the value is recorded. Even the 40 tons additions for gold transited through neighboring countries are an estimate based on sources and assumptions. SWISSAID considers half of the gold exported to the Emirates from four transit countries to be smuggled. Calling this choice prudent does not transform it into an observed data: 50 percent is a parameter of the calculation and contributes directly to the total. Estimates can be useful, but the reader must be able to clearly distinguish the declared data, reconstructed weights, hypotheses and documented cases. The formula “591 tons of illicit gold” tends to bring them together in a single statement.
Audits do not automatically represent the entire industry
The report says it has analyzed 50 compliance reports And 51 audit reports, but later states that only 2 gods 52 audit reports identified show full compliance. The text does not clarify why the denominator changes from 51 to 52. It is an internal inconsistency that should be explained, especially when general conclusions are drawn from those numbers. Furthermore, 52 reports are not the same as 52 refineries: some companies appear for multiple years. The report also admits that public reporting is incomplete and that not all refineries have been identified. Therefore “only two fully compliant” does not mean “only two compliant refineries”. The distinction between the categories must also be considered: 23 reports are classified as “compliant with low risk deviations”, while others report medium or high risk deviations. Summarizing all cases that are not fully compliant with a single formula can make deficiencies of different severity appear the same. The report also reports that, according to the Emirates Ministry, 13 compliant refineriesincluding those with low-risk deviations, accounted for 90 percent of refined production. This statement does not close the discussion, but calls for a clearer comparison between the number of audits, volumes processed and severity of deficiencies. The report is not just about Switzerland: it analyzes the role of United Arab Emirates In the global gold marketfrom imports and re-exports to controls on refineries. There Swiss is treated as one of the main destination countries for Emirati gold and for the role of the Swiss company Valcambi SAbut it is not the only market examined.
The temporal comparison does not demonstrate the failure of the law
SWISSAID concludes that Emirati due diligence rules have had little or no impact on African smuggling flows. The conclusion is based above all on the comparison between a few years before and after the entry into force of the legislation, in January 2023. But the fact that the estimates do not show the expected reduction does not demonstrate that the law has had no effect: in the same period the flows, the policies of the producing countries and the quality of the statistics may have changed. To attribute a change to the law it is necessary to separate its effect from that of other factors. The report notes that, according to its methodology, no noticeable decrease emerges. However, it does not demonstrate what the level of flows would have been without the legislation. The causal conclusion is therefore stronger than the comparison presented.
Stay in the market, provided you verify
The traceability shortcomings reported by SWISSAID deserve attention. But they argue the need for more effective controls; they do not prove that abandoning the UAE market is the only answer. In the response provided to SWISSAID, Valcambi has limited the information disclosed in consideration of the legal proceedings currently underway. The company says its approach is based on clear requirements and their consistent application: «Materials are only accepted when they comply with applicable regulatory requirements and the company’s due diligence standards, as well as when the identified risks have been adequately addressed.» Valcambi furthermore claims that the pole of United Arab Emirates represents one of the most important centers of the precious metals market and is increasingly oriented towards high standards. The company disputes the recommendation of SWISSAID to abandon the market: in his opinion, the solution consists in establishing clear rules and accepting materials only when they comply with them. That’s how it is, he claims Valcambithat the principles of responsible sourcing can be extended and illegal practices can be concretely combated. This position is only credible if the due diligence is verifiable: it must go back beyond the immediate supplier, document the risks identified and show that non-compliant batches are rejected. Corporate declarations alone are not enough; but not even a commercial discrepancy is enough to prove that all the gold involved is illegal. The report poses important questions for refiners and regulators Emirates. To be convincing, however, it must separate indicators, hypotheses and evidence more precisely. Its estimates can signal where to investigate; they should not be presented as certain counts of illicit gold. Risk does not mean proof, discrepancy does not automatically mean contraband, and a before-after comparison does not alone prove the failure of a law.
