Gold refiners and precious metals dealers

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The three large refineries of the Mendrisiotto, Valcambi in Balerna, Argor-Heraeus in Mendrisio and PAMP in Castel San Pietro, are described in Chapter F.I. Their money laundering risk lies in the origin of the metal they process. Gold from artisanal and small-scale mining in conflict regions, gold from illegal mining in South America and gold routed through trading hubs such as Dubai can carry the proceeds of crimes committed at the source, from the financing of armed groups to environmental crime and corruption. The best-known Ticino case ended without charges. The OAG investigated Argor-Heraeus for complicity in war crimes and pillage in connection with about three tonnes of gold ore allegedly extracted by an armed group in the Democratic Republic of Congo in 2004 and 2005. It closed the proceedings in March 2015 because there was insufficient evidence that the company knew of the illegal origin of the gold. The company welcomed the decision, while the non-governmental organization TRIAL International criticized it.¹

Refiners are financial intermediaries under Article 2(2) AMLA as trade assayers licensed under the Precious Metals Control Act, and their AML supervision now lies with the Central Office for Precious Metals Control described above. The reform of 2025 lowered the cash threshold for dealers in precious metals and precious stones from CHF 100,000 to CHF 15,000.² Since 1 January 2022 the due diligence and reporting duties of Articles 964j to 964l of the Code of Obligations on minerals and metals from conflictaffected and high-risk areas apply in addition, as Chapter F.I explains.

In figures. The national risk assessment of 2021:

bribery 28.95 per cent, fraud 26.63 per cent and criminal organization 7.75 per cent of reports in 2015– 2019,³
domiciliary companies involved in 29.55 per cent of all reports, in 43.36 per cent of bribery reports and in 43 per cent of criminal organization reports,⁴
foreign contracting parties in 60.4 per cent of reports,⁵
average of 4,758 reports per year in 2015–2019, against 1,113 in 2004–2014.⁶

Notes

Business & Human Rights Resource Centre, "Swiss slammed for closing DR Congo 'dirty gold' case", April 2015, https://business-humanrights.org/en/latest-news/swiss-slammed-for-closing-dr-congo-dirty-gold-case. ↩
WEKA (above). ↩
CGMF, Report 2021 (above). ↩
CGMF, Report 2021 (above). ↩
CGMF, Report 2021 (above). ↩
CGMF, Report 2021 (above). ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of August 2025.

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Dr Alexander Ressos, TEP

Rechtsanwalt/Attorney-at-Law

I am a Swiss attorney-at-law and also admitted as a solicitor in Hong Kong and in England & Wales, with almost 25 years of experience.

Together with my multilingual team, including Chinese, Japanese, Korean, Russian, Ukrainian and French native speakers, I advise companies and their owners from around the world on the full range of banking, corporate, commercial and tax law matters in Switzerland, including international tax planning, fiduciary services, and legal family office services including immigration & relocation or real estate investments. My practice has a particular focus on clients from growth and frontier markets in Greater China, Central Asia and the Caucasus, the rest of Asia, the Middle East, Africa and Latin America, and I equally advise clients from Europe and North America. Through an affiliated Swiss trust company, we also take care of the incorporation and ongoing administration of their companies and other structures, including accounting, tax returns and corporate secretarial services, and I serve as a professional director where required. With the support of a network of first-class cooperation partners, I also implement solutions worldwide.

My approach is to act as a trusted advisor who works directly with decision-makers, on an equal footing: I start from what you want to achieve and shape every structure, contract and tax decision around your commercial goals and how it improves your after-tax return. As “lawyers who make it happen”, my team and I stay involved until your company is set up, your structure is in place and your transaction has closed, and we remain available for any follow-on work that may be required. You benefit from bespoke solutions and personal attention, and sound, friendly and practical advice. We are not the lowest-cost provider in the market, nor do we intend to be; our aim is to deliver well-founded, proper solutions and excellent value for money.

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Gold refiners and precious metals dealers

Notes

Setting up or expanding in Switzerland?