On the afternoon of Monday, August 21, US Treasury Secretary Steven Mnuchin, Senate Majority Leader Mitch McConnell, Kentucky Governor Matt Bevin, and Kentucky Congressman Brett Guthrie took a visit to the vault of the US Mint’s gold depository in Fort Knox, Kentucky, a vault which, according to the US Treasury, holds gold bars containing 147,341,858 fine troy ounces of gold (4583 tonnes of gold).
The trip was notable in that it is one of the rare occasions in history that a US political/congressional delegation has ever visited the Fort Knox depository, and Mnuchin is now only the 3rd treasury secretary ever to make this visit.
The trip was also notable in that unlike previous political excursions to the vault, the Mnuchin-led visit was very low-key, it was announced to the media and public at extremely short notice, and there is no evidence that any media representatives participated, or at least if they did, they have kept very quiet about it.
In contrast, the previous congressional visit to the Fort Knox depository in September 1974 was heavily publicised in advance, was accompanied by 100 news reporters and photographers, and it even documented the visit via photographs and film which were released to the public.
Mnuchin’s visit to the vault merely appears to have taken the form of a quick peek into one of the cramped vault compartments within the Fort Knox vault, and therefore can only be seen as an odd PR stunt whose real intent remains unclear, which does nothing to improve the transparency of the notoriously secretive gold depository, and which on balance has now re-opened scrutiny on how much gold is, or is not, actually stored in the compartments of the Fort Knox vault.
The trip to the Fort Knox vault was only announced by Mnuchin on Monday morning, August 21 (the morning of the Fort Knox visit) during a speech to the Chamber of Commerce in Louisville, Kentucky, which Mnuchin and Mitch McConnell were attending.
As Grace Schneider, a business reporter for the Louisville, Kentucky based Courier-Journal tweeted that morning:
So Mnuchin announced the visit literally a few hours before it took place. Fort Knox is located about 40 miles south-west of Louisville. In his Monday morning speech at the Chamber of Commerce, the Washington Examiner reports that Mnuchin made the bizarre comment that “I assume the gold is still there”. McConnell, at the same time, quipped that “we’re going to find out”. Mnuchin’s comment is bizarre because as US Treasury Secretary, he is top official of the US Treasury.
The US Treasury owns the gold in Fort Knox. The US Mint is just the custodian. The Director of the US Mint and all other senior officials report to Mnuchin. At any time, Mnuchin can get a full and complete high-level briefing on the real status of the US gold reserves. He can also get a full de-briefing on the extent to which the US gold reserves have been audited over the years – or not audited as the case may be. To say that he assumes the gold is still there shows either a flippant view of the expected accountability of a US Treasury Secretary, or else a disregard for the responsibility to which the US public has entrusted him.
It’s not clear whether any journalists actually accompanied the politicians on last Monday’s visit to the Fort Knox depository. An article by an AP journalist from Kentucky named Adam Beam was published on August 22, the day after the visit to the Fort Knox depository.
Beam, based in Frankfort, Kentucky is listed as a Kentucky Statehouse reporter for AP, so would presumably, due to this role, be well-known in Kentucky political circles and would have privileged access to the Mnuchin & Co delegation. AP’s Beam wrote that:
“Inside the famed vaults at Fort Knox, Senate Majority Leader Mitch McConnell held a 27-pound gold bar in his hands Monday as part of the first civilian delegation to see most of the country’s bullion reserves in more than 40 years.”
But AP’s Beam also wrote in the same article that:
“in an interview, McConnell said he could not say much about the visit for security reasons”
suggesting that Beam may not have been on the actual visit to the vault, because if he was, he would have no need to interview McConnell and could have recorded the vault details himself. if the AP Kentucky Statehouse reporter wasn’t even on the visit, what hope was there for other reporters?
As far as I can see from related coverage, there are no photos of any of the delegation either inside the depository. This would suggest that there were no media photographers nor camera people present inside the vault. For such a historic trip, this is itself quite bizarre. Until that is, you realize that in 1978, the US Mint made the internal plans and structures of Fort Knox classified, which effectively bans any photography or filming from inside the depository.
Only One Compartment Viewed
The same AP article quoted Kentucky Governor Matt Bevin as saying that [Fort Knox] “officials had to cut a seal to open the vault for them“. What Bevin means is that the seal on the door of one of the compartments in the vault was cut so that they could open the door to the compartment. According to the US Mint, Fort Knox stores US Treasury gold bars in 13 compartments within the Fort Knox vault. See BullionStar article “Second Thoughts On US Official Gold Reserves Audits” for details.
By opening just one of the 13 compartments for Mnuchin & Co to peer into, that leaves 12 of the supposed gold storage compartments that were not opened. Still, this didn’t stop Mnuchin stating on Twitter that “Glad gold is safe“. This is a ridiculous statement from a US Treasury Secretary when you consider what the actual visit consisted of, and it would be remiss of the US public to put any trust in it.
Kentucky Governor Matt Bevin also said something similar in a radio interview following the vault visit, i.e. that the delegation only saw a subset of the supposed gold. Interviewed by Newradio 840 WHAS, and quoted by televison channel WHAS 11, Governor Bevin said:
“I didn’t see every bit of it [the gold], but the amount that I saw was impressive”
The US Treasury Secretary takes a quick look into one of 13 compartments in the vault and says “Yep, the gold is safe, it’s there“. Imagine a commercial gold vault operating on the basis of how Fort Knox operates. It couldn’t. I have been in BullionStar’s precious metals vault in Singapore. I have looked around. There are a lot of gold bars, silver bars, gold coins and silver coins. But I couldn’t say based on a quick casual observation that ‘yep, all the gold and silver is there’.
That’s why there is a rigorous inventory system at BullionStar, and that’s why BullionStar employs a transparent multi-layered auditing system comprising 5 different audit schemes that are all accessible to customers. To ensure that at any given time, both BullionStar staff and customers know exactly what is inside the BullionStar vault.
But the US Treasury seems to think its sufficient that a quick unrecorded trip by 4 US political insiders can somehow instill confidence that all the gold that is claimed to be in Fort Knox is actually there. In case readers may think BullionStar is being unfair to the US Treasury, its worth noting that there have been many articles published on the BullionStar website by Koos Jansen that highlight the myriad of inconsistencies about the supposed gold reserves stored at Fort Knox and US government auditing of said gold reserves. See for example:
As a freebie trip for 4 select political insiders, last Monday’s trip to Fort Knox was undoubtedly a memorable one for them. In the same radio interview Bevin said that:
“This is like the mother of all field trips. This is pretty cool”
But as a validation and verification of over 56% of the supposed US Official Gold Reserves, the visit was a complete farce. Announced the morning it took place. No evidence that any media were allowed to participate. Only peeked into one of the 13 storage compartments. And then to round it off, Mnuchin (an ex Goldmanite) tweets that ‘Glad gold is safe“. You couldn’t make this up. And finally, no mention of the fact that most of the gold bars even supposedly stored in Fort Knox are low purity ‘coin bars’ made from melted down gold coins. In fact, of all the gold bars reported to be held within the US Gold Reserves, only 16% of these bars are of LBMA Good Delivery size and purity range.
On August 10, the Wall Street Journal (WSJ) published an article about the Federal Reserve Bank of New York (FRBNY) custody gold and the NY Fed’s gold vault. This vault is located under the New York Fed’s headquarters at 33 Liberty in Manhattan, New York City.
The article, titled “The Fed Has 6,200 Tons of Gold in a Manhattan Basement – Or Does It?”, can be read on the subscription only WSJ site here, but is also viewable in full on both the Fox News Business and MorningStar websites, here and here. It also appeared on the front page of the Wall Street Journal print edition on Friday, August 11.
The NY Fed offers a ‘custody gold’ storage service to its customers, customers which are exclusively foreign central banks and international financial institutions, except notably, the US Treasury is also a gold storage customer of the NY Fed. The Fed’s gold vault, which is on level E (the lowest level) of its basement area under its downtown Manhattan headquarters, open in 1924, and has been providing a gold storage service for foreign central banks since at least the mid-1920s. Custody gold means that the NY Fed stores the gold on behalf of its customers in the role of custodian, and the gold is supposed to be stored on an allocated and segregate basis, i.e. “Earmarked gold”.
NY Fed stored gold has risen in public consciousness over the last few years arguably because of recent Bundesbank gold repatriation operations from New York as well as also similar gold repatriation from the central bank of the Netherlands. The moves by the Chinese and Russian central banks to actively increasing their gold reserves have also put focus on whether the large traditional central bank / official sector gold holders (such as Germany, Italy and the International Monetary Fund) have all the gold that they claim to have, much of which is supposedly stored at the NY Fed vault.
The main theme of the August 10 WSJ piece, as per the title, is whether the NY Fed actually stores all the gold in the vault that its claims to store, a theme which it introduced as follows:
“Eighty feet below the streets of lower Manhattan, a Federal Reserve vault protected by armed guards contains about 6,200 tons of gold.
The WSJ article intersperses a number of facts about this custody gold alongside various quotes, and while I cannot speak for anyone else quoted in the article, the quotes could probably best be described as being on the sceptical side of the NY Fed’s official claims.
Since I am quoted in the article, it seems appropriate to cover it here on the BullionStar website. The relevant section is as follows:
‘But “no one at all can be sure the gold is really there except Fed employees with access,” said Ronan Manly, a precious-metals analyst at gold dealer BullionStar in Singapore. If it is all there, he said, the central bank has “never in its history provided any proof.”
Mr. Manly is among gold aficionados who wonder if the bank is hiding something about what it’s hiding.’
Let me begin by explaining the basis of my quote.
The only reporting which the New York Fed engages in for the custody gold recorded as being held on behalf of its customers (central banks and official sector organizations) is a single number communicated each month (with a 1 month lag) on Federal Reserve table 3.13 – “Selected Foreign Official Assets Held at Federal Reserve Banks” and listed as “Earmarked Gold”.
As of the end of July 2017, the Fed reported that it was holding $7.84 billion of “Earmarked Gold” in foreign and international accounts. This amount is a valuation at the official US Treasury / Fed price of gold of US $42.22 per fine troy ounce, and which works out at approximately 5775 tonnes of gold.
The reason that this figure differs from the ~6200 tonnes number quoted by the Wall Street Journal is that it doesn’t include 416 tonnes of US treasury gold also claimed to be stored in the NY fed vaults. When the US Treasury claimed quantity is added, the figure comes to 6191 tonnes, hence the WSJ citation of circa 6200 tonnes.
NY Fed Gold – Opacity and Secrecy
Other than that, the Federal Reserve does not publicly communicate any other relevant information or details about the quantity of custody gold bars said to be stored in its vault, and furthermore, the Fed has never in its history publicly communicated any such relevant details or information.
So it is a fact that the Federal Reserve has “never in its history provided any proof” that all the gold it claims is there is really there, hence the quote is factual, and hence the connected quote that “no one at all can be sure the gold is really there except Fed employees with access” is a valid conclusion also.
The NY Fed has never provided any of the following:
– details of the names of the central banks and international financial institutions that it claims to hold gold on behalf of
– details of how much gold is held by each customer
– details of whether any of the gold stored in the vault is under lien, claim encumbrance or other title
– details of whether any of the custody gold is lent or swapped
– details of location swaps and / or purity swaps of gold bars between the NY Fed vaults and other central bank or commercial bank vaults around the world
– details of the fact that nearly all of the gold bars supposedly held in the NY Fed vault are a combination of old US Assay office gold bars and low grade coin bars made from melted coins
The NY fed has never allowed the conduct of any independent physical gold bar audits or published any results of its own audits. It has never published any gold bar weights lists (note one weight list for some US Treasury gold bars stored at the NY Fed vault made it into the public domain in 2011 as part of documentation that was submitted to a ‘Investigate the US Gold’ hearing in front of the US House of Representatives Committee on Financial Services. That weight list starts on page 132 of the pdf which can be accessed here.
Mainstream Media Cheerleaders and Detractors
The lack of transparency of the New York Fed as regards the custody gold that it stores for its central bank customers is therefore a valid point. The Wall Street Journal article of August 10 is merely highlighting this valid point. However, predictably this did not stop some mainstream US media critics from denouncing the WSJ article such as can be seen in the following tweet from a POLITICO ‘chief economic correspondent‘.
In which the WSJ takes seriously the lunatics who think the NY Fed is lying about what's in its vaults. https://t.co/83LsDN4ApP
I would wager that this Ben White chap has never asked the New York Fed any serious questions about its custody gold, preferring instead to throw around tweets using accusatory language such as ‘lunatics’. But this sort of reaction is par for the course from elements of the cheerleading US mainstream media, who seem to feel an obligation to protect the Fed and the status quo of the incumbent central bank led financial system from any valid criticism.
However, I have asked the NY Fed serious questions about its custody gold.
– the number of central banks and official sector institutions that have gold in storage with the NY Fed in Manhattan.
– the identities of these central banks / official sector institutions that have gold in storage.
– could FRBNY CBIAS / Account Relations provide me with gold bar weight lists for the gold holdings that these central banks and official sector institutions hold with the NY Fed?
As the first query went unanswered, I then resubmitted the query a month later in mid-March. On neither occasion did the Fed respond or acknowledge the request. Realistically, I didn’t expect the NY Fed to answer, since they have track record of being aloof and unanswerable to anyone but their own stakeholders, however, the outcome of the emails has established that the NY Fed does not engage on this issue nor provide any transparency in this area to the public.
I had expected the WSJ article to be a lot longer and more in-depth than it actually was, and to obtain some publishable response from the NY Fed. The WSJ however says in the article that:
“The Fed declined to comment”
The lack of any quotation by the Fed within the WSJ article is a glaring omission, and actually proves the complete lack of cooperation by the Fed on the entire topic of gold bar storage. The WSJ article does say that it filed Freedom of Information (FOIA) Requests with the NY Fed, which again underscores that without FOIAs, the Fed wouldn’t voluntarily reveal anything.
What these Freedom of Information requests actually contained is not, however, even revealed by the WSJ, except hilariously in one passing reference to “a heavily redacted tour guide manual“. Hilarious in the sense that the NY Fed would even see fit to heavily redact a simple tour-guide manual. To quote the WSJ:
‘The Wall Street Journal filed Freedom-of-Information requests with the New York Fed. Among the Journal’s findings, from a heavily redacted tour-guide manual provided by the Fed: Tour guides are informed that “visitors are excitable” and should be asked to “please keep their voices down.”‘
Why doesn’t the Wall Street Journal do a full publication of all the NY Fed FOIA responses that it received and publish them on its website? This at least would be some sort of backup evidence to the published article.
There are a multitude of angles that the Wall Street Journal could cover if it wanted to do a proper investigation into the gold bars supposedly stored in the NY Fed vault below 33 Liberty on Manhattan Island.
Why did the German Bundesbank take multiple years to transfer back a small portion of the gold that it claimed to have held at the NY Fed vaults, with much of that gold having to be recast / remelted into new bars en route to Frankfurt in Germany. If the gold was allocated and segregated to the Bundesbank account at the NYFed, there would have been no reason for the multi-year transfer delays and no reason to need to melt down and recast any gold bars.
Why did low-grade coin bars start turning up in the NY Fed vaults from 1968 onwards? The only place they could have come from is Fort Knox in Kentucky. The fact that these low-grade coin bars had to be used suggests there was not enough high-grade gold bars (995 US assay office Good Delivery gold bars) to satisfy central bank customer requirements at the NY Fed vault at that times. Some of these coins bars were over time shifted out of the NY Fed vaults and refined into high-grade bars and sent to the Bank of England in London. How much coin bar gold is still in the NY Fed vault.
For the 3 largest claimed gold holders at the NY Fed, which are the Banca d’Italia, the Bundesbank and the International Monetary Fund, and which between supposedly hold at least 4000 tonnes of gold at the NY Fed, there is no way to validate the accuracy of any of these holdings, neither from IMF, Bundesbank or Banca d’Italia sources, nor from the NY Fed. These gold holdings have, on paper, not changed since the early 1970s, but thats over 40 years ago and there is no way to check the accuracy of these 3 holdings which make up the lions share of all the gold supposedly held at the NYFed.
Why is there a tunnel between the NY Fed level E basement gold vault to the Chase Manhattan Plaza level B5 basement gold vault across the street? i.e. Why is a central bank vault linked to a commercial vault run by a commercial bank (JP Morgan Chase)?
Does, or has the JP Morgan / Chase in the past, facilitated the activation of NY Fed stored central bank gold into the commercial gold market via movements of gold bars from 33 Liberty to Chase Manhattan Plaza vaults?
Why is there no mention in the Wall Street Journal article of the NY Fed’s Auxiliary vault which was built in 1963 and its location, and which supposedly stores gold bars in a “wall of gold”. Was this not newsworthy?
Why did the 2004 version of the NY Fed gold vault brochure ‘The Key to the Gold Vault’ state that gold bars “belonging to some 60 foreign central banks and international monetary organizations” were stored at the NY Fed vault, and then the 2008 version of the same brochure had changed this statement to gold “belonging to some 36 foreign governments, central banks and official international organizations”.
Why the drop from 60 customers to 36 customers. I have heard from a very reliable senior ex-NY Fed executive that some central banks were unhappy to keep their gold in Manhattan in the aftermath of 9/11 and wanted it stored elsewhere. You wouldn’t blame then given what happened to the Scotia gold vaults under the WTC 4 on 9/11.
Why does the NY Fed decline to comment for a Wall Street Journal article? Surely this should ring alarm bells at the Wall Street Journal?
BullionStar recently teamed up with Real Vision TV, the unique video-on-demand finance and investment channel, to film a presentation for the Real Vision audience on some topical areas of the gold market.
The video presentation, which was filmed in London in June 2017, covers the fractional-reserve world of bullion bank trading in the London Gold Market, and also some concerns and risks of gold-backed Exchange Traded Funds. It then wraps up by discussing the benefits and attractions of physical gold ownership in light of the dangers and risks of today’s synthetic gold trading market.
Real Vision TV has kindly made this presentation available for viewing by BullionStar customers and readers, and the video presentation, which is 20 minutes long, can be viewed at the following link:
BullionStar would like to thank Real Vision TV for making this presentation possible and for facilitating the broadcasting of the presentation to the BullionStar audience.
Real Vision TV, founded by Raoul Pal and Grant Williams, is a subscription-based video on-demand channel featuring discussions, interviews, presentations and insights from many of the world’s top financial market minds and investment gurus.
Over the last number of years, one of the most interesting trends in the physical gold world is the ongoing conversion of large 400 ounce gold bars into smaller high purity 1 kilogram gold bars to meet the insatiable demand of Asian gold markets such as China and India.
This transformation of 400 ounce bars into 1 kilogram bars is an established fact and is irrefutable given the large amount of evidence which proves it is happening, as has been documented on the BullionStar website and elsewhere.
It is also something which causes plenty of excitement in the gold world as it underscores the huge movement of physical gold from West to East, and the continual depletion of gold inventories from locations such as the London Gold Market.
The general movement is one of 995 purity 400 ounce gold bars coming out of gold-backed ETFs, central bank gold holdings and other wholesale gold holdings, and these bars making their way to the Swiss refineries where they are transformed / smelted / recast into smaller 9999 high purity gold bars. The smaller gold bars are then exported from Switzerland to India, China, Hong Kong, and the Middle East.
At the same time as the wider gold market acknowledges and publicises this trend, the establishment gold world and bullion banks (as represented by the London Bullion Market Association) tend to downplay this conversion of 400 ounce gold bars into 1 kilogram bars, presumably because it directly highlights the continual drain of real physical gold out of the London vaults into China and India, gold which has little chance of ever coming back again.
For an example of significant downplaying of conversion of 400 ounce gold bars into kilogram gold bars, see BullionStar post from September 2015 titled “Moving the goalposts….The LBMA’s shifting stance on gold refinery production statistics” which documents how a mammoth 2000 tonnes of LBMA gold refinery output attributed to the year 2013, mysteriously disappeared from the LBMA’s publications in early August 2015, after the original figure of 6,601 tonnes had been highlighted on this website, with the original figure being replaced by a far lower 4600 tonnes.
While gold refineries in countries other than Switzerland may be involved in these 400 ounce to 1 kilogram gold bar transformations, the Swiss refineries are the big players in this area, as they say so themselves. The names in question are Valcambi, PAMP, Argor Heraeus and Metalor. For a full understanding of the extent to which these large Swiss gold refineries process 400 ounce gold bars into kilobars and the importance that they attribute to this specific category of refinery activity, please see BullionStar blog from November 2015 titled “From Good Delivery bars to Kilobars – The Swiss Refineries, the GFMS data, and the LBMA“.
But if you thought the massive conversion of large gold bars into kilogram bars that occurred in years such as 2013 and 2014 was an anomaly or a one-off, then think again. Because it also happened in 2015, and in a very big way.
LBMA Update – 2015 Gold Refinery Statistics
In early May 2017, the London Bullion Market Association published a revised version of its 4 page ‘LBMA Overview Brochure’, the most notable update of which was that it revealed refinery production statistics for 2015 for the gold and silver refineries around the globe that are on the LBMA’s Good Delivery List.
A table in the updated brochure states that in 2015, the “total refined gold production by the refiners on the List was estimated to be 5,034 tonnes”. The corresponding figure for gold in 2014 was 4921 tonnes.
At some point each year, the LBMA will invariable release such refinery statistics, however, the lag in publication is inexplicably long, for example, 2015 data only gets released in May 2017. Why 2016 data is not released in 2017 remains a mystery. This length of lag would not happen in any other industry. Leaving aside this mystery, the 2015 statistics are interesting and worth analysing for a whole lot of reasons, which are discussed below.
This year the LBMA update – of the 2015 data – was a very low-key affair indeed and did not even, in the LBMA’s eyes, merit a press release. This differs to May 2016, when the LBMA published 2014 gold and silver refinery statistics and at least accompanied the announcement with a press release which it titled “4,921 tonnes of gold production in 2014 – LBMA GD refiners”.
The LBMA’s May 2016 press release stated that 2014 refinery gold production by the refiners on the LBMA’s Gold Good Delivery List for gold totalled 4921 tonnes, and importantly, it attributed the excess over ‘world mine production of 4,394 tonnes‘ to be due to “recycling of material by LBMA GD refiners converting large 400 oz bars into kilobars“.
This reference to ‘world mine production of 4,394 tonnes‘, which was itself attributed to Thomson Reuters GFMS, is incorrect, and the LBMA should have said that “world mine production + scrap recycling + net hedging supply” was 4394 tonnes, as is clear in the Thomson Reuters GFMS table from which the figure of 4394 tonnes was taken. This table is as follows:
The ‘net hedging supply’ category can be ignored as it is not relevant for gold-laden material arriving into gold refineries for processing. What the LBMA should have said in its 2016 press release is that in 2014, the gold refineries on its list (which generate 85% – 95% of world gold refinery output) produced 4921 tonnes of gold, which was in excess of combined gold mining production and scrap recycling i.e. in excess of 3131 + 1158 = 4289 tonnes. This excess was due to “recycling of material by LBMA GD refiners converting large 400 oz bars into kilobars”.
Given that the LBMA gold refiners only represent 85% – 90% of world gold refinery output, and not 100%, the mine and scrap material that they process is only 85% – 90% of global mine production and scrap production. Therefore, the GFMS figures should be scaled back to represent this 85% to 90% range.
It is however not realistic to expect that bullion banks which supply large 400 ounce gold bars to gold refineries for conversion into smaller gold bars would use non-LBMA accredited gold refineries to do so, since a) bullion banks are all members of the LBMA, and b) the London bullion banks use Swiss gold refineries which are all on the LBMA good delivery list. They would therefore not use a more obscure non-LBMA gold refinery, such as one of the smaller Indian gold refineries, to convert large wholesale / central bank gold bars into smaller gold bars.
Therefore, what the LBMA press release in May 2016 should really have said is as follows:
“In 2014, the gold refineries on the LBMA Good Delivery List (which generate 85% – 95% of world gold refinery output) produced 4921 tonnes of gold. This was in excess of the 85% – 90% of combined gold mining production and scrap gold recycling that these refineries are known to process. The LBMA refineries’ 4921 tonnes of refinery output in 2014 in excess of their mine and scrap processing of 3646 – 3860 tonnes (85% and 90% of combined mine and scrap supply) was due to recycling of material by LBMA GD refiners converting large 400 oz bars into kilobars.”
Such a statement would then put conversion of large 400 ounce gold bars into kilogram gold bars by LBMA gold refineries in 2014 at between 1060 and 1275 tonnes of gold (4921 – 3860, and 4921 – 3646). It would also mean that large 400 ounce gold bars from existing above-ground stockpiles were topping up ‘normal’ physical gold supply (gold mining output and scrap recycling) by between 25% and 30% during 2014.
These 2014 refinery figures have previously been covered in a BullionStar posting in June 2016. See BullionStar blog “An update on LBMA Refinery Statistics and GFMS”. The important take-away point here is that in 2014 the gold refineries on the LBMA good delivery list generated refined gold output in a distinct category attributed to recycling of material by LBMA good delivery refiners converting large 400 oz bars into kilobars.
Fast forwarding now to the 2015 LBMA figures and the 2015 Thomson Reuters GFMS figures, and repeating the above calculations:
For 2015, the LBMA states that the gold refineries on its list had total refined gold output of 5034 tonnes. In 2015, according to Thomson Reuters GFMS, gold mining production was 3158 tonnes, while scrap gold supply was 1173 tonnes, i.e. a combined mine and scrap gold supply of 4331 tonnes.
Since the gold refineries on the LBMA Good Delivery List for gold represent 85% to 90% of ‘world production’, which by LBMA logic is GFMS gold mining production and GFMS scrap recycling, then, these refineries would have processed between 3681 tonnes and 3898 tonnes (85% – 95%) of mine production and scrap supply during 2015.
This then implies that during 2015, these LBMA gold refineries also processed between 1136 tonnes and 1353 tonnes of gold due to converting large 400 oz bars into kilobars.
If the LBMA had have written a press release in May 2017 to coincide with updating its table of the output of LBMA Good Delivery refineries, it should have read something like the following:
“In 2015, the gold refineries on the LBMA Good Delivery List (which generate 85% – 95% of world gold refinery output) produced 5034 tonnes of gold. This was in excess of the 85% – 90% of combined gold mining production and scrap gold recycling that these refineries are known to process. The LBMA refineries’ 5034 tonnes of refinery output in 2015 in excess of their mine and scrap processing of 3681 – 3898 tonnes (85% and 90% of combined mine and scrap supply) was due to recycling of material by LBMA GD refiners converting large 400 oz bars into kilobars, which was in the range of 1136 to 1353 tonnes.”
Where would these huge quantities of 400 ounce gold bars have come from that were melted down during 2015, predominantly or even exclusively by the Swiss gold refineries? Because 1136 to 1353 tonnes of large wholesale market gold bars is a lot of gold. The most likely source of this gold is from the London Gold Market. Beyond that, gold which was already stored in Switzerland is also a possible pool from which to draw from.
2015 UK to Switzerland Gold Exports
During 2015, Switzerland imported 1853 tonnes of non-monetary gold, and exported 1861 tonnes of non-monetary gold. By far the largest source of Swiss gold imports during 2015 was ‘the UK’, which in this case really means the London Gold Market. Non-monetary gold is just gold which is not monetary (central bank) gold. Non-monetary gold shows up on trade statistics. Monetary gold does not show up on trade statistics since central banks get an exemption from revealing physical movements of monetary gold across national borders.
During 2015, Switzerland imported 644.5 tonnes of non-monetary gold from the UK (London). You can see from the below graph that no other source country came anywhere close to supplying non-monetary gold to Switzerland in 2015, with the next largest source countries each only sending less than 70 tonnes of gold to Switzerland. And London does not have any gold mines nor any major scrap gold collection facilities.
Some of the other exporters of gold to Switzerland during 2015 were France, Germany, Italy and UAE/Dubai (none of which are gold mining countries), and South Africa, Russia, Peru (which have gold mining). Some of the gold sent from France, Germany, Italy and UAE was obviously scrap. Some of the gold sent from South Africa, Russia and Peru was most likely gold mining ore or gold doré. But somewhere within these numbers, there was also most likely good delivery gold bars. For example, why would Russia or South Africa send gold mining ore or gold doré or scrap to Switzerland when they have their own perfectly good gold refineries with huge capacity.
Surprising perhaps, the largest gold-backed ETF, the SPDR Gold Trust (GLD) did not lose that much gold during 2015, with only a net 65 tonne gold loss. This is more so because the damage to GLD’s gold holdings had really been done in mostly in 2013 and to a lesser extent in 2014 when holdings had fallen from the 1350 tonne range down to the 700 tonne range. See chart.
Based on recently released data from the Bank of England, it can be seen that during 2015 the Bank of England gold vaults lost 13.5 million ounces of gold, with Bank of England total gold holdings dropping from 167.2 million ounces at the end of 2014 to 153.6 million ounces at the end of 2015. This is equivalent to a 421 tonne loss of gold from the Bank of England vaults during 2015. All gold held in the Bank of England is in the form of Good Delivery gold bars (i.e. the large 400 ounce gold bars.
Whether gold lost from the Bank of England vaults during 2015 was central bank gold or bullion bank (commercial bank) gold is unclear since the Bank of England does not provide a breakdown of figures. It’s possible that some of this gold that left the Bank of England during 2015 was converted from monetary gold to non-monetary gold, and then sent to Switzerland to be transformed into kilogram gold bars. This would then show up in the Swiss trade statistics. If extracted from the Bank of England vaults and left as monetary gold and then exported to Switzerland, it would not show up in Swiss trade statistics.
If 644 tonnes of non-monetary gold, as per the Swiss trade statistics, were sent from London to Switzerland during 2015, and another 421 tonnes of monetary gold from the Bank of England were also sent to Switzerland during 2015, this in total would be 1065 tonnes of gold. This quantum would begin to account for the range of 1136 to 1353 tonnes being converted from 400 oz gold bars into 1 kilogram gold bars that the 2015 LBMA gold refinery statistics imply. Add in another 100 – 200 tonnes of Good Delivery bars from sources such as Russia, South Africa and Dubai and this huge scale of 400 ounce bar conversion begins to look achievable. There could also be Good Delivery bars flowing out of Swiss central bank vaults directly, i.e. the Swiss National Bank (SNB) gold vaults in Berne, which would not show up on any inbound gold trade customs statistics.
Within a 3 year period, we can see roughly that the following quantities of large gold bars were melted down into kilogram bars and sent to Asia:
2013: about 2000 tonnes of gold
2014: between 1060 and 1275 tonnes of gold
2015: between 1136 to 1353 tonnes of gold
Overall, within the 2013 – 2015 period that is about 4200 – 4600 tonnes of gold being converted into kilogram and other smaller denomination high purity gold bars and sent to markets in China, India, Hong Kong and elsewhere in Asia. This is gold above and beyond mine supply and scrap supply. Where has all of this gold come from? Some of it is proven to be from gold-backed ETFs. Some is most probably also from central bank vaults, in which case the central banks do not have the gold that they claim to have. Which everybody know anyway, as much central bank gold has been lent out and is merely a fiction on the central bank balance sheets. But there may also be other stockpiles of Good Delivery gold bars which are also feeding this huge trend. Until the LBMA begins to publish its vault statistics, any grey area unreported gold vault inventories in London are still being kept in the dark.
If the trend of raiding ETFs and borrowing central bank gold to send to Switzerland to convert into kilogram bars for the Asian markets continues, then this is not and cannot be sustainable. The question is how long it can remain sustainable, in other words when will it become unsustainable?
Infographic website Visual Capitalist recently published an eye-catching infographic on behalf of Sprott Physical Bullion Trusts which featured 4 well-known billionaire investors and their supposed investments in gold. The infographic is titled “Why the World’s Billionaire Investors Buy Precious Metals” and can be seen here.
The 4 investors profiled in the infographic are:
Jacob Rothschild (Lord), chairman of London-based investment trust RIT Capital Partners Plc
David Einhorn, president of Manhattan-based hedge fund firm Greenlight Capital
Ray Dalio, chairman and CIO of hedge fund firm Bridgewater Associates, Westport (Connecticut)
Stanley Druckenmiller, chairman and CEO of Manthattan-based Duquesne Family Office (and formerly of Duquesne Capital Management)
Overall, four very famous investors, and four names that should at least be vaguely familiar to almost anyone who has a passing interest in financial markets and investing.
For each of the 4 billionaires, the Sprott infographic provides a few quotes about their views on gold and then moves on to record their recent ‘Moves’ into ‘gold’, or in some cases their recent readjustments of existing ‘gold’ exposures.
However, the trouble with this infographic is that although it’s visually appealing, nowhere does it mention how these famous investors achieve their exposures to ‘gold’, i.e. what form their gold investments take.
This is something which is also regularly bypassed in financial media articles, especially those published by Bloomberg, articles which refer to hedge fund managers such as Druckenmiller, or John Paulson, or Ray Dalio buying ‘gold’, but which all too often are too lazy to do basic research into the actual trades that these hedge fund managers execute to acquire their positions in ‘gold’ and whether these positions are actually in real physical gold or in some form of synthetic or derivative or paper gold.
In fact, the first comment posted on the Visual Capitalist website under said Sprott infographic when it was published asks exactly this question:
“I’d like to know if they are holding physical bullion, presumably in guarded safe vaults, or just paper.”
Given that the infographic is ‘Presented by’ Sprott Physical Bullion Trusts, one might assume that Rothschild, Einhorn, Dalio and Drukenmiller are all investing in physical bullion.
But are they? This is the question I set out to answer and which is documented below. Some of my findings may surprise you.
The Rothschilds: Jacob & RIT Capital Partners
First port of call, the Rothschilds of St James’s Place in London. Given that the Rothschilds are probably the richest family in the world and have been involved in the gold market for hundreds of years, you might assume that the family of the Five Arrows knows a thing or two about the difference between real gold bars and paper gold. And presumably they do. However, no one seems to have told this to the day-to-day managers of RIT Capital Partners Plc, the Rothschild controlled investment vehicle quoted in Sprott’s infographic.
Investment trusts are actually public limited companies (Plcs) which are structured as closed-ended investment vehicles. These vehicles issue a certain number of shares that can then be publicly traded. RIT Capital Partners plc, formally called the Rothschild Investment Trust (hence the name RIT), trades on the London Stock Exchange. Jacob Rothschild (The Lord Rothschild) is chairman of RIT Capital Partners Plc.
As a publicly traded vehicle, RIT Capital Partners Plc publishes annual and half-yearly reports, and is therefore more transparent than its hedge fund brethren. RIT’s latest report, an annual report for year-end 2016, was published on 28 February 2017.
Strangely, although the Sprott infographic was only published on 7 June 2017, it quotes not from the annual report for year-end 2016 but from RIT’s half-yearly report to 30 June 2016, which was published on 15 August 2016.
The Sprott infographic states:
“In a 2016 shareholder update [Jacob] Rothschild outlined bold changes to the RIT Capital Partners’ portfolio, including…increased exposure to gold and precious metals to 8%”
Similarly, in the RIT Chairman’s Statement (page 2) of the 30 June 2016 report, Jacob Rothschild said “We increased gold and precious metals to 8% by the end of June.”
Glancing at either the Chairman’s statement or the Sprott infographic, you might think ‘ok, so RIT holds (or held) 8% of its portfolio in gold and precious metals’. However, this is not the case, a fact which becomes clear when we look at the Investment Portfolio (holdings) of RIT that are detailed in the same report.
RIT is a global investment fund whose holdings span equities, hedge fund investments, private investments, real assets, credit, and bonds. It’s ‘gold’ and ‘precious metals’ holdings are listed under ‘Real Assets’. The entire RIT portfolio is worth £2.73 billion.
The Real Assets section of the RIT report to 30 June 2016 (on page 6 of the report, page 8 of the pdf) lists relevant gold-related line items as:
“BlackRock Gold & General Fund”, described as “Gold and precious metal equities”, valued at £22.9 million, and representing 0.9% of the NAV, with a fund weight of 0.83%
“Gold Futures” with a description “Long, 6.0% notional“, valued at £7.6 million, represents 0.3% of the NAV
“Silver Futures with a description “Long, 1.2% notional” valued at £7.6 million, representing 0.0% (rounded) of the NAV
These are the only gold-related investments in the entire RIT portfolio. Therefore, could this 8% that Jacob Rothschild refers to as “we increased gold and precious metals to 8% by the end of June” be a combination of a 6% notional long on gold futures, a 1.2% notional on long silver futures, and a 0.8% fund weight in gold mining equities through the BlackRock Gold & General Fund holding?
In short, the answer is Yes.
Firstly, looking at the BlackRock Gold & General Fund, this is a UCITS equity fund which exclusively invests in the shares of gold and silver mining companies such as Newcrest, Newmont, and GoldCorp and which is benchmarked against the FTSE Gold Mining Index (an equity index). However, the BlackRock website reminds us that “The Fund does not hold physical gold or metal.” Like all equity investments, this fund exposes its holders to equity risk, currency risk, sectoral risks (in this case the mining sector), possible gold hedging risks, and the general corporate risks that come with stock specific investing in any publicly quoted company, some of which cannot be diversified through portfolio investing.
Next up are the precious metals futures line items. In investment portfolios, notional is literally the gross exposure of a position. In this case, the RIT portfolio being long 6.0% notional in gold futures just means that the portfolio’s notional exposure to gold (via the gold futures position) represented (on 30 June 2016) an amount which was 6.0% of the total (gross) exposure of the portfolio. This is also a leveraged position since it was acquired via the purchase of exchange traded futures and the maintenance of these futures via margin. The amount reflected in the NAV for this position just refers to the margin.
I also checked with RIT investors relations as to whether Jacob Rothschild, when he stated that RIT holds gold, was actually referring to these gold futures positions. RIT investor relations responded:
“Yes, we do refer to long gold futures exposure as “holding gold”. We take this view since we are confident that gold futures are acting as a suitable proxy for gold both from a regulatory perspective and in terms of where we are in the cycle.
However, it should be clear to all that holding gold futures is not the same thing as holding vaulted physical gold. Gold futures may provide exposure to the US Dollar price of gold, but that’s about it, and even if they can be theoretically exercised into physical gold on the COMEX or ICE platforms, no one uses them for this purpose. For example, only 0.04% of COMEX gold futures contracts result in physical delivery each year.
Gold futures also entail exchange risk, risk of not being able to exercise for delivery, margin risk, forced cash settlement risk, etc etc. Gold futures are also derivatives that can come into existence in massive quantities as long as there are counterparties to take the other side of the futures trades.
Allocated physical gold on the other hand is an asset which exists in limited quantities, has no counterparty risk, has intrinsic value and has been used as money and as a store of value for thousands of years.
The “regulatory perspective” that RIT refers to just seems to mean that the fund’s exposure ticks various compliance boxes and is an acceptable security from a compliance and regulatory perspective.
The “where we are in the cycle” phrase probably refers to the interest rate cycle in terms of interest rate movements, inflation, real interest rates etc, but surely this is irrelevant because if you really believe that gold futures prices are a perfect proxy for gold prices, then the existence of a “cycle” and the phases of such a cycle become irrelevant to the investment decision?
In summary, it should be clear that RIT Capital Partners Plc does not hold any gold or other precious metals, because it merely holds gold futures and units in a BlackRock fund which itself only holds gold and silver equities (common shares) and which does not hold physical gold.
Just for completeness, let’s turn to the latest annual report from RIT for year-end 2016 that Sprott did not refer to. Has anything changed compared to 30 June 2016? At year-end 2016, according to Jacob Rothschild:
“We continue to hold gold and gold mining shares amounting to 6% of the portfolio.“
Therefore, by the end of 2016, by RIT’s logic, it now had a 6% exposure to gold (and the exposure to silver futures had disappeared). However, as per the 6 month earlier period, this was really a) exposure to the US dollar price of gold via gold futures and b) an exposure to the common equity of publicly-traded gold mining companies through the BlackRock fund investment.
In the Real Assets section of the RIT annual report (page 13 of the report, page 15 of the pdf), it lists:
“BlackRock Gold & General Fund”, with a description “Gold and precious metal equities” valued at £20.3 million, representing 0.9% of the NAV, and with a fund weight of 0.7%
“Gold Futures” with a Description “Long, 5.7% notional” representing (0.2%) of the NAV
Again, the 6% Rothschild reference includes the 5.7% long notional on gold via the gold futures, the BlackRock fund with a weight of 0.7%, and possibly the (0.2%) NAV (margin), which altogether net to approximately 6% when rounded down. Since 8% sounds better than 6%, Sprott may have chosen to reference the 30 June 2016 RIT report and not the more recent 30 December 2016 RIT report as this would make Rothschild appear more bullish on gold.
David Einhorn and Greenlight Capital
Hedge funds by their nature are very secretive, and because they are private pools of capital, they have no obligation to report detailed holdings even to their clients, let alone to the general public. Some of the justifications for hedge fund secrecy include preventing other trading parties adversely trading against them and preventing competitors replicating their positions. Note, hedge funds still have to report equity holdings to the US SEC and they do this via their quarterly 13F form submissions, which can be viewed on the SEC EDGAR website about 6 weeks after quarter end.
Sometimes hedge fund stars will drop hints about some of their positions or engage with the financial media, but this is mainly to talk their positions and trading books up. Often however, the “partner letters” (similar to shareholder letters) that hedge fund partnerships send to their clients / investors will give some indication as to their positions and asset allocations, and for whatever reason, some of these letters seem to make it into the public domain pretty quickly. Note that most hedge funds are established as Limited Liability Companies (LLCs), a structure which supports the partnership model.
Following Jacob Rothschild, next up on the Sprott infographic is hedge fund manager David Einhorn and his Greenlight Capital hedge fund firm. Greenlight, as a hedge fund firm, runs a series of funds that invest in equity, debt etc but also include global macro and that are known as the “Greenlight Capital funds” a.k.a. “The Partnerships”. There are at least 6 funds in this group, maybe more.
The Sprott infographic refers to a recent gold-related ‘Move’ that Einhorn that made as follows:
“In early 2017, Einhorn mentioned on an earnings call that he was:…Keeping gold as a top position”
“Gold remains a long-term position with a thesis that global fiscal and monetary policies remain very risky”
So we can assume that Einhorn maintains a gold exposure of some sort. Since there was no information in the above partner letter as to what exactly Greenlight refers to as a gold position, and nothing that I could find on the web, I did what any junior Bloomberg reporter should but doesn’t do, and shot off an email to Greenlight asking how Greenlight Capital attains its long gold exposure? Surprisingly, or maybe not, within about 20 minutes Greenlight answered with a short and sweet one-liner:
“We hold physical allocated gold in all our funds.”
This response came from the top of the Greenlight tree, close to Einhorn. Hint David Einhorn only follows three accounts on Twitter, one of which is Donald Trump another of which is the Einhorn Trust. So now we know that at least one major hedge fund firm holds physical allocated gold.
On a side note, Greenlight also offers two funds called Greenlight Capital (Gold), LP and Greenlight Capital Offshore (Gold), Ltd. These two funds actually offers investors a gold class which denominates investments in that class in gold rather than USD. This is similar to a USD denominated fund offering shareholders a EUR or CHF class, the only difference being that this class is in gold.
Ray Dalio and Bridgewater
Bridgewater Associates, based in Westport in Connecticut, runs some of the largest and most well-known individual hedge funds such as the global macro Pure Alpha as well as other well-known funds called ‘The All Weather’ and ‘Pure Alpha Major Markets’. Ray Dalio is founder, chairman and chief investment officer (CIO) of Bridgewater.
In the Sprott infographic, the gold ‘Move’ which they chose to highlight Dalio for was that:
“In 2016, Dalio said it is prudent to have a ‘well-diversified portfolio’ that is 5-10% gold”
However, unlike the other investors profiled, i.e. Rothschild, Einhorn, and Druckenmiller, who had investment decisions attributed to them that involved taking or extending long positions, there is nothing, at least in the infographic, that refers to Dalio taking on or amending a gold position.
“And so gold is one of the currencies. So we have dollars, we have euros, we have yen and we have gold.”
“Now, it [gold] doesn’t have a capacity — the capacity of moving money into gold in a large number is extremely limited.”
“I think … there’s no sensible reason not to have some — if you’re going to own a currency, … it’s not sensible not to own gold”
“I don’t want to draw an inordinate amount of attention to gold”
“a certain limited amount, at least passably, should be in gold, just like you would hold a certain amount in cash”
“Now, it depends on the amount of gold, but if you don’t own, I don’t know, 10 percent in — if you don’t have that and then it depends on the world, then you — then there’s no sensible reason other than you don’t know history and you don’t know the economics of it.”
Dalio frequently, in various forums, demonstrates his understanding of the historical importance of gold in the monetary system. Based on the language that Dalio uses about capacity of the gold market and his appreciation of the history of gold, my hunch is that Bridgewater does hold physical gold in a similar manner to how Greenlight Capital holds gold.
Although it is quite tricky to contact Bridgewater, I did manage to find Dalio’s email (somehow or other) and like an aspiring Bloomberg reporter (or not), I shot off an email to Dalio asking:
“DoesBridgewater hold physical gold in its funds (e.g. Pure Alpha, All Weather, and Pure Alpha Major Markets) or some other type of long gold exposure?”
The same day, I received back an automated response:
Message from "Ray Dalio"
I recognize from your email address that this is the first message I have received from you since Bridgewater Associates began using Sender Address Verification (SAV).
Your message is very important to me. Like you, we are very concerned with stopping the proliferation of spam. We have implemented Sender Address Verification (SAV) to ensure that we do not receive unwanted email and to give you the assurance that your messages to me have no chance of being filtered into a bulk mail folder.
By pressing REPLY and SEND to this message your original message will be delivered to the top of my inbox. You need only do this once and all future emails will be recognized and delivered directly to me.
However, after replying as per the instructions above using the verification address, there was no further response from Bridgewater. Maybe he is on vacation!
So the jury is still out on how Bridgewater acquires its exposure to gold, assuming that its funds actually have exposure to gold. But my guess is that at least some of Bridgewater’s funds do hold gold, and probably hold real physical allocated gold.
Stanley Druckenmiller and Duquesne
Finally, the Sprott infographic features Stanley Druckenmiller, founder and former chairman and president of Pittsburgh-based Duquesne Capital Management, and also former portfolio manager of Soros’ Quantum Fund. In 2010, ‘Stan’ Druckenmiller wound down Duquesne Capital since he claimed it was becoming harder to deliver consistently high returns, but he continued to manage his own wealth through Duquesne Family Office LLC, which is based out of Manhattan.
According to the infographic, in early 2017 Druckenmiller said:
“Gold was down a lot, so I bought it.”
Stan Druckenmiller, Duquesne
This quote was reported in a 8 February 2017 Bloomberg article which itself was based on a CNBC interview from 7 February:
“I wanted to own some currency and no country wants its currency to strengthen,” Druckenmiller said Tuesday in an interview. “Gold was down a lot, so I bought it.”
As per usual, Bloomberg doesn’t bother to find out or mention what form of gold exposure Druckenmiller was referring to in that interview.
Strangely, Bloomberg says that Druckenmiller bought gold in late December and January having previously sold his ‘gold’ on election night in November when Trump was elected. I say strangely because Druckenmiller is known for getting his US dollar ‘gold exposure’ via the gold-backed ETF the SPDR Gold Trust (GLD) however, the Duquesne Family Office 13F filings with the SEC don’t show GLD activity in Q4 2016 or Q1 2016.
Looking at recent Duquesne Family Office 13F filings which show reportable equity holdings (including GLD since GLD is a listed security and is basically like a share), the last time Duquesne Family Office had a long exposure to the SPDR Gold Trust was in Q1 2016 when it held 2,016,000 call options on the SPDR Gold Trust (Cusip 78463V907) which at the time had a notional exposure of $237.16 million. Druckenmiller had purchased 2,880,000 call options on GLD during Q2 2015 but reduced this to 2,016,000 calls during Q1 2016. Duquesne has not held any SPDR Gold Trust shares or options since Q1 2016.
However, looking at the Duquesne 13F filings for Q3 2016, Q4 2016 and Q1 2017, there are some interesting changes in reported holdings of some gold mining equities over this period.
The timing of Druckenmiller saying that he sold his ‘gold’ on election night in November 2016 and the bought gold in late December 2016 and January 2017 fits very well with the Duquesne trades of selling Barrick Gold and Agnico Eagle so that they appeared in the Q3 13F, but not in the Q4 13F and then reappeared in the Q1 2017 13F. If this is the case, then Druckenmiller’s Duquesne does not hold gold but holds gold mining equities, and Druckenmiller’s recent references to buying gold are really references to holding common shares in publicly-traded gold mining companies.
Duquesne, however, could hold other ‘gold exposures’ such as gold futures or even real physical allocated gold. But due to the non-obligation of these investment pools to report holdings, this is unclear.
I also sent an email to Stan Druckenmiller at his Duquesne address, asking him:
“Does Duquesne Family Office hold physical gold as part of its exposure to gold within its investments, or is the exposure some other type of long gold exposure such as the gold-backed ETF GLD?”
However, as of the time of writing, Druckenmiller has not responded.
Druckenmiller’s gold exposure via GLD calls between Q2 2015 and Q1 2016 also deserves some commentary. Readers of this website will know that holding a gold-backed ETF such as GLD is not the same as owning real physical gold. Although the Trust behind GLD holds gold bars, GLD units just provide exposure to the US dollar price of gold and there is no conversion option into real gold. With GLD, the holder is a shareholder and not a gold holder. There are many other concerns with GLD, all of which are documented on a BullionStar infographic.
However, Duquesne’s ‘exposure’ is even one more step removed from gold since it was in the more of a derivative (call option) on an underlying (GLD) which itself does not provide ownership of any gold to the holder. So in some ways this could be called a second order derivative.
Paulson & Co
Although Sprott’s infographic doesn’t feature John Paulson of hedge fund firm Paulson & Co, maybe it should have. However, on second thoughts maybe not, because Paulson & Co is currently the 6th largest institutional holder of SPDR Gold Trust (GLD) shares, which as explained above, is not the same as owning real physical gold. According to its latest 13F filing, Paulson & Co holds 4,359,722 GLD shares worth a sizeable $500 million.
Paulson also launched a specific gold fund in 2010 which is now called the PFR Gold Fund, named after Paulson, and the two managers who used to run the fund, namely, Victor Flores and John Reade, hence the PFR. Reade has now left Paulson & Co, and moved to the World Gold Council (WGC), which derives the majority of its revenue from…wait for it….the SPDR Gold Trust, since WGC’s 100% owned subsidiary World Gold Trust Services is the sponsor of the GLD.
RIT Capital Partners Plc claims to hold gold but really holds a) gold futures which provide notional long gold exposure and b) a BlackRock fund which invests in gold mining shares.
Greenlight Capital holds allocated gold in all of its hedge funds (and they are good about replying to emails).
Bridgewater Associates probably holds gold exposure across at least some of its funds. Given Ray Dalio’s grasp of the importance of real physical gold, I would be surprised if Dalio’s funds do not hold real physical gold. But Dalio is a hard man to track down, so the jury is still out on this one.
Stan Druckenmiller’s Duquesne Family Office had a large exposure to the SPDR Gold Trust via call options in 2015 and early 2016 but then closed this exposure. Duquesne also invests in gold mining equities Barrick Gold and Agnico Eagle Mines, and this could be what Druckenmiller is referring to when he said he sold and then bought back gold.
Paulson is a big fan of the SPDR Gold Trust, a vehicle which is in no way the same as owning physical gold, because it merely provides exposure to the US dollar price of gold.
In 2016, withdrawals of gold from the Shanghai Gold Exchange totalled 1970 tonnes, the 4th highest annual total on record. This was 24% less than SGE gold withdrawals recorded in 2015, which reached a cumulative 2596 tonnes (See Koos Jansen’s 6 January 2017 blog at BullionStar “How The West Has Been Selling Gold Into A Black Hole” for more details of the 2016 withdrawals).
SGE gold withdrawals are an important metric in the physical gold market because SGE gold withdrawals are a suitable proxy for approximating Chinese wholesale gold demand. This proxy functions well because China’s domestic gold mining production, Chinese gold imports, and most Chinese gold scrap are all sold on the Shanghai Gold Exchange. As a reminder, gold withdrawals from the SGE means actual physical gold bars withdrawn from the SGE’s network of 62 approved precious metals vaults in 35 cities across China. (See “The Mechanics Of The Chinese Domestic Gold Market” for a discussion of why this proxy works).
2017 SGE Gold Withdrawals
Year-to-date, which now includes the first four months of 2017, SGE gold withdrawals have reached 727 tonnes, which annualized equals 2181 tonnes, and would make 2017 the 3rd highest SGE vault withdrawal year on record, and only slightly behind the 2197 tonnes of registered withdrawals from the Exchange’s vaults in 2013. And since SGE gold withdrawals are a suitable proxy for wholesale Chinese gold demand, it would point to 2017 shaping up to be one of the strongest years ever for physical gold demand in the Chinese gold market.
SGE Gold Withdrawals 2008 – 2017. The 2017 figure reflects January – April inclusive. Source:www.GoldChartsRUS.com
With two-thirds of the year still to play out, annualised estimates of year-to-date gold withdrawal figures will always be approximations and will change when each successive month’s figure is added.
For example, January 2017 gold withdrawals of 184.4 tonnes suggested an annualised withdrawal figure of 2213 tonnes. February’s withdrawals as per published SGE data came in at 179.2 tonnes, implying an annualised figure of 2182 tonnes. As monthly withdrawals increased in March to 192.2 tonnes, this edged the annual estimate up to 2224 tonnes. But coincidentally, April’s SGE gold withdrawal figure brought the annual estimate back to ~2182 tonnes. This was so because combined gold withdrawals for January and February exactly equaled combined withdrawals for March and April, in both cases 363 tonnes over the two consecutive two month periods.
January + February = 184+179 = 363 tonnes
March + April = 192+171 = 363 tonnes
There is also a data discrepancy worth pointing out with the Shanghai Gold Exchange’s gold withdrawal figures for 2017. This discrepancy relates to the fact that the monthly withdrawal numbers for the 4 month period from January to April do not add up to the cumulative gold withdrawal figure for 2017 as published elsewhere on the Exchange’s website.
SGE gold withdrawals for January to April inclusive summate to exactly 727.073 tonnes.
However, in the latest (April) edition of the SGE’s monthly “Data Highlights” report, which is published in English, it states that cumulative withdrawal volume inclusive of April totalled 771.973 tonnes, which is 44.9 tonnes higher than the figure implied by the summation of the 4 individual months’ figures.
This data discrepancy has been present in the ‘Data Highlights’ report each month since February. For example, at the end of February 2017, the combined monthly withdrawals of January (184.412 tonnes) and February (179.237 tonnes) were 363.649 tonnes, but the ‘Data Highlights’ report for February stated that the cumulative withdrawal total for those two months was 378.649 tonnes. This is exactly 15 tonnesmore than the two months combined would suggest. So, it seems that there is a data issue somewhere in SGE record keeping, especially given the rounded figure nature of the discrepancy number.
The SGE March report also had an error when the monthly totals for January – March pointed to gold withdrawals of 555.899 tonnes , while the March ‘Data Highlights’ listed cumulative gold withdrawals of 524.899 tonnes, in this case exactly 31 tonnesless than the summation of the 3 monthly figures would suggest. Again, the rounded figure nature of the discrepancy number suggests a data issue somewhere in the SGE reporting system.
Until the SGE clarifies the discrepancy, its best to go with the summation of the individual month’s withdrawal figures while awaiting feedback from the Exchange.
The above chart plots cumulative gold withdrawals for the 4 months to end of April compared to similar periods in previous years, and again shows that 2017 looks set to be one of the strongest years for Chinese gold demand on record. The cumulative gold withdrawals of 727 tonnes for the January to April timeframe are the 2nd highest ‘Month 1-4’ cumulative figure on record, with only 2015 higher, when the similar figure came in at 821 tonnes.
Beginning last November and persisting into December 2016, the SGE gold price and the International gold price (as expressed in Yuan) began to diverge with the SGE gold price trading significantly higher. This created a noticeable and rapidly rising premium in the SGE gold price, and at one point in mid December this premium was $40 per ounce higher than, or over 3% above the international gold price.
This phenomenon was at the time attributed to the introduction by the Chinese authorities of more stringent restrictions on gold imports in an effort to reduce currency outflows. For example, Reuters, citing trader sources, wrote on 9 December 2016 that China was “curbing gold imports in [a] bid to limit yuan outflow”.
There were also rumours in the gold market at that time that a number of banks that had been authorised to import gold into China had lost their import licences (or that their licenses had not been renewed), and that the People’s Bank of China was also becoming stricter on the quotas of gold that it would allow banks to import in a given consignment. However, when BullionStar asked the SGE about this in December, the SGE did not reply.
Only 13 banks are authorised to import gold into China, 10 of which are local Chinese banks, and the other 3 of which are the foreign banks HSBC, ANZ and Standard Chartered.
In theory, an expansion in the SGE price premium could have been caused by a combination of limited supply or higher demand, or both. The below chart for 2016 (lower panel) illustrates the emergence of this premium in early November, with the premium rising rapidly from less than 0.5% at that time to nearly 3.5% at one point in December, but still ending the year in the 2% range. The upper panel of the chart show that same phenomenon only in terms of the relative prices of the SGE and International gold prices.
In contrast, for the 10 months of 2016 that preceded November, the premium of the SGE price to the International price was persistently very low and static from January to October 2016.
Fast forwarding to 2017, the most interestingly observation of the SGE premium since the November-December timeframe is that although the premium dropped sharply in January from the 2% range down to the 0.4% range by January month-end, it resumed a uptrend in February before spiking up noticeably again during March to levels approaching those seen in November and December.
In the case of March, it appears that premiums rose again for the very same reason that was attributed to the sharp rise in late 2016, i.e. the re-emergence of supply constraints brought on by more stringent gold import restrictions. According to Reuters in an article on the subject dated 17 March in which it quoted a Hong Kong based trader saying that:
“imports are happening, but with some restrictions. The government has been doing this since November to control the capital outflows. Now, it is becoming a bit aggressive with stringent reviews”
“The quotas are reviewed regularly and extended on a case by case basis.”
Although premiums shrank after mid-March and returned to the 1% level, they oscillated in the 1% to 0.5% range until mid-April and since then have resumed a steady rise to the 1% level, which is a very different chart to the one that persisted for most of 2016.
It therefore seems that the impact of tighter import restrictions that appeared in November and December of last year and which the rising premiums reflected was not a transitory phenomenon but instead has become a persistent feature of the Chinese gold market.
And what does this say about the Chinese authorities’ plans to liberalise the Chinese gold market since more restrictive import quotas and rules appear to be doing the opposite by undermining some of the liberalisation steps that had already been underway?
An article in February on BullionStar’s website titled “A Chink of Light into London’s Gold Vaults?” discussed an upcoming development in the London Gold Market, namely that both the Bank of England (BoE) and the commercial gold vault providers in London planned to begin publishing regular data on the quantity of physical gold actually stored in their gold vaults.
Critically, this physical gold stored at both the Bank of England vaults and the commercial London vaults underpins the gargantuan trading volumes of the London Gold Market and the same market’s ‘liquidity’. Therefore, a new vault holdings dataset would be a very useful reference point for relating to London’s ‘gold’ trading volumes as well as relating to data such as the level and direction of the gold price, the volume of gold held in gold-backed Exchange Traded Funds (ETFs), UK gold import and export statistics, and Swiss and Hong Kong gold imports and exports.
The impending publication of this new gold vault data was initially signalled by two sources. Firstly, in early February, the Financial Times (FT) wrote a story claiming that the London Bullion Market Association (LBMA) planned to begin publishing 3 month lagged physical gold storage data for the entire London gold vaulting network, that would, according to the FT:
“show gold bars held by the BoE, the gold clearing banks, and those [vaults] operated by the security companies such as Brink’s, which are also members of the LBMA.”
The “gold clearing banks” are the bullion bank members of London Precious Metals Clearing Limited (LPMCL), namely, HSBC, JP Morgan, ICBC Standard Bank, Bank of Nova Scotia – Scotia Mocatta, and UBS. HSBC and JP Morgan operate precious metals vaults in London. See profile of JP Morgan’s London vault and a discussion of the HSBC vault . ICBC Standard Bank also maintains a vault in London which is operated on its behalf by Brinks.
The second publication to address the new gold vault data was the World Gold Council. On 16 February, addressing just the Bank of England vaults, the World Gold Council wrote in its Gold Investor publication that:
“The Bank of England is, for the first time, publishing monthly data revealing the amount of gold it holds on behalf of other central banks.”
“The data reveals the total weight of gold held within the Bank of England’s vaults and includes five years of historical data.”
While I had been told by a media source that the London vault data would be released in the first quarter of 2017, at the time of writing, there is still no sign of any LBMA vault holdings data covering the commercial vault operators in London. However, the Bank of England has now gone ahead and independently released its own numbers covering gold held in the Bank of England gold vaults. These gold vaults, of which there are between 8 – 10 (the number fluctuates), are located on the 2 basement levels of the Bank of England headquarters in the City of London.
In an updated web page on the Bank of England’s website simply titled ‘Gold’, the Bank of England has now added a section titled ‘Bank of England Gold Holdings’ and has uploaded an Excel spreadsheet which contains end-of-month gold holdings data covering every month for a 6-year period up to the end of December 2016, i.e. every month from January 2011 to December 2016 i.e. 72 months.
According to the Bank of England, the data in the spreadsheet shows:
“the weight of gold held in custody on the last business day of each month. We publish the data with a minimum three-month lag.
Values are given in thousands of fine troy ounces. Fine troy ounces denote only the pure gold content of a bar.
We only accept bars which comply with London Bullion Market Association (LBMA) London Good Delivery (LGD) standards. LGD bars must meet a certain minimum fineness and weight. A typical gold bar weighs around 400 oz.
Historic data on our gold custody holdings can be found in our Annual Report.”
Prior to this spreadsheet becoming available, the Bank of England only ever divulged gold vault quantity data once a year within its Annual Report, for year-end reporting date end of February.
You will appreciate that the new spreadsheet, having data for every month of the year, and for 72 months of data retrospectively, conveys a lot more information than having just one snapshot number per year in an annual report. Therefore, the Bank of England has gone some way towards improving transparency in this area.
Before looking at the new data and what it reveals, it’s important to know what this data relates to. The Bank of England provides gold custody (storage) services to both central banks and a number of large commercial banks. Large commercial banks which trade gold are commonly known as bullion banks, and are mostly the high-profile and well-known investment banks.
On its gold web page, the Bank highlights this fact – that it provides gold custody service to both central banks and commercial banks:
“We provide safe custody for the United Kingdom’s gold reserves, and for other central banks. This supports financial stability by providing central banks with access to the liquidity of the London gold market.
We also provide gold accounts to certain commercial firms that facilitate access for central banks to the London gold market.”
In the London Gold Market, the word “liquidity” is a euphemism for gold loans, gold swaps, and gold trading including gold sales. This reference to central banks accessing the London Gold Market as being in some way supportive of ‘financial stability’ is also an eye-opener, since reading between the lines, the Bank of England is conceding that by accessing the London Gold Market’s “liquidity” via bullion banks, these central bank clients are either contributing to direct stabilisation of the gold price in some shape or form, or else are using their gold operations to raise foreign currencies for exchange rate intervention and/or system liquidity. But both routes are aiming at the same outcome. i.e. stability of the financial system.
At the end of the day, the gold price has always been a barometer that central banks strive to keep a lid on and which they aim to stabilise or smoothen the gyrations of, given that the alternative – a freely formed and unmanipulated gold price – would thwart their coordination of fiat currency exchange rates, interest rates and inflation targets.
Interestingly, in addition to the new spreadsheet of gold holdings data, the Bank of England gold web page now includes a link to a new 1 page ‘Gold Policy’ pdf document, which, looking at the pdf document’s properties, was only created on 30 January 2017. This document therefore also looks like it was written in conjunction with the new gold vault data rollout.
The notion of central banks accessing the liquidity of the London Gold Market via bullion banks is further developed in this Gold Policy document also. The document is quite short and merely states the following:
“GOLD ACCOUNTS AT THE BANK OF ENGLAND
1. The Bank primarily offers gold accounts to central bank customers. This is to support financial stability by providing central banks with secure custody for their gold reserves and access to the liquidity of the London gold market (particularly given the Bank’s location).
2. To facilitate, either directly or indirectly, access for central banks to the liquidity of the London gold market, the Bank will also consider providing gold accounts to certain commercial firms. In deciding whether to provide an account, the Bank will be guided by the following criteria.
a. The firm’s day to day activities must support the liquidity of the London gold market. b. Specifically, the Bank may have regard to a number of factors including but not limited to: evidence of active or prospective trading with a central bank customer; or whether the firm has committed to honour buy and sell prices.
3. Access to a gold account remains at the sole discretion of the Bank.
4. The Bank will review this policy periodically.”
The Vault Data
Nick Laird has now produced a series of impressive charts of this new Bank of England data on his website GoldChartsRUS. Plotting the series of 72 months of gold holdings data over January 2011 to December 2016 yields the below chart.
On average, the Bank’s vaults held 5457 tonnes of gold over this 6 year period. The minimum amount of gold held was 4693 tonnes at the end of March 2016, while the maximum quantity of gold held was 6250 tonnes at the end of February 2013.
The overall trend in the chart is downward with a huge outflow of gold bars from the bank’s vaults from the end of February 2013 to the end of March 2016.
As of January 2011, the BoE held just over 5500 tonnes of gold bars in its vaults. Gold holdings rose until the end of August 2011 and peaked at nearly 5900 tonnes before falling to 5600 tonnes at year-end 2011. Overall in 2011, the holdings fluctuated in a 400 tonne range, trending up during the first 8 months, and down during the latter 4 months.
This downtrend only lasted until January 2012, at which point BoE gold holdings totalled about 5450 tonnes. For the remainder of 2012, BoE gold under custody rose sharply, reaching 6200 tonnes by the end of 2012, a level near the ultimate peak in this 6 year chart. The year 2012 was therefore a year of accumulation of gold bars at the Bank during which 750 tonnes were added.
The overall maximum peak was actually 6250 tonnes at the end of February 2013, after which a sustained downtrend evolved through the remainder of 2013. By December 2013, gold under custody at the Bank of England had fallen to 5670 tonnes, creating an overall outflow of 580 tonnes of gold bars during 2013.
The outflow of gold continued during 2014 with another 470 tonnes flowing out of the Bank, leading to end of year 2014 gold holdings of just 5200 tonnes. The outflow also continued all through 2015 with only 4780 tonnes of gold in custody at the end of December 2015. The Bank therefore lost another 440 tonnes of gold bars in 2015.
Overall, that makes an outflow of 1490 tonnes of gold from the Bank’s vaults over the 3 years from 2013 to 2015 inclusive. This downtrend lingered for 3 more months, with another 80 tonnes lost, which brought the end of March 2016 and end of April 2016 figures to a level of about 4700 tonnes, which is the overall trough on the chart. It also means that there was a net outflow of 1570 tonnes of gold bars from the Bank’s vaults from the end of February 2013 to the end of March / April 2016.
A new uptrend / inflow trend began at the end of April 2016 and continued to the end of November 2016, where gold custody holdings peaked again at about 5123 tonnes before levelling off at the end of December 2016 at 5102 tonnes. Therefore, from the end of April 2016 to the end of December 2016, the Bank of England vaults added 400 tonnes of gold bars.
The gold holdings of the vast majority of central banks have remained stagnant over the 2011 – 2016 period, the exceptions being the central banks of China and Russia. But Russia buys domestically mined gold and stores it in vaults in Moscow and St Petersburg, so this would not affect gold holdings at the Bank of England. China’s central bank, the People’s Bank of China (PBoC), is known to buy its gold on the international market, including the London Gold Market. It then monetizes this gold (classifies it as monetary gold), and airlifts it back to China. But these Chinese purchases don’t show up in UK gold exports because monetary gold is exempt from trade statistics reporting. However, if China was surreptitiously buying gold from other central banks with gold accounts at the Bank of England or buying gold from bullion banks with gold accounts at the BoE, then some of the gold outflows from the BoE could be PBoC gold purchases. But without central bank specific data, its difficult to know.
But what is probably true is that the fluctuations in the quantity of gold stored in the Bank of England vaults are more do to with the gold holdings of bullion banks and less to do with the gold holdings of central banks, for the simple reason that central bank gold holdings are relatively static, or the least the central banks claim that their gold holdings are static. This does not take into account the gold lending market which the central banks and bullion banks go to great lengths to keep secret.
There is also a noticeable positive correlation between the movement of the US Dollar gold price and the inflows/outflows of gold to and from the Bank of England vaults, as the above chart demonstrates.
Bullion Bank gold accounts at the BoE
One basic piece of information that the Bank of England’s new vault storage data lacks is an indication of how many central banks and how many commercial banks are represented in the data.
In its first quarterly report from Q1 2014,the Bank of England states that 72 central banks operate gold accounts at the bank of England, a figure which includes a few official sector organisations such as the International Monetary Fund (IMF), European Central Bank (ECB), and Bank for International Settlements (BIS). This number would not have changed much in the meantime, so we can assume that the gold holdings of about 72 central banks are represented in the new data. But the number of commercial banks holding gold accounts at the Bank of England is less clear-cut.
The 5 gold clearing banks of the LPMCL all hold gold accounts at the Bank of England. Why? Because it says so on the LPMCL website:
“Each member of LPMCL has vaulting facilities under its control for the storage of gold and/or silver, plus in the case of gold bullion, account facilities at the Bank of England, which have contributed to the development of bullion clearing in London.”
The LPMCL also states that its clearing statistics include:
“Transfers over LPMCL Clearing Members’ accounts at the Bank of England.”
Additionally, the LPMCL website states that their
“clearing and vaulting services help facilitate physical precious metal movement logistics, location swaps, quality swaps and liquidity management.”
The Bank of England’s reference in its new ‘Gold Policy’ document to commercial banks needing to be “committed to honour buy and sell prices” is a reference to market makersand would cover all 13 LBMA market makers in gold, which are the 5 LPMCL members and also BNP Paribas, Citibank, Goldman Sachs, Merrill Lynch, Morgan Stanley, Société Générale, Standard Chartered Bank, Toronto-Dominion Bank. But there are also gold trading banks that make a market in gold which are not officially LBMA market makers, such as Commerzbank in Luxembourg which claims to be one of the biggest bullion banks in the world.
So I would say that lots of other bullion banks (of which there about 40 in total) have gold accounts at the Bank of England in addition to the 13 official LBMA market makers.
More fundamentally, any bullion bank that is engaged in gold lending with central banks (the central banks being the lenders and the bullion banks being the borrowers) would need a gold account at the Bank of England. I counted 28 bullion banks that have been involved with borrowing the gold of just one central bank, the central bank of Bolivia (Banco Central de Bolivia – BCB) between 1998 and 2016. Some of these banks have since merged or exited precious metals trading, but still, it gives an estimate of the number of bullion banks that have been involved in the gold lending market. The Banco Central de Bolivia’s gold lending activities will be covered in some forthcoming blog posts.
Bullion banks that are Authorised Participants (APs) for gold-backed ETFs such as the SPDR Gold Trust (GLD) or iShares Gold Trust (IAU) may also have gold accounts at the Bank of England. I say may have, because in practice the APs leave it up to the custodians such as HSBC and JP Morgan to allocate or deallocate the actual physical gold flowing in and out of the ETFs, but HSBC on occasion uses the Bank of England as a sub-custodian for GLD gold (see “SPDR Gold Trust gold bars at the Bank of England vaults” for details), so if some of the APs want to keep their own stash of allocated physical gold in relation to ETF trading, it would make sense for them to have a gold account at the Bank of England.
As to how much gold the GLD stores at the Bank of England and how regularly this occurs is still opaque because the SEC does not require the GLD filings to be very granular, however there is a very close correlation between inflows and outflows from GLD and the inflows and outflows from the Bank of England vaults, as the following chart clearly illustrates.
As gold was extracted from the GLD beginning in late 2012, a few months later the Bank of England gold holdings began to shrink also. This trend continues all the way through 2013, 2014 and 2015. Then as the amount of gold began to increase in the GLD at the end of 2015, the gold holdings at the Bank of England began to increase also. Could this be bullion banks extracting gold from the GLD, then holding this gold at the Bank of England and then subsequently exporting it out of the UK?
Some of it could, but UK gold net exports figures suggest that gold was withdrawn from both the Bank of England vaults and from the ETF gold stored at commercial gold vaults (run by HSBC and JP Morgan), after which it was exported.
Looking at the above chart which plots Bank of England gold holdings and UK gold imports and exports (and net exports) is revealing. As Nick Laird points out in this chart, over the 2013 to 2015 period during which the Bank of England gold holdings fell by 1500 tonnes, there were UK net gold export flows of 2500 tonnes, i.e. 2500 tonnes of gold flowed out of London gold vaults, so an additional 1000 tonnes had to come from somewhere apart from the Bank of England vaults.
The new monthly vault holdings data from the Bank of England can now also be compared to the amount of gold reported by the Bank of England in its annual reports. The figures the Bank reports in the annual report are as of the end of February. These figures are only reported in Pounds Sterling, not quantities, so they need to be either converted to USD and divided by the USD LBMA Gold Price on the last day of February, or else just divided by the GBP LBMA Gold Price on that day.
For end of February 2015, the calculated total for gold held at the Bank of England (based on the annual report) came out at 5,134 tonnes. Now the Bank of England data says 5126 tonnes which is very close to the calculation. For February 2016, the calculation came out at 4725 tonnes. The new Bank of England data now says 4730 tonnes, so that’s pretty close also.
This new Bank of England data is welcome and the Bank of England has taken a step towards greater transparency. However, it would be more useful if the Bank published a breakdown of how much of this gold is held by central banks and how much is held by bullion banks, along with the number of central banks and number of bullion banks that the data represents. Two distinct sets of data would be ideal, one for central bank custody holdings and the other for bullion bank custody holdings. The Bank most likely would never publish two sets of data as it would show bullion bank gold storage activity for the whole world to see.
While the Bank of England has now followed through with its promise to publish its gold vault holdings, the LBMA has still not published gold vault data for the commercial gold vault providers, i.e. its members HSBC, JP Morgan, ICBC Standard Bank, Brinks, Malca Amit, Loomis and G4S. Where is this data, why is there a delay, and why has it not yet been published?
As a reminder, the Financial Times article in early February said that the LBMA would publish gold vault holdings data that would:
“show gold bars held by the BoE, the gold clearing banks, and those [vaults] operated by the security companies such as Brink’s”
The Financial Times article also said that:
“HSBC and JPMorgan, London’s biggest bullion banks, are backing the initiatives by the LBMA to improve transparency.”
With the gold holdings data on the other London vaults still not published, it begs the question, has there been a change of mind by HSBC and JP Morgan, two of the LBMA’s largest and most powerful members?
“Reputedly [the Bank of England vaults are] the second largest vault in the world with approximately 500,000 gold bars held in safe custody on behalf of its customers, including LBMA members, central banks, international financial institutions and Her Majesty’s Treasury.”
A holding of 500,000 Good Delivery gold bars is equal to 6250 tonnes. However, according to the Bank of England’s own figure for month end December 2016, the Bank of England only holds 5100 tonnes of gold in custody (408,000 Good delivery gold bars). Therefore, the LBMA is overstating the Bank of England’s holdings by 1150 tonnes, unless, and it’s unlikely, that the BoE vaults have seen huge gold bar inflows in the last 4 months.
In early February 2017 while preparing for a presentation in Gothenburg about central bank gold, I emailed Sweden’s central bank, the Riksbank, enquiring whether the bank physically audits Sweden’s gold and whether it would provide me with a gold bar weight list of Sweden’s gold reserves (gold bar holdings). The Swedish official gold reserves are significant and amount to 125.7 tonnes, making the Swedish nation the world’s 28th largest official gold holder.
Before looking at the questions put to the Riksbank and the Riksbank’s responses, some background information is useful. Sweden’s central bank, Sveriges Riksbank aka Riksbanken or Riksbank, has the distinction of being the world’s oldest central bank (founded in 1668). The bank is responsible for the administration of Swedish monetary policy and the issuance of the Swedish currency, the Krona.
Since Sweden is a member of the EU, the Riksbank is a member of the European System of Central Banks (ESCB), but since Sweden does not use the Euro, the Riksbank is not a central bank member of the European Central Bank (ECB). Therefore the Riksbank has a degree of independence that ECB member central banks lack, but still finds itself under the umbrella of the ESCB. Since it issues its own currency, the Riksbank is responsible for the management of the Swedish Krona exchange rate against other currencies, a task which should be borne in mind while reading the below.
On 28 October 2013, the Riksbank for the first time revealed the storage locations of its gold reserves via publication of the following list of five storage locations (four of these locations are outside Sweden) and the percentage and gold tonnage stored at each location:
Bank of England 61.4 tonnes (48.8%)
Bank of Canada 33.2 tonnes (26.4%)
Federal Reserve Bank 13.2 tonnes (10.5%)
Swiss National Bank 2.8 tonnes (2.2%)
Sveriges Riksbank 15.1 tonnes (12.0%)
The storage locations of Sweden’s official Gold Reserves: Total 125.7 tonnes
Nearly half of Sweden’s gold is stored at the Bank of England in London. Another quarter of the Swedish gold is supposedly stored with the Bank of Canada. The Bank of Canada’s gold vault was located under it’s headquarters building on Wellington Street in Ottawa. However, this Bank of Canada building has undergone a complete renovation and has been completely empty for a number of years, so wherever Sweden’s gold is in Ottawa, it has not been in the Bank of Canada’s gold vault for the last number of years.
The Swedish gold in Canada (along with gold holdings of the central banks of Switzerland, the Netherlands and Belgium) could, however, have been moved to the Royal Canadian Mint’s vault which is also in Ottawa. Bank of Canada staff are now moving back into the Wellington Street building this year. But is the Swedish gold moving back also or does it even exist? The location of the Swedish gold in Ottawa is a critical question which the Swedish population should be asking their elected representatives at this time, and also asking the Riksbank the same question.
Just over 10% of the Swedish gold is supposedly in the famous (infamous) Manhattan gold vault of the Federal Reserve under the 33 Liberty building. Given the complete lack of cooperation of the Federal Reserve Bank of New York (FRBNY) in answering any questions about foreign gold holdings in this vault, then good luck to Swedish citizens in trying to ascertain that gold’s whereabouts or convincing the Riksbank to possibly repatriate that gold.
A very tiny 2% of Swedish gold is also listed as being held with the Swiss National Bank (SNB). The SNB gold vault is in Berne under its headquarters building on Bundesplatz.
The Riksbank also claims to hold 15.1 tonnes of its gold (12%) in its own storage, i.e. stored domestically in Sweden. Interestingly, on 30 October 2013, just two days after the Riksbank released details of its gold storage locations, Finland’s central bank in neighbouring Helsinki, the Bank of Finland, also released the storage locations of its 49 tonnes gold reserves. The Bank of Finland claims its 49 tonnes of gold is spread out as follows: 51% at the Bank of England, 20% at the Riksbank in Sweden, 18% at the Federal Reserve Bank of New York, 7% in Switzerland at the Swiss National Bank and 4% held in Finland by the Bank of Finland. This means that not only is the Riksbank storing 15.1 tonnes of Swedish gold, it also apparently is also storing 9.8 tonnes of Finland’s gold, making a grand total of 24.9 tonnes of gold stored with the Riksbank. The storage location of this 24.9 tonnes gold is unknown, but one possibility suggested by the Swedish blogger Cornucopia (Lars Wilderäng) is that this gold is being stored in the recently built Riksbank cash management building beside Stockholm’s Arlanda International Airport, a building which was completed in 2012.
On its website, the Riksbank states that its 125.7 tonnes of gold “is equivalent to around 10,000 gold bars”. A rough rule of thumb is that 1 tonne of gold consists of 80 Good Delivery Bars. These Good Delivery Gold gold bars are wholesale market gold bars which, although they are variable weight bars, usually each weigh in the region of 400 troy ounces or 12.5 kilograms. Hence 125.7 tonnes is roughly equal to 125.7 * 80 bars = 10,056 bars, which explains where the Riksbank gets its 10,000 gold bar total figure from.
Using Gold for Foreign Exchange Interventions
On another page on its web site titled ‘Gold and Foreign Currency Reserve’, the Riksbank is surprisingly open about the uses to which it puts its gold holdings, uses such as foreign exchange interventions and emergency liquidity:
“The gold and foreign currency reserve can primarily be used to provide emergency liquidity assistance to banks, to fulfil Sweden’s share of the international lending of the International Monetary Fund (IMF) and to intervene on the foreign exchange market, if need be.”
This is not a misprint and is not a statement that somehow only applies to the ‘foreign currency reserve’ component of the reserves, since the same web page goes on to specifically say that:
“The gold can be used to fund emergency liquidity assistance or foreign exchange interventions, among other things.”
Therefore, the Riksbank is conceding that at least some of its gold is actively used in central bank operations and that this gold does not merely sit in quiet unencumbered storage. On the contrary, this gold at times has additional claims and titles attached to it due to being loaned or swapped.
When the Riksbank revealed its gold storage locations back in October 2013, this news was covered by a number of Swedish media outlets, one of which was the Stockholm-based financial newspaper Dagens Industri, commonly known as DI. DI’s article on the topic, published in Swedish with a title translated as “Here is the Swedish Gold“, also featured a series of questions and answers from personnel from the Riksbank asset management department. Some of these answers are worth highlighting here as they touch on the active management of the Swedish gold and also the shockingly poor auditing of the Swedish gold.
In the DI article, Göran Robertsson, Deputy Head of Riksbank’s asset management department, noted that historically the Swedish gold was stored at geographically diversified locations for security reasons, but that this same geographic distribution is now primarily aimed at facilitating the rapid exchange of Swedish gold for major foreign currencies, hence the reason that nearly half of the Swedish gold is held in the Bank of England gold vaults – since the Bank of England London vaults are where gold swaps and gold loans take place.
Robertsson noted that over the 2008-2009 period,50 tonnes of gold Swedish gold located at the Bank of England was exchanged for US dollars:
“London is the dominant international marketplace for gold.We used the gold 2008-2009 during the financial crisis when we switched it to the dollar we then lent to Swedish banks”
One of these Riskbank gold-US Dollar swap transaction was also referenced in a 2011 World Gold Council report on gold market liquidity. This report stated that in 2008 following the Lehman collapse:
“In order to be able to provide liquidity to the Scandinavian banking system, the Swedish Riksbank utilised its gold reserves by swapping some of its gold to obtain dollar liquidity before it was able to gain access to the US dollar swap facilities with the Federal Reserve.”
In the October 2013 DI interview, Göran Robertsson also noted that at some point following this gold – dollar exchange, “the size of the reserve was restored“, which presumably means that the Riksbank received back 50 tonnes of gold. As to whether the restoration of the gold holdings was the exact same 50 tonnes of gold as had been previously held (the same gold bars) is not clear.
Sophie Degenne, Head of the Riksbank’s asset management department, also noted that:
“The main purpose of the gold and foreign exchange reserves is to use it when needed, as in the financial crisis”
Auditing of the Swedish Gold
On the subject of so-called transparency and auditing of the gold, Sophie Degenne said the following in the same DI interview:
“Why do you reveal at which central banks the gold is located? It is a part of the Riksbank endeavours to be as transparent as we can. We have engaged in dialogue with the relevant central banks”
How do you verify that the gold is really where it should be? “We have our own listings of where it is.We reconcile these against extracts that we receive once a year.From now on, we will also start with our own inspections.”
Therefore, the Riksbank gold auditing procedure at that time was one of merely comparing one piece of paper to another piece of paper and in no way involved physically auditing the gold bars in any of the foreign locations. These weak audit methods of the Swedish gold were first highlighted by Liberty Silver CEO, Mikael From in Stockholm-based news daily Aftonbladet’s coverage of the Swedish gold storage locations in an article in early November 2013 titled “Questions about Sweden’s gold reserves persist“.
In Aftonbladet’s article, Mikael From stated that while it was welcome that the Riksbank was at that point signalling an ambition to inspect the Swedish gold reserves, it was not clear that the Riksbank would be conducting a proper audit of the gold reserves at the time of inspection, although such a proper audit would be highly desirable. Mikael stated that without such a proper audit, and without witnessing the gold with their own eyes, the Riksbank and the Swedish State could not be certain that the Swedish gold actually existed.
Turning now to the questions which I posed to the Swedish Riksbank in early February 2017 about its gold reserves. I asked the Riskbank two basic and simple questions as follows:
“I am undertaking research into central bank gold reserves, including the gold reserves held by the Riksbank at its 5 storage facilities.
1. Are the gold bars held by the Riksbank in its foreign storage facilities physically audited by the Riksbank (i.e. stored at Bank of England, Bank of Canada, Federal Reserve New York and Swiss National Bank)? In other words, does the Riksbank have a physical audit program for this gold?
2. Secondly, would the Riksbank be able to send me a gold bar weight list which shows the gold bar holdings details for the 125.7 tonnes of gold held by the Riksbank. A weight list being the industry standard list showing bar brand (refiner), serial number, gross weight, fineness, fine weight etc.
A few days after I submitted my questions, the Presschef/Chief Press Officer of the Riksbank responded as follows. On the subject of auditing:
“Answer 1: Yes, the Riksbank performs regularly physical audits of its gold.“
In response to the question about a gold bar weight list, the Chief Press Officer said:
Answer 2: The Riksbank publishes information about where the gold is stored and how much in tonnes is at each place. See table (same distribution table as above). However, the Riksbank does not publish weight lists or other details of the gold holdings.“
So here we have the Riksbank claiming that it personally now performs physical audits of its gold on a regular basis. This is the first time in the public domain, as far as I know, that the Riksbank is claiming to have undertaken physical gold audits of its gold holdings, and it goes beyond the 2013 statement from the Riksbank’s Sophie Degenne when she said “we will also start with our own inspections“.
But critically ,there was zero proof offered by the Riksbank to me, or on its website, that it has undertaken any physical gold audits. There is no documentation or evidence whatsoever that any physical audits have ever been conducted on any of the 10,000 gold bars in any of the 5 supposed storage locations that the Riksbank claims to store gold bars at. Contrast this to the bi-annual physical audits which are carried out on the gold bars in the SPDR Gold Trust (GLD) which are published on the GLD website.
In any other industry, there would be an outcry and court cases and litigation if an entity claimed it had conducted audits while offering no proof of said audits. However, in the world of central banking, perversely, this secrecy is allowed to persist. This is outrageous to say the least and Swedish citizens should be very concerned about this lack of transparency of the Swedish gold reserves.
Official Secrecy about Swedish Gold Reserves
Given the brief and not very useful Riksbank responses to my 2 questions above, I sent a follow on email to the Riksbank asking why the Swedish central bank did not publish a gold bar weight list. My question was as follows:
“Is there any specific reason why the Riksbank does not publish a gold bar weight list in the way, for example, that a gold-backed ETF does publish such a weight list every trading day?
i.e. Why is the Riksbank not transparent about its gold bar holdings?”
This second email was answered by the Riksbank Head of Communications, as follows:
“This kind of information is covered by secrecy relating to foreign affairs, as well as security secrecy and surveillance secrecy in accordance with the relevant provisions in the Swedish Public Access to Information and Secrecy Act.
As far as we are aware of, the Riksbank is among the most transparent central banks, being public with information about the storage locations and volumes, but do let us know if any other central banks are offering the level of transparency you are asking for (except for Germany of course, which we are aware about).”
So here you can see here that gold, which in the words of the Wall Street Journal is just a ‘Pet Rock’, is covered by some very strong secrecy laws in Sweden. Why would a pet rock need ultra strong secrecy laws?
An explanatory document on Sweden’s “Public Access to Information and Secrecy Act” can be accessed here. In Sweden, the rules governing public access to official documents are covered by the Freedom of the Press Act. While its beyond topic to go into the details of Swedish secrecy laws right now, there is a short section in the document titled “What official documents may be kept secret?” (Section 2.2) which includes the following:
“The Freedom of the Press Act lists the interests that may be protected by keeping official documents secret:
National security or Sweden’s relations with a foreign state or an international organisation;
The central financial policy, the monetary policy, or the national foreign exchange policy;
Inspection, control or other supervisory activities of a public authority;
The interest of preventing or prosecuting crime;
The public economic interest;
The protection of the personal or economic circumstances of private subjects; or
The preservation of animal or plant species.
Given that the Riksbank stated that the information in its gold bar weight lists was “covered by secrecy relating to foreign affairs, as well as security secrecy and surveillance secrecy”, I would hazard a guess that the Riksbank would try to reject Freedom of Information requests in this area by pointing to central bank gold storage and gold operations as falling under points 1 or 2, i.e. falling under national security or relations with a foreign state or international organisation, or else monetary policy / foreign exchange policy (especially given that the Riksbank uses gold reserves in its foreign currency interventions). Perhaps the Riksbank would also try to twist point 5 as an excuse, i.e. that it wouldn’t be in the public economic interest to release the Swedish gold bar details.
As to why the Riksbank and nearly all other central banks are ultra secretive about gold bar weight lists and even physical auditing of gold bar holdings usually boils down to the fact that, like the Riksbank, these gold bar holdings are actively managed and are often used in gold loans, gold swaps and even gold location swaps. If identifiable details of the gold bars of such central banks were in the public domain, given that these bars are involved in loans, currency swaps and location swaps, these gold bar details could begin to show up in the gold bar lists of other central banks or of the gold bar lists of publicly listed gold-backed Exchange Traded Funds. This would then blow the cover of the central banks which continue to maintain the fiction that their loaned and swapped gold is still held in unencumbered custody on their balance sheets, and would blow a hole in their contrived and corrupt accounting policies.
A Proposal to the Oldest Central Bank in the World
Since the Riksbank happened to ask me were there any central banks “offering the level of transparency [I was] asking for” i.e. providing gold bar weight lists, I decided to send a final response back to the Riksbank in early March highlighting the central banks that I am aware of that have published such gold bar weight lists, and I also took the opportunity of proposing that the Riksbank should follow suit in publishing its gold bar weight list. My letter to the Riksbank was as follows:
“You had asked which central banks offered a level of transparency on their gold holdings that include publication of a gold bar weight list. Apart from the Deutsche Bundesbank, which you know about, I can think of 3 central banks which have released weight lists of their gold bar holdings.
The 3 examples below (together with the Bundesbank) show that some of the most important central banks and monetary authorities in the world have now deemed it acceptable to include the release of gold bar weight lists as part of their gold communication transparency strategies.
The 4 sets of weight lists below include gold bar holdings at the Bank of England (stored by Mexico, Australia, Germany), and at the Federal Reserve Bank of New York (stored by the US Treasury and Bundesbank). Together these two storage locations account for 60% of the Riksbank’s gold holdings (74.6 tonnes).
The Riksbank is the world’s oldest central bank and has a long track record of being progressive and transparent. By releasing the Riksbank’s gold bar weight lists for the gold bars stored over the 5 storage locations (London, New York, Ottawa, Berne and in Sweden), the Swedish central bank would be joining an elite group of central banks and monetary institutions that could be considered the early stage adopters of much needed transparency in this area.”
The RBA list includes refiner brand, gross weight, assay (fineness), and fine weight, as well as bank of England account number.
3. US Treasury
In 2011, the US Treasury’s full detailed schedules of gold bars was published by the US House Committee on Financial Services as part of submissions for its hearing titled “Investigating the Gold: H.R. 1495, the Gold Reserve Transparency Act of 2011 and the Oversight of United States Gold Holdings”.
These US Treasury weight lists are as follows, and are downloadable from the financial services section of the “house.gov” web site.
Weight list of all Treasury gold held at Fort Knox, Denver and West Point – 699,515 bars – pdf format
The Bundesbank list show all the German gold bars held at the Bank of England, NY fed and Banque de France as well as in Frankfurt.”
As of now, the Swedish Riksbank has a) not published a gold bar weight list of any of its gold bar holdings and b) not acknowledged my follow up email where I listed the central banks that have produced such lists and suggested that the Riksbank do likewise.
The Swedish Riksbank claims to hold 10,000 large Good Delivery gold bars in 5 locations across the world and now claims to have conducted physical gold audits of this gold. Yet it has never published any physical gold audit results of any of these gold bars nor published any of the serial numbers of any of the 10,000 gold bars it claims to have in storage. For a so-called progressive democracy this is shocking, although not surprising given the arrogant and unaccountable company that central bankers keep with each other.
If someone with time on their hands, ideally a Swedish citizen, has an interest in this area, it would be worthwhile for them to research the rules of the Swedish Freedom of Information Act, and then craft a few carefully worded Freedom of Information requests to the Riksbank requesting physical audit documents and gold bar weight lists of Sweden’s 125.7 tonnes of gold that is supposedly held in London, New York, Ottawa, Berne and in Sweden, possibly in or around Stockholm or beside Arlanda airport.
While these Freedom of Information requests would probably get rejected due to some spurious secrecy excuse and thrown back at the applicant in short order, at least its worth trying, and might make a good story for one of the Swedish financial newspapers to cover.
German precious metals group Heraeus Precious Metals (HPM), part of the Heraeus industrial group, has just announced the full acquisition of Swiss precious metals refining group Argor-Heraeus. Heraeus is headquartered in Hanau, just outside Frankfurt. Argor-Heraeus is headquartered in Mendrisio in the Swiss Canton of Ticino, beside the Italian border.
In early November 2016, BullionStar was among the first to report that Swiss Argor-Heraeus was indeed an acquisition target. At the time, market sources had indicated that the most likely acquirer was a private equity company Capinvest, with other suitors said to be Japanese group Asahi and Swiss based MKS-PAMP.
In late 2016, S&P Global Platts reported that Swiss private equity company “Capvis” was in talks to acquire Argor-Heraeus, with one of Platts sources quoting a purchase price in the region of €200 million with completion in Q1 2017, while another source said €200 million was too high a figure. At the end of the day, a Capvis takeover did not materialise and earlier this year market sources said that Argor-Heraeus was no longer for sale (externally). In hindsight, it was probably at this stage that Heraeus decided to make its move. Alternatively, the discussions with external buyers may have just been conducted so as to gauge sentiment and establish a series of potential valuations for the Swiss refiner.
As a reminder, Argor-Hereaus had an unusual ownership structure in that it was jointly owned by 4 shareholders, namely German group Heraeus, German bank Commerzbank, the Austrian Mint, and Argor-Heraeus management. Prior to the takeover, Heraeus was the largest shareholder holding 33% of Argor-Heraeus shares, with Commerzbank holding a further 32.7% of the equity, the Austrian Mint holding another 30%, and Argor-Heraeus’s management holding the balance of shares.
As an existing shareholder and board member of Argor-Heraeus, the Heraeus group would have been privy to all of Argor-Heraeus’s financial and operational details, and so would have been in an advantageous position to negotiate purchase price details with Commerzbank and the Austrian Mint, which would have been a natural advantage relative to external potential acquirers.
However, the exact purchase price Argor-Heraeus is not known, since, according to the Heraeus press release “the parties have agreed not to disclose financial details of the deal”. Notwithstanding this, German newspaper Handelsblatt is claiming that the Heraeus takeover values Argor-Heraeus at “half a billion Swiss Francs“, since according to Handelsblatt’s sources, Heraeus paid “few hundred million euros for the remaining Argor shares“. With CHF 500 million equal to approximately €468 million, the Handelsblatt claim would mean that Heraeus may have paid €313 million for the 67% of Argor-Heraeus that it did not own. This would be far higher than the €200 million figure that S&P Platts mentioned in December.
Motivations for Acquisition
According to Heraeus, one of its motivations in acquiring Argor-Heraeus is to strengthen its capabilities in gold and silver refining by tapping “Argor’s expertise and processing capacity for gold and silver”, since Heraeus considers itself strongest in platinum group metals. Heraeus states that another driver of the acquisition is geographical diversification given that Argor-Heraeus has facilities on the ground in Chile, as well as in Italy, Germany and of course Switzerland, while Heraeus has a strong presence in Asia, North America and India in addition to Germany.
With 3 of the 4 giant Swiss precious metals refineries having now been acquired by new owners within less than 2 years of each other, this leaves the PAMP refinery, owned by MKS PAMP, as the only one of the “Big 4” Swiss refineries to have bypassed this recent flurry of corporate control activity. As to whether MKS PAMP will itself become a takeover target is debatable, but it would be surprising if MKS isn’t thinking about this very question right now.
Guillermo Barba, the Mexican financial and economic journalist, has recently published an article on his website confirming that through an information request that he had made to Mexico’s central bank, Banco de México (Banxico), the central bank has now released what amounts to a relatively comprehensive list of Mexico’s gold bars held in storage at the Bank of England gold vaults in London.
Mexico’s list is an inventory of wholesale market gold bars that Banixco owns and stores in custody at the Bank of England vaults in London. In the contemporary parlance of the gold market, most people would call this type of holding an allocated gold holding, but more historically in the Bank of England world, it has been known as an “earmarked gold” holding or a “set-aside gold” holding because the specific bars are set-aside for a specific central bank, in other words the central bank has its name attached to those particular bars (earmarked).
Wholesale gold bars are also known as London Good Delivery gold bars or variable weight gold bars, and each weighs in the region of 400 troy ounces ( ~ 12.5 kilos). On the Banixco list, there are 7,265 wholesale gold bars listed. This new list is one of the very few detailed central bank gold bars lists (weight lists) which exists in the public domain, and it could be useful for a number of purposes (see below).
Barba has done persistent and diligent work over the last 6 years, by patiently obtaining more and more information from the Mexican central bank about its gold reserves via various Freedom of Information Requests (FOIA), and shedding some light on this usually opaque area of gold and central banking.
2011: Gold Reserves Skyrocket, Central Bank Secrecy
Before we examine this newly published list from the Banco de México, a little background is useful. As of February 2017, Mexico held about 120.7 tonnes of gold in its official gold reserves, which puts the country at the tail-end of the world’s Top 30 official/country gold holders.
All through the 2000s, Banixco only held a few tonnes of gold in its official reserves, ranging from about 4 tonnes and 9 tonnes. This situation changed in early 2011 when the Mexican central bank purchased just over 93 tonnes of gold in March 2011 (first reported by the FT in early May 2011). This brought Mexico’s gold holdings up from 7.1 tonnes to about 100.2 tonnes by the end of Q1 2011. The country’s official gold holdings were boosted further to about 125.2 tonnes by Q2 2012 when Banixco bought more than 16 tonnes in March 2012. See World Gold Council quarterly changes of central bank gold holdings for the underlying data.
After Mexico made these sizeable gold purchases in early 2011, Guillermo Barba submitted various FOIAs to the Mexican central bank about the country’s newly acquired gold stash. Unfortunately, most of these information requests received weak responses from the Bank. For example, the question:
“How many bars of gold make up the recent acquisition of 93 tonnes of gold made by Banxico en the first quarter of 2011”
received a response from Banixco of:
“…we inform you that the information that you request is classified as reserved”
The Mexican central bank also added that:
“due to the variability of the content of gold in the bars, it is not possible to specify with certainty the exact number of bars purchased.”
We later learned that the Bank of England purchased this “gold” on behalf of Mexico. On the surface, Banixco saying that it could not “specify with certainty the exact number of bars purchased” seems to suggest that at least some of the Mexican gold at that time in 2011 was held on a unallocated basis and possibly out on loan to bullion banks in the London gold lending market.
If Mexico bought actual gold bars at the outset in Q1 2011, the gold bought for Mexico was probably already sitting in the Bank of England vaults. Some of it may then have been lent out to bullion banks immediately. Alternatively, at the outset in Q1 2011, the Bank of England could have ‘sold’ to Mexico a fine ounce claim on a number of gold ounces, that could then be allocated to actual gold bars on a future date. Without seeing the purchase invoices of the Mexican gold transactions, it’s hard to say what the initial purchase transactions referred to.
Another question Barba put to Banixco in 2011 was:
“In what country or countries is the gold that forms part of the International Reserves of Mexico physically located?”
“access to the requested information will not be granted, since it is classified as reserved”
Barba’s article addressing his questions in 2011 and Banixco’s responses, which was published in September 2011, can be read here.
“At month’s end, April 2012, Banco de Mexico maintained a position in fine gold of 4,034,802 ounces, of which only 194,539 ounces are located in the territory of the United Mexican States.
“countries where these reserves are located are ‘United States of America, England and Mexico.‘
‘the acquisitions of gold during March and April 2012 are under custody in England’.”
[the gold is stored in] “the city of London, England, where more than 99% of the gold which the Bank of Mexico maintains outside the country is presently under custody…”
With 4,034,802 ounces (125.5 tonnes) held in total, and 194,539 ounces (6.05 tonnes) held in Mexico, there were 3,840,263 ounces (119.44 tonnes) held outside Mexico, which was 95.2% of Mexico’s total gold holdings. With 99% of the foreign gold in London, this equated to about 3.8 million ounces (118 tonnes) held in London, and about 38,000 ounces (1.2 tonnes) held in the US with the Federal Reserve Bank (FRB).
Mexican Federal Auditors not happy with Banixco
In February 2013, Guillermo Barba also highlighted that the Mexican Federal Audit Office (Auditoría Superior de la Federación or ‘ASF’) Report for the Year 2011 was highly critical of Banixco’s relaxed approach to its gold purchases at the Bank of England.
The ASF reprimanded Banixco, saying that it:
“has not conducted physical inspections to gold to verify compliance with the terms of acquisition and the conditions regarding its storage, in order to be certain of the physical custody of this asset”
According to the ASF, Banixco only held documents about the “Terms and Conditions” of the gold holdings contract with the Bank of England, with records of “the dates of the transactions” and also some “payment vouchers”.
ASF also recommended that the Mexican central bank:
“make a physical inspection with the counterparty [Bank of England] that has the gold under its custody, in order to be able to verify and validate its physical wholeness.”
February 2017: Partial Glimpse of Bar List
Fast forward to 17 February 2017, and Barba published another article confirming that following some further information requests to the Mexican central bank, Banixco had clarified the following facts about its gold holdings:
“Of the 3.881 million ounces of gold that the Bank of Mexico has at the close of October 2016, 98.95% are held in the United Kingdom, 0.0004% in the Federal Reserve Bank of the United States and the remaining 1.05 % In Mexico.”
“The Bank of Mexico has the serial number of each ingot protected in accounts assigned abroad. From these accounts, the number of ingots rises to 7,265. It should be noted that for unallocated accounts there is no specific serial number and therefore the number of ingots cannot be determined.”
“Assigned accounts are those that are owned on specific ingots with serial numbers, and segregated from the rest.“
Therefore, for each gold ingot held in a foreign domiciled allocated gold account, Bank of Mexico is in possession of the bar serial numbers. This was the first information from Banixco that specifically addressed the number of gold bars held by the Mexican central bank at the Bank of England.
As of October 2016, with 3,881,000 ounces of gold held by Mexico in total, 98.95% of which was held at the Bank of England in London, that would infer that 3,840,250 ounces of gold (119.4 tonnes) were held in London, with only about 1,550 ounces (0.0004%) held at the FRB in New York.
Assuming each gold bar contains 400 oz troy ounces of gold, then 7,265 bars would contain 2.906 million troy ounces. It would also mean that about 934,000 troy ounces (29 tonnes) of Mexico’s gold are held unallocated accounts (where the gold is not unassigned as specific gold bars). The existence of unallocated gold accounts is revealing since it proves that the Bank of England doesn’t just offer its central bank customers the traditional custody facility of earmarked / set-aside / allocated gold bars. It also offers what either amounts to gold accounts that are denominated on a fine ounces basis but are fully backed by a pool of gold, or alternatively these unallocated accounts may not be fully backed (i.e. fractionally-backed).
To facilitate gold lending in the London Gold Market between central banks (the lenders) and commercial bullion banks (the borrowers), the Bank of England would have to operate account facilities for its customers that were in a sense dematerialised because when a central bank lends gold bars to a bullion bank, it does not necessarily (and probably doesn’t) receive back the same gold bars, because those bars have either been sold in the market or onward lent in the market. Therefore an account convention with specific bars earmarked to a customer would not facilitate this process. Only an account where the unit is a balance of fine troy ounces of gold would allow these transfers to occur. In this scenario, the central bank still insists it has a fine troy ounce gold holding, even though its gold has been lent out to a bullion bank.
The other alternative is that the Bank of England is selling its central bank customers a gold account service where, for example, Central Bank A pays dollar cash upfront for 100 tonnes of gold, and the Bank of England signs a piece of paper saying “We the Bank of England have a liability to Central Bank A for 100 tonnes of gold“, but that gold is not necessarily in the Bank of England vaults or anywhere else. The Bank of England just has to be able to allocated the claim to real physical gold bars if Central Bank A ever decides that its 100 tonne gold asset be converted to allocated gold bars.
Without seeing the “Terms and Conditions” of these “unassigned gold” contracts with the Bank of England, its hard to say how exactly the “unassigned gold” is backed up, and to what extent it’s backed up.
Historically, the Bank of England only ever offered earmarked gold accounts to its central bank customers, and on a few occasions in the 1950s and 1970s it actually pushed back on plans to offer customers fine gold ounce balance accounts (and got legal advice on this), because the Bank did not want to go down the road of ending up with one pool of gold backing multiple central bank customer accounts, as this went against the concept of custody of assets and title to specific gold, and furthermore the Bank was afraid of the legal implications of central banks depositing specific bars but getting back different bars which might not be of the same quality etc.
March 2017: Banixco Releases Detailed Bar List
Initially, as per his 17 February article, Banixco only provided Barba with a list of the 7,265 gold bars showing two columns of data, the first column listing internal Bar-IDs from the Bank of England’s gold bar database, and the second column listing the refiner brand names of the bars. This first list can be seen here, but it’s not really that important, because a few weeks later, Banixco agreed to provide Barba with a second, much more comprehensive list. This second list is featured in Barba’s article dated 7 March 2017.
The latter Banixco gold bar list file can be downloaded here. For each of the 7,265 gold bars listed (in 7265 Rows), the list contains 7 columns or variables of data, namely:
Sequence Number from 1 to 7265
“Serial Number” (which is an internal Bank of England sequence number)
Brand Code (an 8-digit code)
Gross Weight (troy ounces to 2 decimal places)
Assay (gold Fineness)
Fine Weight (troy ounces to 3 decimal places)
Although the Banixco list does not include the real serial numbers that each gold refiner stamps on its own gold bars, the combination of columns “refiner brand – gross weight – assay – fine weight” in the list should be adequate to uniquely identify each bar, because don’t forget, these are variable weight bars and each bar for a given refiner will have a different fine weight when expressed to 3 decimal places. The start of the list looks as per the below screenshot:
Overall, the 7265 gold bars weigh 2,919,911.55 troy ounces and contain a total of 2,912,000 fine troy ounces of gold.The list provided by Banixco is sorted by ‘Brand Code’ which is an 8-digit Bank of England database table field that consists of refiner code (digits 1-4), refiner location (digits 5-6) and sequence number (digits 7-8). For example, Valcambi is VALCCH01 i.e. VALC, CH = Switzerland, and 01.
The 2nd column in the list is a Bank of England internal ID bar number which is either 6 or 7 digits. On Mexico’s list, the highest number is 1047712 and the lowest number is 704989, but the numbers present on the list run in short and broken sequential ranges of, for example, 1039142-1039221 or 880338-880446. If this is a sequential internal series of numbers that started at 000001, it would suggest that more than 1 million individual Good Delivery Bars have passed through the Bank of England’s 10 gold vaults since the numbering series was initiated. The series may not be fully sequential at all, and could possibly also include some part of the number signifying vault location, although this is doubtful.
The Refiner Bar Names on Mexico’s Gold Bar List
There are 24 ‘Brand Codes’ listed on the Mexico’s gold bar list, including such refiners as South Africa’s Rand Refinery, Australia’s Perth Mint, Switzerland’s Valcambi, Argor-Heraeus and Metalor, the Royal Canadian Mint, Germany’s Heraeus, Johnson Matthey, the US Assay Office, the State Refinery (Moscow), the Central Bank of the Philippines Gold Refinery, and N.M. Rothschild. Many of these brands held at the Bank of England are the same refiner brands which are trusted and popular in the retail investment gold bar market, and carried by BullionStar, such as Perth Mint, Argor-Heraeus, Heraeus, Royal Canadian Mint, and Johnson Matthey.
Some refiners have, or have had over time, refinery operations in multiple geographic locations, so some refiners have multiple Brand Codes listed in the Bank of England gold bar database. One example is Johnson Matthey, which on the Banixco list is listed as 4 separate entities, namely Johnson Matthey Salt Lake City USA, Johnson Matthey and Co Ltd [GB], Johnson Matthey & Mallory Ltd. Toronto, and Johnson Matthey Hong Kong Ltd. Another example is Metalor, which is present on the Banixco list in 3 guises, namely Metalor Hong Kong, Metalor USA, and Metalor Technologies SA (Switzerland).
Other long-standing refiners have gone through various mergers over time and their historic parts are now all part of a larger refining group. This applies to “Perth Mint” bars, which on the Banixco list are represented by Western Australia Mint (Trading as AGR) , AGR Joint Venture Melbourne and the Royal Mint (Perth).
On an individual Brand Code basis, the below table shows these refinery brand names, and the number of gold bars of each brand name that show up on Mexico’s gold bar weight list.
First up is the Rand Refinery, with Banixco holding 1735 rand Refinery gold bars. Nearly a quarter of Banixco’s earmarked bars are Rand Refinery bars. It’s not surprising that on a refiner name basis, Banixco holds more Rand Refinery gold bars than any other bar brand. After all, Rand Refinery of South Africa is said to have refined over 50,000 tonnes of gold since it was established in 1921, which is about 30% of all the gold that has ever been mined. A lot of Rand Refinery bars were also historically sold in the London Gold Market and held within the bank of England vaults. This is probably still the case.
For example, according to the Bank of England archives, most of the gold held by the International Monetary Fund (IMF) at the Bank of England was (as of the late 1970s) in the form of Rand Refinery gold bars. Whether this is still the case is unclear, as the IMF is ultra secretive about its remaining gold reserves and never reports facts such as gold bar weight lists.
Second up is AGR Joint Venture, which is now technically part of the Perth Mint, with the Bank of Mexico holding 1519 of these bars. Together with the Rand refinery bars, these two brands makeup 45% of Banixco’s total holdings. Adding in the bars of Johnson Matthey Toronto and Valcambi Switzerland, nearly 70% of Mexico’s bars are from just 4 bar brands.
Grouping refiner names where appropriate such as all Johnson Matthey names and all Perth Mint related names, results in a slightly different ranking, with Perth Mint taking pole position with 1892 bars held by Banixco, and with Rand Refinery and Johnson matthey in exact joint second place with 1736 bars a piece in the Mexican holdings.
Under this grouping approach, 74% of Mexico’s gold bars have been manufactured by just 3 refinery groups, rising to nearly 85% if Valcambi bars are included.
One of the reasons for highlighting this, is that it could be useful for extrapolating the frequency of gold bar brands that might be held across gold accounts generally at the Bank of England. While this extrapolation might be flawed, it does suggest that there are certain refinery bars brands that are more common than others within the Bank of England vault network.
The Bank of England did not just go and transfer newly refined gold bars into the Banixco account. It populated the Banixco allocated gold holding (in 2011 or after) with a selection of bars from lots of different eras. Hence the presence of NM Rothschild bars, US Assay Office bars, old Royal Mint (Perth) bars, as well as AGR Joint venture bars. Its also possible that a bullion bank or bullion banks executed the order on behalf of Mexico with gold that these banks store at the Bank of England (bullion banks also store gold at the bank of England for those who were not aware of this fact).
AGR Joint Venture bars were only produced until 2003. See here for details of AGR’s history. NM Rothschild bars have not been produced since 1967. Royal Mint (Perth) bars are extremely old and have not been produced under this name for a very long time. LBMA Good Delivery records don’t even specify when Royal Mint (Perth) bars ceased to be produced. The last Johnson Matthey bars produced in England were in 2005. US Assay Office bars (from the New York Assay Office) haven’t been produced since 1997 at the latest, and mostly well before that. Therefore, even though the Banixco gold bar list doesn’t list year of manufacture for each bar, some inferences can be made to show that a lot of the bars allocated to the Mexican gold account at the Bank of England are old bars that are no longer in production. But that’s not surprising because gold is a store of wealth and has been for 1000s of years, so an old bar is as good as a newer bar.
The bar list is also interesting in that it shows that when the Bank of England (or a bullion bank with a gold holding at the Bank of England) either buys physical gold bars on behalf of a central bank customer, or allocates specific bars to a central bank gold account for a gold balance that was previously in a unallocated account, it is either transferring gold from a Bank of England inventory holding, or by buying gold from another central bank that’s already in its vaults, or else buying gold from a bullion bank that probably also has gold stored at the Bank of England, part of which may be gold that has flowed out of gold-backed Exchange Traded Funds that store their gold in the London vaults.
Which brings us to some critical points. Using the “refiner brand – gross weight – assay – fine weight” combination for bars on the Banixco list, it should be possible to cross reference these bars against records of gold bars that have been held over time in gold-backed ETFs such as GLD and IAU. Various gold researchers such as Warren James maintain databases with records of all gold bars that are in and that have ever been in gold-backed ETFs. If a bar on the Banixco list has a match in those database tables, then it proves that the Bank of England sources gold for its central bank customers that was at one time held in one of the ETFs. And this probably happens, since the bullion banks such as HSBC and JP Morgan are active in allocating and deallocating gold in and out of ETFs, and they hold gold accounts at the Bank of England and are active in the gold lending market.
More importantly, if in the future, a gold-backed ETF flags up one or more gold bars that were among the 7265 gold bars on the Banixco list, and Banixco hasn’t reported selling any gold, then it will prove that Banixco either lent or swapped some of ts gold while still accounting for it under ‘gold and gold receivables’ in its balance sheet, and it will prove that central bank gold is being double counted while on loan, i.e. claimed to be held by a central bank, while really being held in a gold-backed ETF.
On 9 February 2017, the Deutsche Bundesbank issued an update on its extremely long-drawn-out gold repatriation program, an update in which it claimed to have transferred 111 tonnes of gold from the Federal Reserve Bank of New York to Germany during 2016, while also transferring an additional 105 tonnes of gold from the Banque de France in Paris to Germany during the same time-period.
Following these assumed gold bar movements, the Bundesbank now claims to have achieved its early 2013 goal of repatriating 300 tonnes of gold from New York to Frankfurt, but after 4 years it is still 91 tonnes short of its planned transfer of 374 tonnes of gold from Paris to Frankfurt. In essence, over an entire 4-year period (i.e. 208 weeks), the Bundesbank has only been able to transfer 583 tonnes of gold back from New York and Paris to Germany. And the Bundesbank still claims to have 1236 tonnes of gold remaining in storage with the New York Fed.
Furthermore, if the mainstream financial media had bothered looking at Federal Reserve “Table 3.13 – Selected Foreign Official Assets Held at Federal Reserve Banks” under ‘Earmarked Gold’ (line item 4), they would have seen that the foreign custody gold figure that the Fed reports has not changed since September 2016, and that the Fed’s foreign custody gold figure had dropped by 113 tonnes between March 2016 and September 2016, meaning that the Bundesbank’s 111 tonne gold transfer from the US to Germany had been completed by September 2016, i.e. at least 4 months before the Bundesbank reported it.
100 tonnes of gold per day Air-Lifted
All gold withdrawals from the Fed’s “earmarked gold” reporting category in 2016 occurred between March and September 2016, with activity each month throughout that period except in May. As to why there were gold withdrawals from the Fed of 113.45 tonnes when the Bundesbank only reported transferring back 111 tonnes is not clear. Was an additional amount withdrawn from the Fed vault by another foreign central bank or did the Bundesbank conduct further melting down of its US Assay office gold bars and lose 2+ tonnes (1.7%) of fine ounce content that was overstated in its Federal Reserve holdings? Or perhaps this amount was lost when weighing old US Assay Office ‘melts’ (batches of 18-22 bars) which had never been properly weighed before.
Whatever the case, we will never know because the Fed does not divulge the identities of its central bank gold custody customers, nor does the Bundesbank divulge simple details such as gold bar serial numbers on its so-called gold bar list (more of which below).
Simple common sense would have alerted the mainstream media robots to the fact that it is not normal for international gold movements to take 4 years to complete, and that there is something absolutely not right with Germany’s foreign held gold taking so long to transport from New York and Paris. Paris is just a 1 hour flight from Frankfurt and 6 hours by road, and New York is less than 9 hours flying time to Frankfurt.
Other simple questions which the mainstream financial media have failed to ask or have failed to think of include why does the Bundesbank need to keep any gold at all stored at the Federal Reserve in New York, let alone 1236 tonnes, when the New York Fed vault is not even an international gold trading center. And is this gold left in New York is under any liens, claims, encumbrances, loans or swaps?
In contrast to the Bundesbank’s laughable repatriation program duration, take for example, the Banco Central do Venezuela, which was able to transfer 160 tonnes of gold from Europe to Venezuela’s capital, Caracas, over a 2 month period from 25 November 2011 to 30 January 2012. See “Venezuela’s Gold Reserves – Part 2: From Repatriation to Reactivation” for details.
That’s 80 tonnes per month, which would equate to a 4 month transfer window for 300 tonnes of the Bundesbank’s gold stored in New York, not 4 years. Furthermore, why is the mainstream media not asking the Bundesbank why it takes more than 4 years to transfer 374 tonnes of gold from Paris to Frankfurt?
More damning to the contemporary Bundesbank, the same Americans (Federal Reserve) were able to fly over 800 tonnes of gold from the US to England exactly 50 year ago, in November and December 1967, to prop up their share of the London Gold Pool gold holdings at the Bank of England. This gold was flown into RAF Mildenhall in Suffolk over 9 days in batches of around 100 tonnes each day using US air force cargo carriers, and then this gold was ferried by police escorted convoys down to the City of London.
The first 4 of these US air force flights were on Tuesday 28 November 1967, Wednesday 29 November, Friday 1 December, and Sunday 3 December, with the Americans flying in 100 tonnes of gold each day to RAF Mildenhall over those 4 days. That’s 400 tonnes of gold flown from the US to Europe in just 6 days. See screenshot below.
These 4 flights in late November and early December 1967 were followed by 5 more flights on Tuesday 19 December, Thursday 21 December, Thursday 28 December , Friday 29 December, and Sunday 31 December 1967. These 5 flights transported another 445 tonnes of gold bars (14,317,458 fine ounces) from the US to the Bank of England vaults (see screenshot below). That’s another 445 tonnes of gold moved from the US to London in just 13 days.
Overall, the November and December 1967 gold airlifts transported nearly 850 tonnes of gold from the US to Europe in just 1 month.
There were also further massive gold airlifts from the US to the Bank of England in the summer of 1968 which ironically the Federal Reserve needed to do so as to pay back physical gold swaps which the Bundesbank had made available to the Americans at the Bank of England during the last days of the London Gold Pool in March 1968.
These rapid and massive physical gold movements over international borders in 1967 and 1968 show how laughable the Bundesbank’s current gold repatriation program actually is, and how servile the mainstream financial media are in not even questioning the timeframe of the Bundesbank’s repatriation operations.
Updated “So-Called” Bar List
Following its press release on 9 February, the Bundesbank then published an updated version of its so-called gold bar list on 23 February, specifying its gold holdings as of 31 December 2016. A so-called gold bar list, because the format of the Bundesbank’s gold bar list does not follow any accepted industry standard format and does not contain basic details such as bar serial number and bar refiner name that are crucial to any normal gold bar weight list. The updated Bundesbank bar list was also released in a very low-key way, and its publication does not seem to have been picked up by any of the mainstream financial media. The updated Bundesbank ‘list’ can be viewed here in a file that the Bundesbank had actually created on 14 February 2017.
The Bundesbank claims that all of its gold bars are good delivery bars, so it and its gold custodians (Bank of England, Banque de France and Federal Reserve Bank of New York) have all of this information stored on their respective gold bar accounting systems, including real bar serial numbers and refiner names. They have to store this information since any bars entering or leaving LBMA network gold vaults need to be accompanied by proper weight lists, including serial number and bar refiner brand.
Compare a proper weight list with the sparse and incomplete what the Bundesbank includes in its gold bar list:
Inventory Number (internal sequence numbers or incomplete bar numbers)
For Germany’s bars listed as held by the Bundesbank, Bank of England and Banque de France, these inventory numbers are merely “internally assigned inventory numbers”, and ludicrously in the case of the Bank of England and Banque de France gold vaults, they only allow other central banks to publish partial internal inventory numbers (the last three digits).
The secrecy with which the Bank of England, Banque de France and other central banks treat real gold bar serial numbers and other identifiers is most likely due to their paranoia that publication of such serial numbers would undermine their ability to operate with secrecy in the gold lending and gold swap market where bar identities might pop up in the gold holdings of commercial operators such as gold-backed Exchange Traded Funds (ETFs).
Numbers listed against Bundesbank bars held at the Federal Reserve Bank of New York do supposedly show a refiner number, or a melt number, but without the refiner name and year of manufacture of these bars being divulged by the Bundesbank, there is no way to verify and cross-check these bar numbers.
Note that this new Bundesbank gold bar list is the third such list that it has published, and it is in the same format as the previous two versions, both of which are also not real gold bar weight lists since they lack refiner serial numbers and refiner names.
For the purposes of this article, let’s refer to a “Bundesbank bar list” as an “incomplete partial weight list”. The Bundesbank had actually signalled the publication of its updated list at the bottom of its 9 February press release, where it stated:
“On 23 February, the Bundesbank will publish an updated list of its gold bars on its website. This list contains the bar, melt or inventory numbers, the gross and fine weight as well as the fineness of the gold.”
3 Bundesbank gold bar lists
To recap, the Bundesbank had already published 2 incomplete partial weight lists. The first of these was published on 7 October 2015 and showed holdings as of 31 December 2014. The file can be accessed here, or at the bottom of the page here. The Bundesbank actually created this file on 5 October 2015 and saved it with a file name of 2015_10_07_gold.pdf.
The Bundesbank’s second incomplete partial weight list was created on 4 February 2016 and listed holdings as of 31 December 2015, and was published sometime after 4 February 2016. Confusingly, the incomplete partial weight list as of 31 December 2015 file was uploaded to the same web page and with the same file name as the 31 December 2014 file (i.e. it was uploaded with the filename 2015_10_07_gold.pdf and it over-wrote the first list). This second incomplete partial weight list can be accessed here.
Why no lists prior to December 2014?
Given that the Bundesbank has now demonstrated its ability to generate files itemising its gold holdings, even with limited bar details, the fact that the Bundesbank only began publishing its gold holdings’ lists in October 2015 should immediately raise suspicion as to why it did not publish such bars lists as of the end of 31 December 2012 (prior to the repatriation beginning), and as of 31 December 2013.
A casual observer would deduct that the Bundesbank does not want anyone to see an itemised list of its gold holdings on these dates in 2012 and 2013, and the casual observer would probably be correct in deducing such a conclusion. For its was during 2013 and 2014 that the Bundesbank melted down and recast 55 tonnes of the gold bars that it had held in New York. Five tonnes of its gold was melted down and recast in 2013 and a whopping 50 tonnes was melted down and recast in 2014. Recall that in January 2014, the Bundesbank stated that during 2013:
”We had bars of gold which did not meet the ‘London Good Delivery’ general market standard melted down and recast. We are cooperating with gold smelters in Europe,” Thiele continued. The smelting process is being observed by independent experts. It is set up in such a manner that the Bundesbank’s gold cannot be commingled with foreign gold at any time.’
“Some of the bars in our stocks in New York were produced before the Second World War.” “Our internal audit team was present last year during the on-site removal of gold bars and closely monitored everything. The smelting process is also being monitored by independent experts.”
“The very same gold arrived at the European gold smelters that we had commissioned.” “The gold was removed from the vault in the presence of the internal audit team and transported to Europe. Only once the gold had arrived in Europe was it melted down and brought to the current bar standard.”
If the Bundesbank had published weight lists as of the end of years 2012 and 2013, then details such as bar gross weight, fineness (gold purity), and bar fine weight would have to have been divulged. By not publishing earlier bars lists, no one outside the Bundesbank – Federal Reserve nexus will ever be aware of the weights and purities of these 55 tonnes of gold bars that were melted down and recast. The Bundesbank obviously has or had the details of these smelted bars, since it commissioned and monitored the smelting process. But as Peter Boeringher stated in his October 2015 article “it appears the bar lists for these transferred bars were lost or destroyed.”
What secrets did these bars hold? One distinct possibility was that they were low-grade coin bars, that had been produced from melted gold coin. In this case they would have been bars of 0.90 or .9167 gold purities or similar. Low grade coin bars began appearing at the NY Fed vault in Manhattan in 1968 and most likely came from the US Treasury’s gold holdings at Fort Knox, Kentucky which consist of about 80% low-grade coin bars. It would not look good for the NY Fed if such low grade bars appeared on a foreign central bank’s gold bar list, and would invariably raise questions as to which US vaults this gold was sourced from.
Perhaps the bars that the Bundesbank melted were Prussian Mint bars from the Nazi era which the Bundesbank would be averse to holding in Germany for political reasons? Or maybe they were problematic US Assay office bars which had a lower fine ounce content than was stated on the actual bar, an issue that dogged another portion of the Bundesbank’s gold stocks in London in 1968. Or perhaps they were gold bars with some other embarrassing provenance which the Bundesbank and Federal Reserve needed to mask the true origin of. Without the Bundesbank ever clarifying this issue, we will never know.
Comparing the 3 Lists
What can we glean from comparing the 3 lists to each other? The only variable on which to compare the lists are gross weight, fineness, and fine weight, and the bar and melt counts per location.
In theory, the lists from December 2014, December 2015 and December 2016 should be identical assuming that the total amount of gold bars has not changed between versions.
If the lists are not identical, then it could suggest a number of things including:
gold bars that were previously held in Melts have now been individually weighed and itemized on the more recent list. This would most likely be for bars that were transferred to Frankfurt, but could also apply to bars which remained in the other storage locations
further instances of gold bars remelted / recast while being transferred from New York or Paris to Frankfurt that the Bundesbank has kept quiet about
gold bars still held in Paris or New York (or London) that have been being recast and upgraded before being moved. This would apply more to Paris going forward
sales of gold bars to ‘fund’ the German official gold coin program.
gold lending / swap / repo transactions
Since the lists do state melt number, if there are less any melt numbers listed in more recent lists compared to older lists, then it means that the Bundesbank or its agents have weighed and itemised the individual bars in various melts (groups of 18-24 bars). For example, if the entries for 20 melts had disappeared from a more recent version of a list, then there should be about 400 extra individual bars of the newer list.
Using some quick eyeballing, the file dated 31 December 2014 has 2307 pages including introduction. The file dated 31 December 2015 has 2401 pages including introduction, i.e. the latter file has 94 extra pages. There are approximately 44 pages of melts in the 2014 file listed from page 2263 to the last page 2307. There are approximately 40 pages of melts in the 2015 file listed from page 2361 to the last page 2401. From a rough count, there are about 85 rows per page. This would mean about 340 melts were weighed and converted into itemised rows of single bars during 2015. Not all melts have full sets of bars, but assuming they did, that would be about 20 bars per melt, which would be about 20*340 = 6800 bars which would appear in individual rows in the 2015 list if the melts were “broken out”, which is about 80 pages, and is fairly near explaining the reason for the extra 94 pages in the 2025 file.
If you look at the number of gold bars listed in the press releases (current version and archived version), you will see that there were in total 270,326 bars at the end of 2014 and 270,058 bars at the end of 2015, so there were 258 less bars at the end of 2015.
As of the end of 2015, there were 34,808 bars in London vs 35,066 bars at the end of 2014. i.e. There were 258 bars less in London (about 3 tonnes). So the London drop explains the total drop. This could be gold used for a gold coin program.
This is just some quick eyeballing. The next step is to do an automated comparison of the 3 lists side by side by comparing the variables gross weight, fineness and fine weight so see which bar details may have changed over the 2 year period, and to look at what might have changed. This matching and calculation exercise will probably be undertaken by a gold bar database expert in the near future, so watch this space for further details.
On 5 February, the Financial Times of London (FT) featured a story revealing that the London Bullion Market Association (LBMA) plans to begin publishing data on the amount of real physical gold actually stored in the London precious metals vaulting network. The article titled “London gold traders to open vaults in transparency push” can be read here (accessible via FT subscription or via free monthly FT read limit).
This new LBMA ‘monthly vault data’ will, according to the FT’s sources, be published on a three-month lagged basis, and will:
“show gold bars held by the BoE, the gold clearing banks, and those [vaults] operated by the security companies such as Brink’s, which are also members of the LBMA.”
The shadowy source quoted in the FT article is attributed to “a person involved in setting up the programme”, but at the same time, although “the move [to publish the data] is being led by the LBMA“, the same LBMA ”declined to comment” for the FT story. This then has all the hallmarks of a typical authorised leak to the media so as to prepare the wider market for the data release.
On 16 February, the World Gold Council in its “Gold Investor, February 2017” publication featured a focus box on the same gold vault topic in its “In the News” section on page 4, where it states:
“Enhanced transparency from the Bank of England
The Bank of England is, for the first time, publishing monthly data revealing the amount of gold it holds on behalf of other central banks.
As a leading custodian of gold, with one of the largest vaults in the world, the Bank of England’s decision is highly significant. Not only will it enhance the transparency of the Bank’s own gold operations; it will also support the drive towards greater transparency across the gold market.
The data reveals the total weight of gold held within the Bank of England’s vaults and includes five years of historical data.”
The Proposed Data
Based on these two announcements, it therefore looks like the gold vault data release will be a combined effort between the LBMA and the Bank of England, the blood brothers of the London Gold Market, with the Bank of England data being a subset of the overall LBMA data. While neither of the above pieces mention a release date for the first set of data, I understand that it will be this quarter, i.e. sometime before the end of March. On a 3 month lagged basis, the first lot of data would therefore probably cover month-end December 2016, because that would be a logical place to start the current dataset, rather than, for example, November 2016.
While the Bank of England data looks set to cover a 5 year historical period, there is no indication (from the FT article) that the wider LBMA vault data will do likewise. From the sparse information in the FT article, the LBMA data will “show gold bars held“. Does it mean number of gold bars, or combined weight of gold bars? What exactly it means, we will have to wait and see.
The Bank of England data will capture “total weight of gold held“. Notice that in the above World Gold Council piece it also states that the data will cover the amount of gold that the Bank of England “holds on behalf of other central banks.” There is no mention of the amount of gold that the Bank of England holds on behalf of commercial bullion banks.
Overall, this doesn’t exactly sound like it is “enhancing the transparency of the Bank’s own gold operations” as the World Gold Council puts it. Far from it. Enhancing the transparency of the Bank of England’s gold operations would require something along the lines of the following:
Identities of all central banks and official sector institutions (ECB / IMF / BIS / World Bank) holding active gold accounts at the Bank of England. Active gold accounts meaning non-zero balances
Identities of all commercial / bullion banks holding active gold accounts at the Bank of England
A percentage breakdown between the central bank gold held in the Bank of England vaults and the bullion bank gold held in the Bank of England vaults
An indicator for each gold account as to whether it is a set-aside earmarked custody account or whether it is a fine troy ounce balance account
Information for each central bank and official sector institution as to whether any of “its” gold is lent, swapped or repo’d
Information for the bullion bank gold accounts as to whether the gold recorded in those accounts is borrowed, sourced from swaps, sourced from repos, or otherwise held as collateral for loans
Information on the gold accounts of the 5 LPMCL clearing banks showing how much gold each of these institutions holds each month and whether the Bank of England supplies physical gold clearing balances to these banks
Information on when and how often the London-based gold-backed ETFs store gold at the Bank of England, not just using the Bank of England as sub-custodian, but also storage in their own names, i.e. does HSBC store gold in its own name at the Bank of England which is used to supply gold to the SPDR Gold Trust
Information on whether and how often the Bank of England intervenes into the London Gold Market and the LBMA Gold Price auctions so as to supply gold in price smoothing and price stabilisation operations in the way that the Bank of England’s Terry Smeeton seems to have been intervening into the London Gold Market in the 1980s
Information on the BIS gold holding and gold transactions settlements accounts at the Bank of England and the client sub-account details and central bank identities for these accounts
Information on gold location swaps between gold account holders at the Bank of England and gold accounts at the Federal Reserve Bank of New York, the Banque de France, and the Swiss National Bank, and BIS accounts in those locations
Gold for oil swaps and oil for gold swaps
Anything less is just not cricket and does not constitute transparency.
And its important to remember that any publication of gold vault data by the LBMA and Bank of England is not being done because the LBMA suddenly felt guilty, or suddenly had an epiphany on the road to Damascus, but, as the FT correctly points out:
“the LBMA, whose members include HSBC and JPMorgan, hopes to head off the challenge and persuade regulators that banks trading bullion should not have to face more onerous funding requirements.”
The Current Data
As a reminder, there is currently no official direct data published on the quantity of real physical gold bars held within the London gold vaulting system. This vaulting system comprises the vaults of eight vault operators (see below for list).
Once a year in its annual report, the Bank of England provides a Sterling (GBP) value of gold held by its gold custody customers, while the LBMA website states a relatively static total figure of “approximately 6,500 tonnes of gold held in London vaults” that it claims are in the vaults in its network. But beyond these figures, there is currently no official visibility into the quantity of London Good Delivery gold bars held in the London vaults. There are, various ways of estimating London gold vault data using the Bank of England annual figure and the LBMA figure together with Exchange Traded Fund gold holdings and central bank divulged gold holdings at the Bank of England.
The September 2015 estimates calculated that there were 6,256 tonnes of gold in total in the London vaults, with 5,134 tonnes at the Bank of England (as of end February 2015), and 1,122 tonnes in London “not at the Bank of England“, all of which was accounted for by gold-backed ETFs which store their gold in London. These calculations implied that there was nearly zero gold stored in London outside the Bank of England that was not accounted for by ETF holdings.
The “Tracking the gold held in London” estimates from September 2016 used a figure of 6,500 tonnes of gold in total in the London vaults, and showed that there were 4,725 tonnes inside the Bank of England vaults, of which about 3,800 tonnes was known to be held by central banks (and probably a lot of the remainder was held by central banks also) and that there were 1,775 tonnes of gold outside the Bank of England. The article also calculated that there were 1,679 tonnes of gold in the gold backed ETFs that store their gold in London, so again, there was very little gold in the London vault network that was not accounted for by ETFs and central bank gold.
The Vaults of London
Overall, there are 8 vault operators for gold within the LBMA vaulting network. These 8 vault operators are as follows:
The Bank of England
HSBC Bank plc
JP Morgan Chase
ICBC Standard Bank Plc
Malca-Amit Commodities Ltd
G4S Cash Solutions (UK) Limited
Loomis International (UK) Ltd
HSBC, JP Morgan and ICBC Standard are 3 of the London Gold Market’s clearing banks that form the private company London Precious Metals Clearing Limited (LPMCL). The other two member of LPMCL are Scotia Mocatta and UBS. Brink’s, Malca-Amit, G4S and Loomis are the aforementioned security companies. The LBMA website lists these operators, alongside their headquarters addresses.
Bizarrely, the FT article still parrots the LBMA’s spoon-fed line that the vaults are “in secret locations within the M25 orbital motorway”. But this is far from the truth. Many of the London vault locations are in the public domain as has been covered, for example, on this website, and the FT knows this:
It’s slightly disappointing that we spend time and effort informing the London financial media where some of the London gold vaults are, and then they continue to parrot the LBMA’s misleading “secret locations” line. I put this fake news down to a decision by the FT editors, who presumably have a stake in playing along with this charade so as not to rock the boat with the powerful investment banks that they are beholden to.
The FT also reminds us in its article that “last year a gold vault owned by Barclays, which can house $80bn of bullion, was bought by China’s ICBC Standard Bank.“
This Barclays vault in London was built by and is operated by Brink’s, and presumably after being taken over by ICBC Standard, it is still operated by Brink’s. Logistically then, this ICBC Standard vault is most likely within the Brink’s complex, a location which is also in the public domain, and which even hosts an assay office as was previously mentioned here over a year ago. The Barclays vault (operated by Brink’s) is even mentioned in a Brink’s letter to the SEC in February 2014, which can also be seen here -> Brinks letter to SEC February 2014.
Given the fact that there are eight sets of vaults in the London vault system (as overseen by various groups affiliated to the LBMA such as the LBMA Physical Committee, the LBMA Vault Managers Working Party, the gold clearers (London Precious Metals Clearing Limited), and even the LBMA Good Delivery List referees and staff, then one would expect that whatever monthly vault data that the LBMA or its affiliates publishes in the near future, will break out the gold bar holdings and have a distinct line item in the list for each vault operator such as:
HSBC – w tonnes
JP Morgan – x tonnes
ICBC Standard – y tonnes
Brink’s – z tonnes
At the LBMA conference in Singapore last October, there was talk that there were moves afoot for the Bank of England to begin publishing data on the custody gold it holds on a more regular basis. It was also mentioned that this data could be extended to include the commercial bank and security carrier vaults but that some of the interested parties were not in favour of the idea (perhaps the representative contingents of the powerful HSBC and JP Morgan). Whatever has happened in the meantime, it looks like some data will now be released in the near future covering all of the participating vaults. What this data will cover only time will tell, but more data than less is always welcome, and these data releases might also help show how near or how far we were with earlier estimates in trying to ascertain how much gold is in the London vaulting system that is not accounted for by ETF holding or central bank holdings.
Revealing the extent of the gold lending market in London is critical though, but this is sure to remain a well-kept secret, since the LBMA bullion banks and the Bank of England will surely not want the general market to have any clue as to which central banks don’t really have any gold while still claiming to have gold (the old gold and gold receivables trick), in other words, that there is serious double counting going on, and that some of the central bank gold has long gone out the door.
This is Part 2 of a two-part series. Part 1 of this series, “Ireland’s Monetary Gold Reserves: High Level Secrecy vs. Freedom of Information – Part 1” published on 23 January, looked at initial attempts in 2011 and 2012 to extract basic information about Ireland’s monetary gold reserves from the Central Bank of Ireland and the Irish Department of Finance. These attempts proved unsuccessful due to non-cooperation from the central bank which at that time was not covered under the Irish Freedom of Information Act (FOI Act), and also a bizarre refusal of a FOI request from the Department of Finance and a subsequent claim by that Department that it had zero records of said gold reserves that it has entrusted to the Central Bank of Ireland (a central bank which it owns).
On 14 October 2014, a new and expanded Freedom of Information Act was enacted into law in the Republic of Ireland. This news FOI Act (2014) extended the scope of coverage of Freedom of Information requests to “All Public Bodies” in the Irish State, and for the first time included Ireland’s central bank, the Central Bank of Ireland. Information and records relating to the expanded list of public bodies are not fully retrospective, and FOI requests under the new FOI Act (2014) only cover the right of access to records created by these additional public bodies on or after 21 April 2008.
FOI to the Central Bank of Ireland – 2015
Given the introduction of the new FOI Act (2014) and the fact that it covered the Central Bank of Ireland, on 21 June 2015 I submitted a FOI Request to the Central Bank of Ireland with a series of questions about Ireland’s gold reserves. I was cognizant of the fact that the FOI Act only covered records after 20 April 2008 so I structured the questions to take account of this time limitation. The Central Bank of Ireland financial year follows the calendar year, with the annual financial accounts being made up to 31 December (i.e. calendar year-end). Therefore, the logical place to start was with the central bank’s 2009 Annual Report and 2010 Annual Report.
In the 2009 annual report, page 77, note 10 to the Balance Sheet for the line item “Gold and Gold Receivables” states that:
“With the exception of coin stocks held in the Bank, gold holdings consist of deposits with foreign banks. The change in the balance in 2009 is due to the change in the market value of gold during the year.”
In the 2010 annual report, page 98, note 10 to the Balance Sheet for line item “Gold and Gold Receivables” states that:
“Gold and gold receivables represent coin stocks held in the Bank, together with gold bars held at the Bank of England. The increase in the balance in 2010 is due to the change in the market value of gold during the year.”
Notice the difference in wording between the 2009 and 2010 annual reports. Exclusive of the gold coin holdings, the gold reserves in 2009 were stated as consisting of “deposits with foreign banks” while in 2010, the gold reserves were stated as consisting of “gold bars held at the Bank of England“, i.e. one is gold deposits with foreign banks (plural) and the other is allocated gold bars at a specific location (i.e. the Bank of England).
If you go back further and look at earlier annual reports of the Central Bank of Ireland from the years 2008 and 2007, the wording used is “gold holdings consist of deposits with foreign banks.“ Going back another year to 2006, that year’s annual report contained a critical passage on the Irish gold holdings which stated that:
“The gold is held in physical form and ….may be placed on deposit in the London gold market depending on market conditions”.
See screenshot below.
Note 10 to the Balance Sheet for line item “Gold and Gold Receivables” in the 2006 annual report, page 89, stated in a similar way to the 2007 -2009 annual reports, that:
“With the exception of coin stocks held in the Bank, gold holdings consist of deposits with foreign banks. The change in value is due mainly to the change in the market value of gold during the year.”
The phrase “gold holdings consist of deposits with foreign banks”refers to gold placed on deposit in the London Gold Market, i.e. these gold deposits are central bank gold lending deposits placed with commercial bullion banks.
In fact, the phrase “gold holdings consist of deposits with foreign banks” is stated in all the Central Bank of Ireland annual reports from 2009 all the way back to the 2000 Annual Report.
Given that the Central Bank of Ireland Annual Report 2010 stated that the gold holdings consisted of “gold bars held at the Bank of England“, my FOI request asked for details of these gold bars in the form of a gold bar weight list. Because, if one claims to have physical gold bars stored at the Bank of England, one certainly has access to produce a weight list with the details of said gold bars.
Since the form of the Central Bank of Ireland’s gold holdings changed from “deposits with foreign banks” in 2009 to gold bars held at the Bank of England“ in 2010, myFOI Request also asked for records of any correspondence relating to this change. Gold deposits are on a fine ounce basis, gold bars held are on an allocated bar set-aside basis. They are two very different things. When you put gold on deposit with a bullion bank (i.e. lend it), you get back the same amount of gold that you placed on deposit (and maybe interest in the form of gold), but you don’t necessarily get back the same gold bars, since the bullion bank probably sold or lent on the gold that you deposited.
FOI Request Wording
The FOI Request I submitted to the Central Bank of Ireland on 21 June 2015 was as follows (in blue text) and contained 2 parts, the second part of which had 2 questions:
“Dear FOI Unit,
This is a request being made under the Freedom of Information Act 2014.
I would like to request that a copy of documents (such as paper records, records held electronically, email correspondence) containing the following information be provided to me:
“1. Details of the gold holdings of the Central Bank of Ireland during 2009 which consisted of “deposits with foreign banks” as specified on page 77 of the 2009 Annual Report.
The details I am requesting are:
– the names of the foreign banks that the Central Bank of Ireland gold was deposited with during 2009, the duration of these gold deposits during 2009, details of the interest earned on these gold deposits, and information on the dates on which these gold deposits ended (since the gold holdings were not on deposit in 2010).
Source for reference: In the 2009 Annual Report, Note 10 to the Statement of Accounts, Page 77 states: “Gold and Gold Receivables With the exception of coin stocks held in the Bank, gold holdings consist of deposits with foreign banks”
2. Details of the gold holdings of the Central Bank of Ireland during 2010 which consisted of “gold bars held at the Bank of England” as specified on page 98 of the 2010 Annual Report.
I am requesting the following information on the “gold bars held at the Bank of England”:
– A document, such as a weight list, bar list, or bullion weight list, that uniquely identifies the bars of gold held on behalf of the Central Bank of Ireland by the Bank of England. This list would include (for each bar), details such as bar brand, bar serial number (serial number from refiner, not Bank of England number), year of manufacture of bar, gross weight, fineness, fine ounces.
– Information or correspondence that discusses the rationale for switching the Central Bank of Ireland’s gold holdings from “deposits with foreign banks” in 2009 (see above) into “gold bars held at the Bank of England” in 2010.
Source for reference: In the 2010 Annual Report, Note 10 to the Statement of Accounts, Page 98 states “Gold and Gold Receivables Gold and gold receivables represent coin stocks held in the Bank, together with gold bars held at the Bank of England.”
On 6 July 2015, the Central Bank of Ireland FOI Unit responded to me by email with an acknowledgement of my FOI Request, which can be viewed here -> Acknowledgement Letter CB of Ireland FOI gold 20150706. This letter also includes my full FOI request as per the blue text above.
FOI Request Refused in Entirety
On 20 July 2015, I received an email from a “FOI Decision Maker” at the Central Bank of Ireland with an attached letter detailing the fact that he had fully refused by FOI Request and his rationale for doing so. That letter can be viewed here -> FOI gold reserves Decision Letter refusing FOI Request – 20 July 2015. The introduction to the letter stated:
“A final decision was made to refuse your request by myself, Xxxxxxx Xxxxx, FOI Decision
Maker, today, 20 July 2015. I may be contacted by telephone on (01) xxx xxxx in order to
answer any questions you may have, and to assist you generally in this matter.”
Recall that my first question was asking the central bank to provide records “containing the names of the foreign banks that the Central Bank of Ireland gold was deposited with during 2009, the duration of these gold deposits during 2009, details of the interest earned on these gold deposits, and information on the dates on which these gold deposits ended” i.e. information about gold deposits a.ka. gold lending.
In his response, the FOI Decision Maker referred to this question as ‘Category 1’. He completely ignored the fact that I was asking about gold lending and stated that “Please note that the Central Bank of Ireland’s gold bars were held with the Bank of England during the course of 2009.”
This was a completely redundant and misleading statement because with gold lending, the lent gold does not necessarily leave the Bank of England. It stays in the Bank of England vault wherein title is transferred to bullion bank gold accounts during the deposit period and more than likely the deposits are then rolled over into other short-term gold deposits with additional bullion banks. It was also a deflection of my question since it ignored the fact that the 2009 Annual Report had stated that “gold holdings consist of deposits with foreign banks“, and failed to explain why the Annual report had referred to deposits with foreign banks (plural).
The FOI Decision Maker went on to say that he had “identified one record falling within the scope of your request, namely a statement from the Bank of England dated 31 December 2009 confirming the number of gold bars held with the Bank of England on that date”, but that he had “made a decision to refuse this part of your request for the following reasons“.
This is where the central bank FOI fiasco became even more bizarre and ludicrous, or in the words of an ex-Irish Taoiseach (Prime Minister), it became “grotesque, unbelievable, bizarre and unprecedented (GUBU)”, because the FOI Decision Maker claimed he was refusing the request to provide the Bank of England gold bar statement by invoking a clause in the FOI Act (2014) [Section 40 (1) of the Act] that allowed an exemption if:
“access to the record could reasonably be expected to have a serious, adverse effect on the ability of the Government to manage the national economy or on the financial interests of the State…”
The FOI Decision Maker also stated that in his view “the release of detailed information regarding the gold bars held at the Bank of England on behalf of the Central Bank of Ireland could have a serious, adverse effect on the financial interests of the State, as it would disclose important information about the Central Bank’s gold holdings.”
Releasing information about gold bars would disclose important information about those same gold bars? No kidding?
He went on to state: “Furthermore the release of this information, which is of substantial value, would identify the stock of gold coins held at the Central Bank from the stock of gold bars held at the Bank of England and from which a market valuation for the separate holdings could easily be calculated.” And? Why would this be a big deal? It would not be a big deal. The gold coin holdings of the Central Bank of Ireland are quite immaterial and completely incidental to the questions raised in my FOI request.
Not to labour the point, but this FOI Decision Maker continued to dig a hole with the embarrassing excuses as he considered “public interest factors for and against the release of this information” and stated that“while there is public interest in ensuring transparency and accountability of public bodies, I believe that interest is outweighed by the public interest in protecting the confidentiality of asset valuation information, pertaining to the financial circumstances of the Central Bank” so that “accordingly, I believe the public interest is better served by refusing, rather than granting, access to this record.”
Now you can see what we are up against when small-minded central bank bureaucrats are unleashed and given a small amount of power in their FOI Unit fiefdoms to pronounce and decide on what they think is and is not in the public interest.
Question: Who voted that these anonymous central bank staffers should have the power to say what is and what is not in the public interest? Answer: Nobody did.
The second part of my FOI Request asked the Central Bank of Ireland to provide “a weight list, bar list or bullion weight list that uniquely identifies the bars of gold held on behalf of the Central Bank of Ireland by the Bank of England“. After all, the 2010 Annual Report stated that the gold holdings of the Central Bank of Ireland were in the form of “gold bars held at the Bank of England.”
A gold bar weight list is an itemised list of all the gold bars held within a holding that uniquely identifies each bar. In the London Gold Market, the LBMA’s “Good Delivery Rules” specifies the data that this list should contain for the large 400 oz bars as held by central banks. The data in a weight list includes such details as the bar serial number, the refiner name, the gross weight of the bar in troy ounces, the gold purity of the bar and the fine weight of the bar in troy ounces. All gold being shipped in and out of gold vaults in the London Gold Market, including in and out of the Bank of England vaults, has to be accompanied by a proper industry standard weight list. Gold Backed Exchange Traded Funds (ETFs) produce these weight lists for their gold holdings at the end of each and every trading day so it’s not a big task to produce such a list via a position / accounting system.
So, if you have gold bars held at the Bank of England, like the Central Bank of Ireland claims to have, then you certainly have access to a weight list provided by the Bank of England since the Bank of England has a gold bar accounting system which records all of this information. In fact, the Bank of England has provided such a gold bar list to the Reserve Bank of Australia (RBA) for the 80 tonnes of gold that the RBA stores at the Bank of England. This list came to light via an Australian FOI request, and the Aussie list can be seen here.
A full weight list would also be needed when undertaking a physical gold bar audit, which is something that the large gold-backed ETFs perform twice per year. Keep this in mind for anyone wanting to ask the Central Bank of Ireland how, if ever, they audit the Irish gold stored at the Bank of England.
Given all of this background, the following statement from the Central Bank of Ireland FOI Decision Maker as to why he was refusing my request for a gold bar weight list is nothing short of incredible, because he said:
“Section 15(1)(a) of the Act states that a FOI request may be refused if:
‘the record concerned does not exist or cannot be found after all reasonable steps to ascertain its whereabouts have been taken,’
Your request was referred to two divisions within the Central Bank of Ireland, the Payment and Securities Settlement Division and the Currency Issue Division. Both divisions have confirmed that they do not hold any such records which fall within the scope of this part of your request. Accordingly, this part of your request is refused.”
If the Central Bank of Ireland holds gold bars at the Bank of England, then it is a lie to state that a weight list does not exist, because a weight list has to exist even if it is in the gold bar accounting system of the Bank of England and has not been printed.
If the Central Bank of Ireland is claiming that it doesn’t have such a list, then this shows a shocking lack of oversight with regards to the Irish gold holdings at the Bank of England. It could arguably also show a convenient laziness to acquiring such a list which the central bank could then use as a plausible deniability scenario.
On my request for records which addressed “the rationale for switching the Central Bank of Ireland’s gold holdings from “deposits with foreign banks” in 2009…into “gold bars held at the Bank of England” in 2010, the FOI Decision Maker again avoided any discussion of gold lending and reverted to reiterating that:
“the Central Bank of Ireland’s gold bars were held with the Bank of England during both 2009 and 2010. Given that there was no switching from foreign banks to the Bank of England, no records exist which fall within the scope of this part of your request and this part of your request is, therefore, refused.”
There was no explanation offered by this Decision Maker as to why the wording between the 2009 and 2010 annual reports had changed.
The FOI Refusal letter wrapped up with a “Right of Review” paragraph which explained that it was possible to seek an internal review of the decision by a more senior staff member of the Central Bank by a written submission to the Central Bank of Ireland FOI Unit stating the reasons for seeking a review and accompanied by a €30 internal review fee.
The refusal letter ended by saying “should you have any questions or concerns regarding the above, please contact me by telephone on +353 1 xxxxxxx“. So I decided to take up the offer of the FOI Decision Maker, and gave him a call the next day.
Phone Call with the FOI Decision Maker
The following is a summary of the phone call I had with the Central Bank of Ireland FOI Decision Maker after he had refused my FOI Request.
Part of my FOI had asked the central bank to explain the change in wording between 2009 and 2010 where the annual report in 2009 had said the gold was on deposit with foreign banks, while the 2010 annual report said the gold was held in the form of gold bars at the Bank of England.
On the phone call, the FOI Decision Maker said that these two descriptions were referring to the same gold and that the Central Bank of Ireland just changed the wording in the 2010 annual report to be more specific. I don’t believe this, but anyway, he said the justification that it was the same thing being described was because the 2010 report lists both the 2010 data and the 2009 data in two columns side by side with the same footnote (gold held in the Bank of England).
He said the central bank senior accounting person had explained this to him and that she had said that ‘there was no change in investment policy‘. [This could mean anything, including that the gold might still be on loan]. Given that one of my previous questions to the central bank prior to 2014 asking it to explain its investment policy on gold had been met with non-cooperation and “talk to the hand” (see Part 1), then its impossible to know what the Central Bank of Ireland’s investment policy on gold is or was in the first place.
I then explained to the FOI Decision Maker about gold lending with commercial banks using Bank of England customer gold, and asked him to explain why the wording had said ‘gold deposits’ with ‘foreign banks’ (plural) all the way through from 2000 to 2009 and that its documented in the 2006 annual report that the bank engaged in gold lending in the London Gold Market. He could not explain this, but he seemed to be hesitant when I was talking about gold lending. He also said that since the Central Bank of Ireland is only subject to the Irish FOI Act for any data since mid 2008 (which is true), then he couldn’t comment on anything in the year 2008 or before that. A nice handy get out clause for him.
Next up, he said that they found one ‘custodian statement’ dated 2009 from the Bank of England which specified number of gold bars and fine ounces held, and they were considering providing this statement to me. This is where the FOI gets bizarre.
He said that they had 2 conference calls with the Bank of England trying to find out if there was a weight list and also about releasing this statement to me. The second conference call even included the “chief security officer” from the Bank of England FOI office, but that the Bank of England told the Central Bank of Ireland guy that ‘you absolutely cannot‘ send this statement out with bars total and fine ounces since its ‘highly classified‘ and ‘highly‘ something else (I didn’t catch the 2nd ‘highly’ as I was stunned while trying to jot down the notes during the call).
Talk about national security. So here we have the Bank of England instructing another sovereign central bank (the Central Bank of Ireland) in what it’s allowed to and not allowed to release in its own FOIs. I think the Irish Office of the Information Commissioner and any decent Irish journalists might be interested in this, and how the Bank of England was meddling in an Irish FOI Request.
The FOI Decision Maker had said in his letter that the data I was looking for concerned ‘important information about the Central Bank gold reserves‘. When I pointed out that of course it does, that was the whole point of my FOI request, he said ‘well, the FOI Act was not designed with the Central Bank in mind. we have a lot of confidential data etc‘. Again you can see this typical aloof central banker interpretation of the FOI legislation.
I concluded by asking him if there was any point in sending in fresh FOI requests. He said if they are for records, yes, but he tried to steer me in the direction of asking questions to their press office.
FOI Appeal to the Central Bank of Ireland
Next up, I decided to appeal the FOI response by annihilating the spurious excuses put forward by the Central Bank of Ireland FOI Decision Maker, and also by arguing that a UK central bank has no right to interfere in determining a FOI Request that falls under Irish law. I sent the following FOI Internal Review / Appeal request to the Central Bank of Ireland on 18 August 2015:
“Hello FOI Unit,
I would like to seek an internal review / appeal of the final decision of Freedom of Information request (ref: 2015-000132) made by Xxxxxxx Xxxxx, FOI Decision Maker, sent by email to me on 20th July 2015. This decision refused my request of 21st June 2015.
Reasons for seeking the Review
I have documented below the reasons why I am seeking a review of the decision, and listed them by number.
Part of my request was to obtain details of the gold bars held on behalf of the Central bank of Ireland at the Bank of England. Such a record does exist.
The FOI Decision Maker says in his decision: “I have identified one record falling within the scope of your request, namely a statement from the Bank of England dated 31 December 2009 confirming the number of gold bars held with the Bank of England on that date.”
The FOI Decision Maker quotes from “Section 40 (1) of the Act”:
(a) access to the record could reasonably be expected to have a serious, adverse effect on the ability of the Government to manage the national economy or on the financial interests of the State…”
and he specifically says:
“In my view, the release of detailed information regarding the gold bars held at the Bank of England on behalf of the Central Bank of Ireland could have a serious, adverse effect on the financial interests of the State, as it would disclose important information about the Central Bank’s gold holdings.”
There was no proof proved by the FOI Decision Maker as to how releasing a statistic stating the number of gold bars held by the Central Bank of Ireland could “have a serious, adverse effect on the financial interests of the State.”
Likewise, there was no proof provided as to how disclosing “important information about the Central Bank’s gold holdings” could have a “could have a serious, adverse effect on the financial interests of the State.”
I would like a review of the decision to withhold the Bank of England statement dated 31st December 2009 reviewed, with a view to releasing said statement to me.
A follow-up call with the FOI Decision Maker on 21st July about the decision revealed that the Central Bank of Ireland had conducted 2 conference calls with the Bank of England about my request, with the second conference call even including a ‘chief security officer’ or similar from the Bank of England FOI office, and that the Bank of England told the Central Bank of Ireland that ‘you absolutely cannot’ send this statement out with bars total and fine ounces since its ‘highly classified’.
I find it unacceptable that a request made under the Freedom of Information Act of Ireland can allow interference from a foreign central bank in determining its outcome. This is the Bank of England interfering in the Freedom of Information Act of another sovereign nation. Any input from the Bank of England in this matter should be inadmissible and I would like these interactions with the Bank of England to be reviewed as part of the appeal, and how a statement of gold bars can be said to be ‘highly classified’.
The FOI Decision Maker says “the release of this information, which is of substantial value, would identify the stock of gold coins held at the Central Bank from the stock of gold bars held at the Bank of England and from which a market valuation for the separate holdings could easily be calculated.”
“While there is public interest in ensuring transparency and accountability of public bodies, I believe that interest is outweighed by the public interest in protecting the confidentiality of asset valuation information, pertaining to the financial circumstances of the Central Bank.”
3. The asset valuation information of gold holdings is not confidential. In line with international accounting standards Central Bank of Ireland gold is valued at market value in the Balance sheet. The FOI Decision Maker’s explanation does not make any sense, and only serves to deflect my request. My request is not about gold coins. Introducing that argument is spurious and irrelevant.
The FOI Decision Maker says: “Your request was referred to two divisions within the Central Bank of Ireland, the Payment and Securities Settlement Division and the Currency Issue Division. Both divisions have confirmed that they do not hold any such records which fall within the scope of this part of your request.”
All foreign gold held in custody at the Bank of England is weight listed. I am submitting to you evidence of this fact in the form of a response to a Reserve Bank of Australia (RBI) freedom of information request in 2014 where the RBI responded to the request with a full Excel spreadsheet “Listing of the Reserve Bank of Australia’s gold inventory as held at the Bank of England”. See details below.
A freedom of Information request to the Reserve Bank of Australia in 2014
It is a minimal requirement in international auditing standards to have access to details of assets held in custody.
In refusing my request, there was no explanation as to why the Bank of England has not provided such as weight list of gold bars to the Central Bank of Ireland. I would therefore like to appeal this finding also that the Central Bank of Ireland cannot request and provide a weight when other central banks, such as the RBI, can.
The 2009 Central bank of Ireland annual report states that gold holdings consisted of “deposits with foreign banks” as specified on page 77 of the 2009 Annual Report.
The 2010 Central Bank of Ireland annual report states that gold holdings during 2010 consisted of “gold bars held at the Bank of England” as specified on page 98 of the 2010 Annual Report.
The 2009 reference refers to gold deposits as distinct to gold in custody. The 2009 reference also refers to foreign banks in the plural.
The FOI response did not provide any explanation as to why the 2009 annual report used the wording of gold ‘deposits with foreign banks’ (in the plural).
The response merely stated that “the Central Bank of Ireland’s gold bars were held with the Bank of England during the course of 2009.” Gold on loan does not move, it stays in the Bank of England, and so this statement that “the Central Bank of Ireland’s gold bars were held with the Bank of England during the course of 2009” does not address the issue of the “deposits with foreign banks”.
The FOI refusal of ‘Category 2(b)” of my request uses the above justification (i.e. “the Central Bank of Ireland’s gold bars were held with the Bank of England during the course of 2009”). Since there was no adequate explanation of the references to “deposits with foreign banks”, then this is not adequate grounds for refusal and I would like this reviewed.
The FOI Decision Maker says: “there is sufficient information in the public domain regarding the gold holdings of the Central Bank of Ireland.”
This is a subjective assessment. If there was sufficient information in the public domain regarding the gold holdings of the Central Bank of Ireland I would not have felt the need to submit a Freedom of Information request.
The public interest calls for transparency and accountability by the Central Bank of Ireland. The Central Bank of Ireland reports to the Minister of Finance who, as part of the Irish Government, works on behalf of the citizens of Ireland. In my view, refusing my request undermines the public interest and erodes transparency and accountability, and is not in the spirit and keeping of the Freedom of Information Act.
In summary, the response letter, which was written by a separate FOI Decision Maker stated that:
“I am a more senior member of staff than the original decision maker in this case and I have decided on 2nd September 2015 to vary the original decision on your request.”
“In making my decision, I have had regard to the original request, the records which were located as part of that request, and the appeal letter which you submitted in this regard.”
” I have identified two records which fall within the scope of the first part of your request, namely the 2009 and 2010 statements received from Bank of England. I
have decided to vary the original decision in respect of releasing the main text of these statements“
” In my opinion, disclosing the total gold holdings in the Bank of England from which an estimate of the gold holdings in the Currency centre could be deduced would not unduly increase the security threat to the Currency centre when compared to the value of banknotes issued into circulationby the Central Bank. Therefore, in my view, the disclosure of the number of gold bars and fine ounces held in the Bank of England in 2009 and 2010, as recorded in the two statements, is unlikely to have a ‘serious adverse effect’ on the financial interests of the State“
“With regard to the second part of your request, I am satisfied that there is no record detailing the weight list, bar list, or bullion weight list, that uniquely identifies the bars of gold held on behalf of the Central Bank of Ireland by the Bank of England for the period 2009/10. I am advised that the Bank of England is unable to provide holdings bar lists which are past dated.
Accordingly, I have decided to affirm the original decision in respect of the second part of your request and …on the grounds that “the record concerned does not exist or cannot be found after all reasonable steps to ascertain its whereabouts have been taken.”
” You were also advised verbally by the original Decision Maker that a redrafting of
note 10 to the Statement of Accounts took place in 2010 to provide a more accurate
reflection of the external gold holdings of the Central Bank of Ireland.“
From the above you can see that:
a) There was no explanation offered by this second FOI Decision Maker to explain why the first FOI Decision Maker had made a misleading and erroneous statement that the release of record would have a “serious adverse effect on the financial interest of the State. Putting it into context, this statement by the first FOI Decision Maker was just bluff or in common parlance it was ‘horse manure’.
b) There was no comment or acknowledgement by the second FOI Decision Maker about a foreign central bank, i.e. the Bank of England, meddling in and sabotaging an initial FOI Request, or the presence of a Bank of England FOI security officer on a conference call saying “absolutely this guy cannot have this gold bar statement” since its “highly classified”.
c) This second FOI Decision Maker inadvertently stated that the gold coin holdings held by the Central Bank of Ireland are stored in its ‘Currency centre’ premises, which is located in Sandyford, County Dublin, in a low rise secure building in campus type grounds. No part of my FOI Request or Review asked about these gold coin holdings. But since the second FOI Decision Maker volunteered this information, we now know where the domestically stored gold coin holdings are located.
d) The second FOI Decision Maker stated that there is no record “that uniquely identifies the bars of gold held on behalf of the Central Bank of Ireland by the Bank of England for the period 2009/10.”
If the Irish gold couldn’t be uniquely identified over these years (2009 and 2010), then it would suggest that is was not held in custody on a set-aside / earmarked / allocated basis as specific gold bars, and therefore the claim of the Central Bank of Ireland in its 2010 annual report that it held “gold bars at the Bank of England” is misleading.
e) “I am advised that the Bank of England is unable to provide holdings bar lists which are past dated.” This sounds unbelievable. The Bank of England has a sophisticated gold bar accounting system, and has had one since at least the late 1970s. The Bank of England currently also uses a Book Entry Transfer system (BETs) to transfer gold bars between accounts, a system which would itself need archiving capabilities.
All financial market position and transaction systems have archive capabilities. Historic records in financial markets have to be held for multiple years on electronic storage backup and in offsite backup should clients/customers request such details. To use an excuse that the Bank of England cannot generate a gold bar list for any past date is insulting and infantile. It also shows that the Central Bank of Ireland has no independent oversight or control over the reporting of its gold holdings at the Bank of England.
f) “Aredrafting of note 10 to the Statement of Accounts took place in 2010 to provide a more accurate reflection of the external gold holdings of the Central Bank of Ireland”. Taken on face value, this would imply that the 2009 Annual Report of the Central Bank of Ireland was misleading and not accurate. However, at no point in any annual report was there any note or explanation to acknowledge that any redrafting had taken place to provide a more accurate explanation.
There was also no explanation offered by the second FOI Decision Maker as to what “deposits with foreign banks” (in the plural) referred to in the 2009 annual report, as per point 5 in my FOI Review Request.
The Released Records
The 2 statements that the second FOI Decision Maker decided to allow to be released were 2 Swift statements of gold balances for year-end 2009 and 2010, sent from the Bank of England to the Central Bank of Ireland. The release schedule for the statements can be viewed here -> 2015-000132 Schedule. The actual statements, which the Central Bank of Ireland redacted in parts to remove swift codes, can be seen here -> 2015-000132 Records swift. Each of the statements is 6 pages long but contains mostly irrelevant swift formatting etc. The only relevant part of each statement is at the bottom of page 1 of each respective statement, where a varying gold balance is stated, against a total number of bars. That a weight list cannot be produced shows that this gold is not held on an earmarked set-aside basis but merely on a fine ounce basis (like a cash account) and that the number of bars mentioned on the statement is just an input that was added at some historical point in time when the account became a gold balance account.
For 2009 the statement is as follows:
GOLD BAL 258
WE CAN CONFIRM THE FOLLOWING BALANCE HELD IN YOUR ACCOUNT
ACCOUNT TITLE: CENTRAL BANK OF IRELAND
NO OF BARS: 453
FINE OUNCES GOLD: 182,556.209
For 2010, the statement is as follows:
GOLD BAL 258
WE CAN CONFIRM THE FOLLOWING BALANCE HELD IN YOUR ACCOUNT
ACCOUNT TITLE: CENTRAL BANK OF IRELAND
NO OF BARS: 453
FINE OUNCES GOLD: 182,555.914
This is the data which the first FOI Decision Maker said that “access to the record could reasonably be expected to have a serious, adverse effect on the ability of the Government to manage the national economy or on the financial interests of the State…” He has got to be joking, right?
The examples set out in Parts 1 and 2 of this series will hopefully demonstrate to readers the disdain with which the Central Bank of Ireland and the Irish Department of Finance treat Freedom of Information Requests. I have detailed numerous examples where simple questions about the Irish gold reserves have been ignored, blocked, and refused, even when under the remit of the FOI legislation.
However the Central Bank of Ireland has complete contempt for FOI Acts and everything the FOI Act stands for. This is a wide ranging and live issue as the following recent article in the Irish media highlights. An Irish Times article dated 10 June 2016 and titled “Central Bank ordered to review refusal of access to records“, highlights that the independent Information Commissioner said that his office had had “great difficulty in dealing with the bank in respect of the extent of our jurisdiction”, and said that a recent FOI case that was raised showed “the Bank was ‘entirely at odds’ with the spirit and intent of the FOI legislation.”
The same article quoted the Central Bank as saying that is was “fully committed to meeting the Freedom of Information principles of openness, transparency and accountability, and to the provision of access to records in accordance with its obligations under the Freedom of Information Act.”
But this is a complete lie. As demonstrated by the arrogance and lack of cooperation of the Central Bank of Ireland on the topic of the Irish gold reserves, nothing could be further from the truth. Furthermore, there do not seem to be any political representatives willing to push the central bank on FOI issues, not any investigative journalists with the will to cover the topic of the Irish gold reserves at the Bank of England. Have these gold reserves ever even been physically audited? Given the lack of oversight with which the Central Bank of Ireland treats this gold holding, it would appear not. The crux of the issue in my view is the gold lending market, which the world’s central banks do not want the public to know any information about, hence the secrecy about gold bar weight lists.
This article and a sequel article together chronicle a long-running investigation that has attempted, with limited success to date, to establish a number of basic details about Ireland’s official monetary gold reserves, basic details such as whether this gold is actually allocated, what type of storage contract the gold is stored under, and supporting documentation in the form of a gold bar weight list. Ireland’s gold reserves are held by the Central Bank of Ireland but are predominantly stored (supposedly) with the Bank of England in London.
At many points along the way, this investigation has been hindered and stymied by lack of cooperation from the Central Bank of Ireland and the Irish Government’s Department of Finance. Freedom of Information requests have been ignored, rejected and refused, and there has also been outright interference from the Bank of England. Many of these obstacles are featured below and in the sequel article.
6 Tonnes of Gold
Ireland ‘only’ owns 6 tonnes of gold in its monetary reserves, which is a fraction of the gold holdings that many of the large European central banks are said to hold. For such a small holding, it may be surprising that basic details of the Irish gold remain a closely guarded secret. However, it’s worth remembering that Ireland is a member of the Eurozone, that the Central Bank of Ireland is a member bank of the European Central Bank (ECB), and that the Irish gold is (supposedly) stored at the Bank of England vaults. Given the clubs that the Central Bank of Ireland is in or is a part of, it is arguably ECB policy and Bank of England policy on gold secrecy which primarily dictates what the Central Bank of Ireland is allowed to say or not to say about the Irish gold reserves.
But don’t forget though that central bankers in general, and Irish central bankers included, are an arrogant and narcissistic bunch who consider themselves immune from having to answer to anyone other than themselves and sometimes their governments. Furthermore, the out of control arrogant culture and ‘cult’ of independence of these organisations also explains their disdain for public discourse, especially on a topic as highly sensitive to them as monetary gold.
For many years Ireland held 14 tonnes in its monetary gold reserves. This remained the case until the end of 1998. In January 1999, as part of Eurozone foreign exchange transfers to the newly established ECB, the Central Bank of Ireland transferred 8 tonnes of gold to the ECB at the birth of the Euro, leaving it as the guardian of just 6 tonnes of gold. This 6 tonne holding has remained static ever since, at least at a reporting level. Most of this 6 tonnes of gold is supposedly stored at the Bank of England in London in the form of gold bars. A small residual of the 6 tonnes is held in the form of gold coins and stored at one of the Central Bank of Ireland sites in Dublin.
Central Bank Act (1942) and FOI Acts
The Central bank of Ireland was established via “The Central Bank Act, 1942” which states that:
“The Bank is a state corporation established under Statute (the 1942 Act) wherein its capital is held by the Minister. The Minister for Finance is the sole shareholder of the Bank.“
In Ireland, the Minister for Finance heads up the Department of Finance and this Minister is also a member of the Cabinet, i.e. the Government or Executive branch. The current Minister for Finance is Michael Noonan who has held this position since March 2011.
Freedom of Information requests in Ireland were introduced in Ireland by the relatively recent Freedom of Information (FOI) Act 1997 which was enacted by a coalition government and which advanced the concepts of transparency and openness in government records and cabinet meetings etc. However, the powers of this 1997 Act were diluted somewhat by a 2003 Amendment to the 1997 Act which aimed to row back on some of the advances of the 1997 Act and which introduced fees for submitting FOI requests.
I first examined the Irish gold reserves in August 2011. At that time the FOI Act covered government departments such as the Department of Finance, but not the Central Bank of Ireland. A subsequent FOI Act of 2014 replaced the 1997 FOI Act and the 2003 FOI Amendment, and also extended the coverage of FOI requests to all public bodies including the Central Bank of Ireland. The 2014 Act (in section 42 and Schedule 1 ) specifies a number of exemptions for certain types of information of certain types of public bodies including a few exemptions for certain types of central bank information. A government website http://foi.gov.ie summaries the basic framework for FOI’s in Ireland. An independent Office of the Information Commissioner (OIC) also exists to review decisions made by public bodies in relation to the FOI.
At the time in 2011, I began noticing the difficulties which gold researchers in other countries were having in obtaining basic information from their central banks about other countries’ gold reserves, and I thought that going through an investigative process with the Irish equivalent might prove easier to navigate given that the Irish gold holdings were far smaller, and given that the Central Bank of Ireland is not exactly as big as the behemoths of the Bundesbank or Banque de France, and so might be more approachable. However, what the process ended up proving was exactly what others had experienced, that the subject of monetary gold reserves is a subject which central banks do their utmost not to discuss any real details of.
This investigative summary into Ireland’s gold reserves is divided into 2 parts. Part 1 here details all of the investigations submitted to the Department of Finance and Central Bank of Ireland prior to my submission of a FOI request to the Central Bank of Ireland in 2015. The Central Bank of Ireland became subject to Freedom of Information requests in 2014 after the FOI Act of 2014 was enacted.
Part 2 looks at the FOI submitted to the Central Bank of Ireland in 2015, how this was rejected, and how it was then appealed and became ‘partially’ successful. I have redacted certain information in emails and FOI letters such as names of FOI officers and various addresses and phone numbers.
2011 – Central Bank First Refusal
The saga began on 26th August 2011 with an email to the Central Bank of Ireland posing a number of seemingly innocuous questions about Ireland’s gold reserves. My questions were as follows:
“Could you clarify a number of points on the gold holdings of the Central Bank of Ireland.
Note 10 on page 98 of the Bank’s 2010 annual report states that ‘Gold and gold receivables represent coin stocks held in the Bank, together with gold bars held at the Bank of England’.
Of the Central Bank of Ireland’s bars held at the Bank of England, could you clarify if any of this holding is swapped or loaned out or has any other receivable status recorded against it, and if so, what percentage? Additionally, is this held in an allocated account and do you have a gold bar list for the custody that you can provide?”
The Central Bank of Ireland responded a week later on 01 September 2011:
We received your query in connection with gold custody, please find our response below.
The notes to our accounts confirm the locations at which the Central Bank of Ireland maintains its Gold Holdings. The Bank is not, however, in a position to provide further information nor to outline its investment strategy in relation to the Gold Holdings.
Trusting this is our assistance to you.”
Knowing at that time that the FOI Act did not cover the Central Bank of Ireland but did cover the Irish Government’s Department of Finance, I emailed the (independent) Office of the Information Commissioner in September 2011 and asked if they thought that a FOI request to the Department of Finance about a topic connected to the central bank would be within the scope of FOI coverage given that the central bank itself was not covered by the Act at that time.
The Office of the Information Commissioner replied to me on 20 September 2011 and advised me as follows:
“you should contact the FOI Central Policy Unit of the Department of Finance for advice in relation to whether or not certain information might be releasable or not under the FOI Acts. Their email address is: email@example.com”
The same day I sent the following email to the Department of Finance FOI CPU:
“I have a hypothetical question regarding a FOI to the Department of Finance, on a matter that might refer to the Central Bank. The scenario would be as follows:
If I made a FOI request to the Department of Finance on a topic that included correspondence between the Department of Finance and the Central Bank, would the information released to me still include items on the Department of Finance side that might reference the Central Bank, or would references or communications with the Central Bank exclude that particular document or communication from the FOI response.”
The Department of Finance FOI CPU responded same day:
Under the Freedom of Information Act, the decision to grant or not grant records lies with the decision maker in the organization that holds the records. The Central Bank does not come under the remit of Freedom of Information. More information can be found at www.foi.gov.ie;”
Slightly cryptic and not very helpful, so I decided to submit a FOI request to the Department of Finance.
Department of Finance – Irresponsible or Incompetent?
On 8 November 2011, I submitted the following FOI request to the Department of Finance:
“Please direct this email to FOI officer XXXX XXXXXXX, or the appropriate FOI officer at the Department of Finance.
I would like to make the following request under the FOI Act.
In accordance with the Freedom of Information Act, I request access from the Department of Finance of all records and correspondence between 1997 and 2011 relating to:
The Irish State’s gold reserves managed by the Central Bank of Ireland, which are custodied at the Bank of England
The investment strategy of the State’s gold reserves
The Irish State’s gold reserves transferred to the ECB between 1999 and 2011″
More than four weeks later I had still not received either an acknowledgement or a response from the Department of Finance about my FOI submission. Under the Irish FOI Acts, a lack of reply within 4 weeks of your initial application is deemed a refusal of your request and allows you to seek to have the refusal decision re-examined.
On 13 December 2011, I sent the following email to the Department of Finance FOI unit:
“Since you have not sent me a decision on my FOI request within the four-week deadline as stipulated by the Office of the Information Commissioner, and I note that I did not receive a reply or even an acknowledgement, this issue has now become a “refusal of my FOI request by non-reply” and I wish to escalate this as an ‘internal review’.
Can you confirm receipt of this internal review request immediately or I will be informing the Office of the Information Commissioner of this matter by end of day tomorrow.”
Two days later the Department responded as follows with what can only be described as an incredible excuse:
“Thank you for your e-mail and apologies for the delay in processing your case. Unfortunately the FOI Officer in the division has been out for sometime. If you could give me a call on 669xxxx we can go through it. Requests are processed on receipt of a €15.00 fee. I am not quite sure what happened in your case but I am happy to discuss it further with you. I am in the Office in the mornings only.
Kind regards, Xxxxxxx Xxx, FOI Unit, Extn xxxx
To which I replied:
“What happened is that no one responded to me within the four-week timeframe and I have informed the Office of the Information Commissioner of this lack of coverage at your department. If an FOI officer is unavailable, there has to be an alternative officer available. That is part of the OIC guidelines. That is why I also stated in my original email that the request was to “FOI officer Xxxx Xxxxxxx, or the appropriate FOI officer”.
As per the FOI Acts, “A person should be available to handle queries from members of the public in each organisation.”
Additionally, since your department hosts the FOI Central Policy Unit [for the entire Irish Government], I find it hard to believe that you don’t have multiple FOI officers.
So I would like a full explanation of why my request was ignored and a fee waiver since I have been waiting for over 5 weeks now.”
On 20 December 2011, just before Christmas, I received a phone call from a FOI officer at the Department of Finance. The FOI Officer told me, and I quote the conversation, since I jotted it down:
“there are no records or correspondence of gold reserves. I talked to various people in the Department and they told me to tell you there are no records. They said responsibility for gold reserves was transferred to the central bank prior to 1999.”
The FOI Officer said she would send a letter confirming this, and said that I could appeal, and that “a principal officer will check the type of searches undertaken”.
The next day, an email from the same FOI Officer arrived which stated:
“Further to our telephone conversation. A request for Internal Review has to be submitted to this Office within 15 days of receipt of our letter. The cost of an Internal Review is €75. The letter will issue to-morrow.”
Your request was received by email in this Department on 9th November. I as the deciding officer have today made a final decision on your request. I may be contacted by telephone. The delay in responding to your request is regretted.
I regret to inform you that a search of the Department has not yielded any of the records sought by you. Consequently I must refuse your request in accordance with section 10(1)(a) of the FOI Act.
…Right of Appeal (as above)”
Given that I had no confidence in a Department of Finance internal review finding anything after being told on the phone that “they told me to tell you there are no records“, I did not see the point of wasting €75 in confirming this with an internal review. As an aside, unless an internal review is pursued, the independent Information Commissioner cannot normally review the FOI. As the Office of the Information Commissioner told me when I reported the Department of Finance shenanigans to them:
“Under the terms of the FOI Acts, requesters must, apart from a number of exceptional circumstances, avail of their right to seek internal review by the public body before the Commissioner can review the matter.
If after three weeks (15 working days) you have received no internal review decision, or if you are not satisfied with the internal review decision that the Department issues, you can then apply to this Office for a review of your case by the InformationCommissioner.”
However, for a number of reasons, it’s quite unbelievable that the Irish Department of Finance would have zero records or correspondence about the Irish gold reserves.
Firstly, it was only a few months earlier on 16 June 2011, in Dáil Éireann (the Irish Parliament), that the very head of the Department of Finance, the Minister for Finance, Michael Noonan, in answer to a parliamentary question, stated that he had been “informed by the Central Bank that the value of gold and gold receivables held by the Bank at the end of 2010 was some €203.792 million (€147.975 million at end-2009)”. To wit:
Deputy Seamus Kirk asked the Minister for Finance if the suggestion that gold profits in the EU central banks should be used to tackle the debt crisis in the peripheral countries in the eurozone such as Greece, Portugal and Ireland; and if he will make a statement on the matter. [15924/11]
Minister for Finance (Deputy Michael Noonan):I am informed by the Central Bank that the value of gold and gold receivables held by the Bank at the end of 2010 was some €203.792 million (€147.975 million at end-2009). Gold is valued at the closing market price and securities at mid-market closing prices at year-end. The increase in the balance sheet entry for the value of the Bank’s gold holdings at end-2010 is due to the change in the market value of gold during the year.
Note that Noonan did not say that he or one of his juniors had looked in the central bank’s annual report. He said that he was informed by the central bank. If Noonan was informed by the central bank, this would have to have been documented in Department of Finance files as part of official departmental and parliamentary business. If these files don’t exist as the FOI response from the Department of Finance claimed, then it would indicate that the Department of Finance engages in sloppy record keeping and operates in an unprofessional and irresponsible manner. If files do exist about Noonan’s interactions with the central bank concerning the gold reserves, it shows that the Department of Finance had records about Irish gold reserves and lied when they said to me that they didn’t.
More fundamentally, the Irish Nation and people of Ireland essentially entrust to the care of the Irish State and it’s Department of Finance, the Nation’s gold reserves. In turn, the Department of Finance employs the Central Bank of Ireland as an agent or custodian, and so the Central Bank of Ireland is answerable to the Minister for Finance on these gold reserves. Also, the Bank of England is (on paper) acting as sub-custodian (or maybe deposit taker) to the Central Bank of Ireland.
The FOI response and phone call from the Department of Finance stating that it had no record whatsoever of the Irish gold reserves, no records of how these reserves are managed, and no records of the gold transferred to the ECB, if true, indicates complete lack of oversight by the Irish Government and Department of Finance into an important component of Ireland’s foreign exchange reserves, and indicates a complete dereliction of due diligence over a substantial monetary asset of the Irish State.
2012 – Central Bank Second Refusal
The Central Bank of Ireland annual report is usually published in late April of the year following financial year-end. After the 2011 Central Bank of Ireland Annual Report was published in late April 2012, I decided in May 2012 to submit some additional questions about the gold reserves to the central bank in the hope that whoever answered might be more cooperative than the previous non-cooperative individual in September 2011 (see above).
On 24 May 2012, after reading the relevant sections of the annual report and establishing how the auditors and bank staff prepared the annual accounts in relation to the balance sheet items, I posed the following seven specific and reasonable questions about the Irish gold reserves to the firstname.lastname@example.org email address of the central bank:
“Hello, I have some questions on an item in the annual accounts 2011 Central Bank of Ireland annual report.
Item 1 in the balance sheet on page 98 as of 31 December 2011 lists “Gold and gold receivables“ of € 234,967,000. Note 10 to the accounts on page 112 states that “Gold and gold receivables represent coin stocks held in the Bank, together with gold bars held at the Bank of England“.
Given that the valuation difference in this line item between 2010 and 2011 represents an increased gold price and no holding increase, the 2011 valuation represents approximately 193,000 fine troy ounces, which is equivalent to 6 fine troy tonnes, or about 485 london good delivery bars.
My questions are as follows –
Is the Central Bank of Ireland bar gold held at the Bank of England on a specific bar basis or a fine ounce basis?
Is the Central Bank of Ireland bar gold held at the Bank of England earmarked in a set-aside account or is it construed as a gold deposit?
Is the Central Bank of Ireland bar gold held at the Bank of England held under a contract of bailment (with the Central Bank of Ireland as bailor and the Bank of England as bailee), or is the relationship a creditor/debtor relationship?
Is the Central Bank of Ireland bar gold held at the Bank of England beneficially and legally owned by the Central Bank of Ireland free and clear of liens, charges, encumbrances, claims or defects?
Is any of the Central Bank of Ireland bar gold held at the Bank of England currently loaned or swapped out to the Bank of England or other parties?
Given that the quantity of the Central Bank of Ireland bar gold held at the Bank of England did not vary between 2010 and 2011, what verifications and checks did the members of the Central Bank Commission use for gold and gold receivables when preparing the 2011 Statement of Accounts?
And finally, given that the quantity of the Central Bank of Ireland bar gold held at the Bank of England did not vary between 2010 and 2011, what sources of material did the Comptroller and Auditor General use for verification of gold and gold receivables in his audit of the 2011 accounts?”
On 12 June 2012, the Central Bank of Ireland responded as follows:
“Thank you for your email request of 24th May 2012 to our Publications email address . As I do not have a postal address for you, I am responding by this email.
I can inform you that the gold bars held by the Central Bank of Ireland are held in safe custody at the Bank of England.
It is not Bank policy to enter into financial/commercial detail (beyond that contained in the Bank’s Annual Report & Accounts) relating to these or other financial assets that are held. You will note that the Bank’s external auditors have certified that its statement of Accounts gives a true and fair view of the Bank’s affairs.
Xxxxxxx Xxxxxxx, Strategy, Planning & Publications, General Secretariat Division”
On the same day, 12 June 2012, I sent a follow-up email to the central bank employee from this Strategy, Planning & Publications group.
“Dear Mr Xxxxxxx,
Thank you for your reply. Could you direct me to the published Bank Policy, statutory, compliance or otherwise, that covers Bank discussion of its financial assets and investments, so that I can relate this policy to my questions?“
On 20 June 2012, I received a reply from this individual:
“Dear Mr Manly, Thank you for your email of 12th June 2012.
The Bank’s management and staff comply with an employment provision that the Bank’s business must not be disclosed, or discussed with, outside parties.
The duties and obligations of management and staff in this regard are governed by Section 33AK of the Central Bank Act, 1942 (as inserted). All staff are given copy of this Section on appointment and are required to familiarise themselves with its provisions and to comply with them at all times.
Xxxxxxx Xxxxxx, Strategy, Planning & Publications, General Secretariat Division”
Section 33AK of the Central Bank Act of 1942 is a long and restrictive section that was only inserted into Act in 2003. It details specific circumstances of the central bank not disclosing confidential information, one part of which relates to:
“any matter arising in connection with the performance of the functions of the Bank or the exercise of its powers”
Importantly, Section 33AK of the Central Bank Act of 1942 has been routinely criticised in Ireland as a ridiculous secrecy cop-out by the Department of Finance and Central Bank to allow them not to answer all manner of questions in relation to the activities of the central bank, for example it has been used by the Minister of Finance to avoid discussing multiple issues related to Ireland’s economic collapse and subsequent bail-outs. The frequent abuses of Section 33AK were succinctly summed up in an Irish bailout blog in 2013 in an article titled “Is 33AK undermining the banking sector in Ireland?“:
“Section 33AK had never been mentioned by Minister Noonan before November 2012, but 33AK is now routinely used by Minister Noonan to tell pesky TDs (Members of Parliament) to “get lost” when they try to ask important questions about the banking sector…”
“No doubt the mandarin discoverer of Section 33AK in the Department of Finance is regularly patted on the back, but for the sake of our Republic, shouldn’t this legislation be repealed?”
“primarily from the obligations of ‘professional secrecy’ that arise as a result of certain EU law obligations contained within what were previously called the Supervisory Directives and are now called the supervisory EU legal acts”.
In my opinion, this invocation of Section 33AK by the above mentioned Central Bank of Ireland employee of the Strategy, Planning & Publications group to decline answering simple questions about Ireland’s gold reserves and the central bank’s published financial statements is pure obstruction, it is an abuse of power, it is an abuse of the legislation, it is an outrage, it has nothing to do with the EU, and it goes far beyond the meaning of the legislation’s original intention.
Freedom of Information Act (2014) – A New Hope
In October 2014, the Irish President signed the Freedom of Information Act (2014) into law. This repealed and replaced the FOI Acts of 1997 and 2003. The FOI Act (2014) extended “FOI bodies” to “all Public Bodies” unless specifically exempted. Exemptions were either full or partial. Importantly, the Central Bank of Ireland was included under the FOI Act (2014) but with partial exemptions. But for new public bodies (with exemptions), the Act only covers access to information and records created from 21 April 2008 onwards.
Part 2 of this article (forthcoming) details a FOI request about the Irish gold reserves that I made to the Central Bank of Ireland in the 2015 on the back the introduction of this updated FOI Act. As you will see, the central bank deciding officer initially refused all parts of my request and even liaised with the Bank of England on a number of occasions where they discussed by FOI request. That refusal contained such gems as:
“the release of detailed information regarding the gold bars held at the Bank of England on behalf of the Central Bank of Ireland could have a serious, adverse effect on the financial interests of the State”
“‘the record concerned [a gold bar weight list] does not exist or cannot be found after all reasonable steps to ascertain its whereabouts have been taken,’
I appealed this FOI refusal. The appeal was partially successful in producing some very limited details of the supposed Irish gold reserve holdings, including at the Bank of England and gold coins within storage in Dublin, Ireland. Full details in Part 2.
News has just emerged in the gold market that the giant Swiss precious metals refiner, Argor-Heraeus, has held discussions to be acquired, and that the likely outcome is an acquisition by a private equity group. This private equity group is believed to be London-based WRM CapInvest, part of Zurich headquartered WRM Capital. Other interested buyers are also believed to have examined a bid for Argor-Heraeus, including Japanese refining group Asahi and Swiss refining group MKS-PAMP, however, neither of these are thought to be in the running at this stage. Since this news is developing, details of the discussions and potential acquisition are still thin on the ground.
If Argor-Heraeus is acquired, it will mean that 3 of the 4 giant Swiss gold refineries will have been taken over within less than a year and a half of each other.
In July 2015, Indian headquartered Rajesh Exports, the world’s largest gold jewellery fabricator, announced the agreed acquisition of the giant Swiss gold refinery Valcambi. See BullionStar article “Swiss Gold Refineries and the sale of Valcambi” for full details. In July 2016, Japanese precious metals refiner Tanaka Kikinzoku Kogyo K.K , part of the Tanaka Precious Metals group, announced the agreed acquisition of Metalor Technologies, another of the large Swiss gold refineries. Retrospectively, the acquisition of Valcambi by Rajesh Exports now looks to have initiated a flurry of take-over activity in the normally low-key Swiss precious metals refining world.
While Metalor is based in Marin-Epagnier in the Canton of Neuchâtel in northwest Switzerland, the other 3 giant Swiss gold refineries, Argor-Heraeus, Valcambi and MKS-owned PAMP are all located literally within a few kilometres of each other in the Italian speaking Canton of Ticino, in southern Switzerland, near the Swiss-Italian border. Argor-Heraeus is in Mendrisio, Valcambi is in Balerna, and PAMP is in Castel San Pietro. Mendrisio is 4 kms from Balerna and 2kms from Castel San Pietro.
The Golden Triangle of Swiss gold refineries, Canton of Ticino
Commerzbank owns 32.7% of Argor-Heraeus’ share capital. The Austrian Mint holds another 30% of Argor-Heraeus shares. In its annual report, Heraeus doesn’t reveal its holding in Argor-Heraeus, but with the Austrian Mint and Commerzbank owning a combined 62.7%, this means 40.2% of the shares are held by Heraeus and Argor-Heraeus management. On the Argor-Heraeus website, Heraeus is listed first on the shareholder list, which could signify that it’s the largest shareholder. This would put Heraeus’ shareholding above Commerzbank’s 32.7% stake, and mean that Argor-Heraeus management probably hold a shareholding somewhere below 7%.
A Precedent for Private Equity Ownership
Interestingly, there is a precedent of private equity ownership in the Swiss precious metals refining sector. Until Tanaka’s take-over of Metalor technologies last July, Metalor was majority owned by French private equity company Astorg Partners and Belgian private equity company Sofina, which between them held approximately 60% of Metalor’s shares. The remainer of Metalor’s shares were held by Metalor management, as well as by Martin Bisang and Daniel Schlatter. Bisang and Schlatter are connected with Swiss boutique investment bank Bellevue Group, which has in the past also acted as a strategic adviser to Metalor. Bisang had bought into Metalor in 1998 along with Swiss executives Ernst Thomke, Rolf Soiron and Giorgio Behr, and an additional group of Swiss executives bought into Metalor in 2004. These additional buyers were a secretive bunch, only known as the ‘Partners Only’, a group which was said by Swiss media at the time to have been connected to the Swiss Roche group.
Likewise, when Valcambi was sold to Rajesh Exports in July 2015, the then owners of Valcambi were a combination of US gold mining company Newmont (with an approximate 60% shareholding) and a group of shy Swiss private investors (who held the remaining shares) the largest of which were Emilio Camponovo and the Camponovo family. Technically, you could call these Swiss private investors direct private equity investors, or equivalent.
Even the PAMP refinery, which is owned by the Geneva based MKS-PAMP group, could be described as private equity, or at least concentrated privately-owned equity, since the group is controlled by the founding Shakarchi family. Note that MKS-PAMP has a parent company MKS PAMP Group BV based in Amsterdam, but this appears to be purely for corporate structure reasons.
The Sellers – Heraeus, Commerzbank and Austrian Mint
Since Argor-Heraeus has multiple owners, any sale would in theory be more complex than if the refinery only had a single owner. Looking quickly at the current owners, Commerzbank in its bullion banking marketing literature usually draws attention to the fact that its partial owner of a gold refinery, and uses this as a selling point by trumpeting the fact that it has direct connections to the physical gold world. Selling Argor would probably be a negative for Commerzbank, however, it may need the cash given that german banking is in a crisis at the moment. The Austrian Mint is owned by the Austrian central bank (OeNB), which in turn is owned by the Austrian State. Any sale of the Austrian Mint’s shares in Argor would be a one-off profit boost to the OeNB. In 2015, the Austrian Mint sold a stake it held in Casinos Austria (yes, a casino company), so maybe the Mint has a new-found strategy to jettison its non-core investments. Although presumably the Mint gets preferential precious metal supply from Argor, or one would think that it does.
Heraeus also has close relationships with Argor-Heraeus, for example, in the production of various precious metals products, so a sale by Heraeus of its stake in Argor could in theory affect these synergistic relationships. All of these shareholders also receive a substantial annual cash dividend from Argor-Heraeus which is a nice to have to say the least. Selling their stakes would obviously be a loss of their cash dividends. I personally was surprised that Argor-Heraeus would be up for sale, since it definitely has what looks like a very stable, secure and content set of shareholders. As per BullionDesk coverage of this potential deal, Commerzbank and Heraeus have yet to respond or comment on the potential sale of Argor-Heraeus.
Interested Parties in an Argor Bid
Presuming that the private equity company WRM CapInvest, as well as Asahi Refining, and MKS-PAMP all looked at potentially acquiring Argor-Heraeus (and that’s the word in the gold market right now), let’s have a quick look at these players.
The current Asahi Refining group, headed by Asahi Holdings, owns precious metals refinery operations in 5 locations worldwide, namely Tokyo, Salt lake City, Utah (US), Brampton, Ontario (Canada), Mexico City, and Santiago (Chile). Some readers will be familiar with Asahi’s takeover of the US and Canadian gold and silver refining operations of Johnson Matthey, which was completed in March 2015. If Asahi had emerged as the favourite suitor to acquire Argor-Heraeus, it would mean that 2 Japanese headquartered precious metals refiners, Tanaka and Asahi, would both own a Swiss precious metals refinery, namely Metalor and Argor-Heraeus. Market sources indicate that Asahi’s bid value for Argor-Heraeus wasn’t as high as the bid tabled by the favoured private equity group bidder. Argor-Heraeus also operates a precious metals processing plant in Santiago in Chile, which could feasibly provide synergies to Asahi, since Asahi runs a refining operation in Santiago.
Its interesting that MKS-PAMP has been mentioned as a possible acquirer of Argor-Heraeus. As mentioned, the PAMP precious metals refinery is literally ‘down the road’ from the Argor-Heraeus refinery, i.e. 2 kms down the road. PAMP is a prestigious global brand in precious metals refining and bar production, and so is Argor-Heraeus. But would the resulting consolidation in the Swiss precious metals refining industry make sense, and how would this affect the PAMP and Argor-Heraeus brands. That’s a difficult question to answer, and only PAMP could accurately answer that at this time. Market sources say that MKS PAMP was shy in revealing its full financials, data that would presumably be necessary if it put in a bid for Argor-Heraeus.
Argor-Heraeus opened a new refining headquarters in Mendrisio in 2013 which doubled its former refining capacity. According to its 2014 corporate responsibility report, the new Argor-Heraeus refinery has an annual refining capacity for gold of between 350 and 400 tonnes. The PAMP refinery has an annual refining capacity of 450 tonnes of gold, and an annual silver refining capacity of over 600 tonnes. A merged PAMP and Argor-Heraeus would have an annual refining capacity for gold of about 900 tonnes. Their neighbour Valcambi has an annual refining capacity for gold of 1600 tonnes. A combined PAMP and Argor-Heraeus would therefore start to approach the production capacity of Valcambi. Each of Valcambi and a combined PAMP ~ Argor would also have a refining presence in India also, since PAMP has an Indian refining joint-venture with MMTC, and Valcambi, owned by Rajesh Exports, has refining operations in India. Argor-Heraeus is also one of only five refinery members of the London Bullion Market Associations (LBMA) good delivery referee panel. PAMP is also on this panel, as is Metalor and Tanaka. This panel assists the LBMA is maintaining quality standards of refinery members worldwide. Argor-Heraeus is also a full member of the LBMA, one of the few refineries to be a full LBMA member.
Finally, turning to the private equity company WRM CapInvest, which is said by sources in the gold market to be the preferred bidder for Argor-Heraeus, what is known about this company? According to its website, WRM CapInvest is a division of the WRM Capital group of companies. The WRM Group was founded by Raffaele Mincione, who is Italian, but who resides in Switzerland. WRM Group seems to have started as a private wealth management / family office type company but has expanded into private equity.
WRM CapInvest is based in Berkeley Square in Mayfair in London, Mayfair being a very popular location for hedge funds and private equity funds to locate in. WRM CapInvest was incorporated in the UK in March 2012 as Capital Investment Advisors Ltd, but changed name to WRM CapInvest on 11 May 2016. The original single director of WRM CapInvest was Massimo Cattizone, also an Italian. Massimo Cattizone and Raffaele Minicone were listed as shareholders, with Minicone holdings 80% of the WRM CapInvest shares and Cattizone holding 20% of the shares. In July 2013, Leonidas Klemos (Italian), and Michele Cerqua (Italian) were appointed as directors of WRM CapInvest, and Massimo Cattizone ceased to be a director. Between May 2014 and March 2015, Roberto Agostini (Italian) was also a director. In July 2015, Raffaele Minicone was appointed as a director. In February 2016, Leonidas Klemos ceased to be a director. By April 2016, Raffaele Minicone was listed as owning the entire share capital of WRM CapInvest. The current directors are therefore Raffaele Minicone and Michele Cerqua. The reason for listing the above is to highlight that all the directors of WRM CapInvest since it was incorporated have been Italian, and there is a Swiss connection since Raffaele Minicone is based in Switzerland, and the WRM Group is headquartered in Zurich, Switzerland.
Therefore, the fact that Argor-Heraeus is based in the Italian speaking Swiss Canton of Ticino, right beside the Italian border, and that CapInvest is operated by an Italian team, owned by an Italian, and part of a Swiss based group is probably of relevance to a potential acquisition of Argor by CapInvest. Additionally, Knight Frank, a large commercial real estate agent, mentioned on its website in a 2013 article that “CapInvest, which is also backed by private Italian investors, purchased 60 Sloane Avenue for US$206m.”
So the question is, assuming CapInvest acquires Argor-Heraeus, is it acquiring the company on behalf of CapInvest, or on behalf of some other Italian or Swiss investors, or Italian Swiss, or Swiss Italians? And if an acquisition is on behalf of other investors, who are these investors? Could the private investors who were involved in Metalor (such as Martin Bisang and his circle of business acquaintances), or the private investors that were involved in Valcambi (such as Emilio Camponovo and friends) be re-entering the Swiss refining industry with an acquisition of Argor-Heraeus. They would definitely be some of the best placed people around that understand how the precious metals refining industry works, given their experience. Or possibly the Argor-Heraeus management and other local business people in Ticino are moving to take ownership of Argor through a private equity route?
Another potential connection is UBS. Swiss investment bank UBS previously owned the Argor-Heraeus refinery, and only exited its shareholding in 1999, so it’s also possible that a UBS connection could pop up in a Argor-Heraeus acquisition deal. This has a precedent since when Valcambi was acquired by Rajesh Exports in 2015, Credit Suisse, which itself used to own Valcambi (and which Valcambi executives had close ties to), provided strategic corporate finance advice on the Valcambi acquisition and also actually partially funded the Rajesh acquisition.
Whatever the outcome of these developments with Argor-Heraeus, further details should emerge sooner rather than later. So, as they say, watch this space.
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