A counterparty evaluating a physical gold purchase rarely starts by asking what bullion to buy. They start by asking what the transaction will produce on paper — what proves the counterparty is who they say they are, what establishes title to the metal, what carries through audit, what survives a change of fund administrator three years later. The shape of that paper trail is not negotiable per deal: it is set by the operator’s compliance framework, the refinery supply chain, and the custody and delivery infrastructure behind the trade. A physical gold transaction at the wholesale level produces a phased evidence set — onboarding file, contract and invoice, MT103 settlement confirmation, allocation record, and, where physical movement is elected, a delivery dossier — issued in a fixed sequence, each document doing one specific job that the next one depends on.
1. Why documentation precedes price
Spot price moves continuously and is published by reference sources visible to anyone — LBMA fix, COMEX prints, OTC bid-ask streams from major banks. A counterparty can pull a number off a screen at any moment and use it for internal modelling, board papers, or treasury allocation memos. These uses stay inside the buyer’s organisation, and the spot number remains reference data until the operator engages it inside a quote.
A binding quote — quantity in kilograms or fine ounces, format (kilobar, 400oz Good Delivery, LBMA-eligible cast), price formula referenced to a named fix or the spot at confirmation, validity window — is issued only after counterparty onboarding has cleared. Sequencing is structural here: until the operator has identified the counterparty, evidenced their authority to transact, and screened them against sanctions and supplier-restriction lists, no document with commercial weight is produced. Practical consequence for a buyer working against a board mandate or a treasury window plays out on the calendar — onboarding has to be completed before the price the buyer wants is the price the buyer can transact at, and that gap is measured in days of compliance review. Treating spot as a reference and the quote as the first commercial document — issued post-onboarding — keeps the two phases properly separated in the buyer’s own planning.
2. Counterparty onboarding
Before the operator issues anything with commercial weight, the counterparty assembles and submits a file that establishes three things: legal identity of the entity, the authority to bind it to a transaction, and the source of the funds that will settle the transaction. Onboarding is that file.
What goes in:
- Corporate identity documents — certificate of incorporation, memorandum and articles of association, current register of shareholders, register of directors, and a recent good-standing certificate or commercial-registry extract from the entity’s home jurisdiction. Equivalent constitutive instruments and a current schedule of trustees, council members, or governing officers cover trusts, foundations, and similar structures.
- Beneficial-ownership disclosure identifies natural persons holding control above the operator’s threshold (commonly aligned with FATF guidance), with passport and proof-of-address evidence for each. Each UBO declared here drives the screening filter applied at the next stage.
- Authorising resolution — board resolution, partnership minute, or trustee resolution naming the authorised signatories for this transaction or class of transactions, the maximum amount, and any internal limits. Without it, the operator has no recorded basis to treat any signature as binding the entity.
- Authorised-signatory identification. Passport copies, proof of address, and specimen signatures for each signatory named in the authorising resolution. The operator matches each specimen against later instructions — delivery instructions, settlement variations, allocation transfers — once the relationship is live.
- Source-of-funds substantiation — bank reference, audited financial statements, or transaction-specific evidence showing the funds for settlement originate from a legitimate, documented source consistent with the counterparty’s declared business.
- Completed KYC questionnaire. Activity description, transaction rationale, expected volume, jurisdictions of operation, and politically-exposed-person status of UBOs and signatories — captured on an operator-issued form. Updates to any field flow back into refresh logic.
Where the file is incomplete, the operator requests the missing document. Commercial movement waits until it arrives. Counterparties that prepare the full file in one submission — typically by working from the operator’s checklist before first contact rather than after — clear onboarding in days; counterparties submitting incrementally clear in weeks. Completeness of the first submission drives the calendar.
Live status matters as much as completeness. UBO change, signatory change, jurisdiction change, or ownership reorganisation each trigger refresh requirements; a transaction submitted against a stale onboarding record stalls until the file is current, regardless of how complete the original submission was.
3. Internal compliance screening
Screening runs in parallel with onboarding intake and stays entirely on the operator side. The counterparty submits documents; the operator runs them through three filters, none of which produces an outbound document.
Three filters apply in sequence. International sanctions screening runs against OFAC, EU, UK, UN, and other applicable lists, executed through LSEG World-Check One on the counterparty entity, its UBOs, its authorised signatories, and — where corporate structure includes them — its parent and material subsidiaries. Heraeus supplier-restriction check adds refinery-level constraints on top of public sanctions lists: jurisdictions and counterparty profiles that the Heraeus supply agreement excludes even where public lists do not. LBMA Good Delivery supply-chain alignment carries through to the metal itself — refinery-origin, chain-of-custody, and conflict-free sourcing standards that constrain which counterparties can be onboarded against the available bullion inventory.
Counterparties receive no clearance certificate, redacted screening report, or any other artefact from this stage. Clearance shows up as progression — the operator issues a transactable quote or proceeds to offer, and that movement signals to the counterparty that the screens cleared. A failed screen produces a refusal to proceed, communicated as such, with no disclosure of which filter triggered or what the underlying record contained.
This shape follows from the screens’ function. Handing a clearance document to the counterparty would amount to a representation about third-party data the operator cannot warrant, and would create disclosure obligations under the screening providers’ terms. On the counterparty side, compliance reviewers and auditors accepting onboarding-cleared transactions rely on the operator’s own AML/KYC framework as the warranted layer, and the onboarding-cleared status is itself the evidence inside that framework.
4. Commercial documents
After onboarding clears, three documents are issued together to the counterparty: the transactable quote (or its progression to offer), the invoice, and the purchase agreement. They come as a coherent set, because the operator has by that point committed internally to the transaction and the counterparty needs the full instrument to take it through their own approvals.
4.1 The transactable quote
A transactable quote responds to a specific request: this metal, this quantity, this format, executable on stated terms. It carries the price formula — fixed at the next LBMA AM or PM fix, fixed at spot at the moment of contract execution, or fixed inside a defined window with a named reference — and a validity window, after which the formula expires and any subsequent transaction is repriced from scratch. Inside the validity window, the buyer can take the quote through internal approvals, signature, and payment authorisation against a known commercial figure; outside it, the figure is gone and re-issuance restarts the process. Counterparties working against fast-moving spot environments or board-meeting calendars treat the validity window as the planning constraint.
4.2 Offer and invoice
An offer formalises the operator’s commitment to transact on the quoted terms. It restates the metal, quantity, format, price formula, settlement bank details, and delivery or storage option chosen by the counterparty, and references the contract that accompanies it. Its function inside the evidence set is to make the transaction reviewable as a single instrument before signature: counterparty legal can read the offer alongside the contract and confirm consistency before authorised signatories commit.
Accounts payable on the buyer side moves against the invoice. The invoice carries the operator’s banking coordinates for the MT103, the exact reference field the buyer’s bank must populate, the amount in settlement currency, and the value date by which cleared funds must arrive against the contract. Banks reconciling inbound wires match on the reference field; an MT103 issued without the invoice reference, or with a mistyped one, lands as an unmatched receipt and reconciliation falls back to manual work between the two operations teams before the next phase begins. Reference-field accuracy is therefore load-bearing for settlement timing — the invoice serves as the interface between contract and payment infrastructure precisely through that field.
4.3 The purchase agreement
The purchase agreement binds the operator and the counterparty to the transaction, defining the obligations of each side, allocating risk, and governing disputes. Inside the evidence set, it sits between the onboarding file (which establishes the counterparty) and the settlement record (which evidences performance). At the lifecycle level, the sequence locks in: the contract is signed after onboarding clears and the offer is accepted, and before the MT103 is originated. Counterparties that try to compress this — paying first, signing later, or signing on an unreviewed template handed back at speed — create reconciliation and audit gaps that cost more to clean up afterwards than the time the compression was meant to save.
5. Settlement: MT103 and bank confirmation
When the buyer’s bank originates an MT103 against the operator’s banking coordinates from the invoice — populating the reference field with the contract or invoice reference — settlement begins. The operator’s bank receives, posts, and confirms cleared funds against the named contract on the other side. Buyer-side evidence of payment lives in the MT103 itself: message identifier, value date, amount, beneficiary details, and reference, carried into the buyer’s accounting record and audit trail. Operator-side evidence comes from the bank confirmation that cleared funds posted.
Allocation begins only after the operator’s bank confirms cleared funds. Between origination and clearance the wire is in flight — typically same-day for major-currency wires inside compatible banking-day cycles, longer where intermediary banks, currency conversion, or non-overlapping cycles are in play — and until clearance posts, title remains attached to the buyer’s payment moving across rails. Originating a wire late in the buyer’s banking day on a Friday against an operator bank in a different time zone can land cleared on Monday or Tuesday in operator time; allocation follows that clearance regardless of how complete the rest of the file is. Buyers planning around board-resolution validity, fixed-price windows, or quarter-end reporting dates work the wire-origination calendar back from the operator’s expected clearance time.
Reconciliation hinges on the reference field. An MT103 carrying the correct contract reference matches automatically inside the operator’s settlement reconciliation; an MT103 carrying a typo, a missing digit, or no reference at all lands as an unmatched receipt and triggers manual reconciliation between the two operations teams before the file moves to allocation. Buyer responsibility ends at correctly populated origination; operator responsibility begins at posted-and-matched.
6. Allocation record
After cleared funds are posted, the operator issues an allocation record naming specific bullion against the contract. The record transfers title at bar level. Allocation is issued only against completed identification — every bar named, custody acknowledged, signatory recorded — and a half-state produces no document.
Standard contents:
- Counterparty name and contract reference — anchoring the record inside the evidence set against the named transaction.
- Bar list — for each bar: serial number, refiner mark (Heraeus or Argor-Heraeus SA), gross weight, fine weight, assay, year of production where stamped, and LBMA Good Delivery status where applicable. Each entry is verifiable against the bar physically held.
- Vault placement reference points to the storage location (Brink’s-coordinated facility, named city or vault code) and the custody reference under which the bars sit.
- Custodian acknowledgement. The custody side confirms that the listed bars are held under the named counterparty’s account, segregated from operator and other client metal.
- Issue date and signatory — when the allocation was performed and which authorised signatory of the operator issued the record.
Allocation makes the difference visible at bar level. Allocated holdings tie to specific serial numbers and custody references; unallocated holdings rest as a contractual claim against the operator’s metal account, without bar-level identification. Counterparty auditors, fund administrators, and compliance reviewers reading the file work from the bar-level detail in the allocation record — serial numbers tied to refiner marks tied to a custody reference — to evidence the allocated characterisation. Where serial numbers are missing, or serial numbers exist without custodian acknowledgement, the file does not support that characterisation, regardless of contract wording.
Downstream actions reference this record by issue date and bar identifier. Delivery instructions, vault movements, and buyback sell-instructions all act on specific bars listed here. Across the relationship, allocation records accumulate as new transactions add new records — the durable title index against which any later operation is identified.
7. Delivery dossier (when physical movement is elected)
Bullion can sit in Brink’s-coordinated storage indefinitely, with the allocation record as the live title document and no dossier required. Where physical movement is elected — at contract stage or by later instruction against an existing allocation — a separate document set governs the movement from vault to consignee, accumulating across each phase. The delivery service covers Brink’s-coordinated routing, available destinations, and jurisdiction-specific handling.
Across each phase of the movement:
- Delivery instruction. Issued by the counterparty, signed by an authorised signatory named in the onboarding file, identifying the allocation record by issue date, the specific bars to be released (or the full holding), the consignee, and the destination address. The operator verifies the signature against the specimen on file before acting on the instruction.
- Release authorisation flows from the operator to Brink’s, naming the allocation record and the bar list to be released. Brink’s holds the bars under the operator-coordinated account; the release authorisation moves them out of that account against the named instruction.
- Carrier waybill is produced when the bars are loaded for movement: a Brink’s transport document for armoured-transport legs, an AWB for air freight, or a CMR (or local equivalent) for cross-border road movement. The waybill identifies the consignment by sealed-container reference; bar-level identity stays with the allocation record and is reconciled at consignee end.
- Export customs documentation is filed per the Incoterms agreed in the contract. Bullion crossing borders is declared under the applicable HS code and routed through the export jurisdiction’s customs procedure, with declaration and any jurisdiction-specific licences or notifications required for precious-metals movement.
- Transit insurance certificate covers the shipment from release to delivery against named risks. Consignment, carrier, route, and sum insured all appear on the face of the certificate; an insurance claim, if filed later, runs against this document.
- Import customs documentation is handled by the receiving leg or by the operator, depending on Incoterms. The shipment clears import customs in the consignee’s jurisdiction; documentation includes the import declaration, any applicable VAT or GST treatment for investment-grade bullion, and clearance evidence.
- Proof of delivery is signed by the consignee at destination against the bar list from the allocation record. The POD reconciles the sealed-container reference on the waybill to bar-level identity on the allocation record and closes the chain from operator-side release to counterparty-side custody.
Three downstream functions consume the dossier: customs handling, insurance review, and accounting closure. Each works against different documents inside it. Where export or import paperwork is incomplete, customs authorities hold the shipment, and storage and demurrage costs accrue against the consignment until the gap is resolved. Where the POD is missing, accounting cannot book the asset-location change from “held in custody” to “held at named address,” and the line stays parked. Where a transit incident occurs — loss, damage, theft — investigation and claim run against the insurance certificate, using the release authorisation, waybill, and POD (or its absence) as the chain of evidence; an incomplete dossier weakens the claim regardless of merits.
8. Buyback documentation
Selling bullion back runs through a mirror of the acquisition flow. The counterparty — original buyer or a different party who acquired the bullion through an earlier onboarded purchase and now seeks liquidity — re-enters the lifecycle at onboarding. Where the file is current from a prior transaction, the relationship resumes from the live record; where the counterparty is new, or onboarding has gone stale, the file is built from scratch. Screens run, internal records are produced, progression-as-clearance applies — same shape as on the acquisition side.
Buyback adds a second submission alongside the onboarding file: chain-of-acquisition evidence. The operator is buying metal, and provenance has to land before any offer issues. What that evidence looks like depends on where the bullion has been since the original allocation.
When bullion never leaves Brink’s-coordinated storage, the chain is a single trail. The counterparty contributes the original allocation record and authority to act on it; storage records under the same coordinated account demonstrate custody continuity, accessible to the operator directly; a sell instruction acts on the live allocation. Screening clearance leads straight to offer, and timing runs in days.
When bullion has left coordinated storage at any point — delivered out, held by the counterparty at a self-managed location, moved between custodians, or held under a different storage arrangement — the chain has to be re-established document by document. The counterparty submits the original allocation record, the delivery dossier evidencing the movement out, storage or custody records covering the period the bullion was held outside coordinated custody, and any movement records for transitions during that period. Where the bullion has been physically inaccessible to the operator’s chain of evidence for an extended period, an assay and bar-identification check is performed at re-receipt before the offer finalises: the bar list from the original allocation record is reconciled against the bars actually presented for buyback. Timing here runs in weeks, driven by re-evidence work. Pricing and contract execution remain quick once provenance is settled.
Once the offer is accepted and the buyback contract is signed, settlement runs in reverse. An MT103 originates from the operator against the counterparty’s named bank for the buyback amount; clearance posts; allocation closes. For in-custody bullion, the original allocation record is closed and bars return to operator inventory. For re-receipted bullion, bars enter operator inventory once the assay and identification check clears. Both sides close from a single set: settlement confirmation on the counterparty side, closed allocation record on the operator side. Offer mechanics and pricing reference live at the buyback service page.
9. The evidence set as a whole
Across the transaction, the documents that get produced fall into three evidence functions, though the boundaries between them are not always clean. Counterparty identity is carried by the onboarding file and the internal screening records: who the counterparty is, who can bind them, and that they cleared sanctions and supplier-restriction filters at the point of transaction. Title is carried by the contract, invoice, MT103 confirmation, and allocation record together — these four show that terms were agreed, payment cleared against the agreed instrument, funds posted on the operator side, and specific bullion was assigned to the counterparty’s account. Chain of custody is carried by the allocation record again, this time at bar level, plus the delivery dossier where physical movement was elected and the provenance documents that surface at buyback. The allocation record sits across two functions because that is what bar-level identification of segregated metal does — it serves title and custody at the same time.
Different reviewers on the counterparty side read different parts of the file. A compliance reviewer evaluates identity from the onboarding records. A controller booking the asset evaluates title from the settlement and allocation records. An auditor evidencing the asset at year-end evaluates custody from the bar-level documents. When a document is missing, the gap is visible to whichever of these reviewers depends on the evidence that document carries. Stale UBO disclosure leaves a compliance reviewer unable to sign off on identity. An MT103 reference that does not match the contract leaves a controller with an unreconciled wire. An allocation record stripped of serial numbers leaves an auditor with no way to tie a physical bar to a documented holding. And a delivery dossier missing the proof of delivery — even with the rest of the dossier intact — leaves the asset booked at “in custody” when it has actually moved to a named address, a discrepancy that surfaces at the next reconciliation cycle. Each gap is identifiable, and the document that closes it is identifiable.
Durability comes from repetition. A counterparty transacting a second time against a current onboarding file produces a new contract, invoice, MT103 confirmation, and allocation record; the identity layer is already in place and refreshes only when something material changes about the entity, while title and custody layers accumulate per transaction. By the third or fifth transaction, the shape of the file is the same as on the first, and the work behind each new transaction is incremental.
For a counterparty preparing to enter this lifecycle for the first time, the acquisition entry point describes onboarding requirements, available formats, and the route to a transactable quote.