Licensing in progress
The transitory provisions of the Commodities Act give commodity companies until 21.12.2014 to obtain their licenses. Companies active in soft commodities have until 31.12.2015. The companies in table 1 have already taken steps in this direction.
Licence is strongly recommended
ROHMA has conducted an impact assessment on the basis of which it was able to identify approximately two hundred companies who would need licenses for their activities. The list of these companies follows below in table 2. These companies are actively encouraged to start carrying out the steps required in order to obtain a license.
Refineries and importers of gold
According to the Commodities Act, refineries and importers of gold are equally subject to ROHMA supervision and must obtain licenses to carry out their activities. ROHMA particularly supervises the way in which companies active on the physical gold market carry out their supply chain due diligence obligations (for example, to exclude minerals sold to finance conflict, prevent laundering of dirty gold).The general due diligence requirements that apply to commodity companies apply equally to gold refineries and gold import companies. According to research carried out to date, ROHMA estimates that the companies in table 3 could fall under the Commodities Act. These companies are actively encouraged to start carrying out the necessary steps in order to obtain a license.