By Robert Lambourne
Monday, December 8, 2025
Developments this year have strengthened suspicions that the Bank of England is complicit in gold price suppression, especially developments with the custody of the United Kingdom's reserves of foreign exchange and gold held in the government's Exchange Equalisation Account.
The audited annual report of the EEA for the year to March 31, 2025, still has not been published. It is usually published in July. This delay was disclosed by GATA in a dispatch on October 7:
https://www.gata.org/node/24155 [1]
Normally the UK Treasury publishes an audited annual report of the EEA in July. So the report is now eight months late. A company listed on a major stock exchange almost certainly would experience severe share price and regulatory pressure to explain such a delay.
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In late August this writer contacted the Treasury via his member of Parliament to request an explanation for the delay and a likely publication date. Getting a response took more than five weeks and it offered no nothing other than to suggest that certain audit procedures needed to be completed. Neither was any likely date provided for publication of the annual report.
It's not clear why a five-week delay was needed to say so little.
Hence there appears to be a problem with obtaining approval of the accounts from an independent auditor.
Indeed, there are many potential problems that might affect the judgment of an independent auditor of the EEA.
The delay might be connected to the rush to get gold to the United States shortly after the Trump administration took office, amid fears that tariffs could be imposed on U.S. gold imports.
Early this year it was widely reported that the Bank of England was unable to get gold out of its vaults promptly. In a meeting with journalists February 6 the following statement about gold delivery delays this following statement was made by the bank's deputy governor, Dave Ramsden:
"Gold is a physical asset, so there are real logistical constraints and security constraints. Getting into the bank for me this morning was a bit trickier because there was a lorry in the bullion yard. ... It takes time and the stuff is also quite heavy. ... We've got slots for all the people who currently want to get their gold" but "if you were coming in new to us, you might have to wait a bit longer because all the existing slots are booked up":
https://finance.yahoo.com/news/bank-england-suffers-exodus-gold-060200514.html [3]
During the second, third, and fourth quarters this year there was a substantial increase in the use of the "exchange for risk" mechanism on the New York Commodities Exchange. This is a transaction where a futures contract is exchanged for an over-the-counter derivative, such as a swap. GATA's consultant about the Comex, Harvey Organ, has speculated that one of the major users of the mechanism is the Bank of England, pursuing an unconventional way to acquire physical gold.
Now is it really just a coincidence that the annual report of the UK's EEA is still not published when the Bank of England was not only unable to remove gold from its vaults promptly but, in need of real metal, could be responsible for the increased volume of "exchange for risk" transactions on the Comex in recent months?
In the absence of more information from the UK Treasury, this question remains open, and the problem causing the delay in publishing the annual report of the EEA, whatever it is, seems to be getting more serious.
The difficulties recently experienced by the Bank of England prompted this writer to review previous disclosures concerning the role of the bank as a gold custodian and its involvement with other gold-related matters.
A report by Bullion Star's Ronan Manly in December 2022 was headlined: "Has GLD Been Failing to Disclose Gold Held at BoE in 2022?":
Manly's report included a reference to the bank's serving as a sub-custodian of GLD, SPDR Gold Shares, the biggest gold exchange-traded fund.
Manly also noted that JP Morgan was becoming a custodian for GLD along with HSBC. He wrote that the Bank of England held 70 tonnes of GLD gold in 2020 and that subsequent disclosures by GLD did not include any details on how much of its gold (which now is said to total 1,010 tonnes) is warehoused by the Bank of England. Apparently, under U.S. Securities and Exchange Commission regulations this detail should have been disclosed.
Those who follow GATA dispatches know that each month we publish an estimate of gold swaps arranged by the BIS, which in the absence of contrary evidence are assumed to be swaps of gold deposited in exchange-traded funds and held in gold sight accounts at the Federal Reserve. It now seems possible that the Bank of England is both a recipient of some swapped gold and the source of gold physically too as a sub-custodian of HSBC or JP Morgan, acting as the custodians for GLD.
The Bank of England has been a sub-custodian of GLD’s gold since at least 2014 and the bank may have been a recipient of the gold as far back as 2009, when the current use of gold swaps began.
A GATA dispatch report cited press coverage of the first use of gold swaps by the Bank for International Settlements, which seems to be the only time the BIS has discussed the swaps with a news organization:
https://www.gata.org/node/18826 [5]
The press coverage, from the Financial Times, "BIS Gold Swaps Mystery Is Unravelled," is here:
https://www.ft.com/content/3e659ed0-9b39-11df-baaf-00144feab49a [6]
So it is possible that the Bank of England's seemingly trying to acquire physical gold via the "exchange for risk" mechanism at the Comex is even more complicated than just squaring the books for the Exchange Equalisation Account. Maybe the bank has leased out gold supposedly "owned" by both GLD and the UK government.
It seems doubtful that the Bank of England would be doing things like this without the explicit endorsement of the U.S. Federal Reserve.
After recent review of Manly’s report, this writer began investigating whether the Bank of England is a sub-custodian of any other exchange-traded fund or other funds involved with precious metals.
The bank appears as a sub-custodian for at least four other exchange-traded bullion products (and one closed-end trust) besides GLD. No other major central bank has been identified as a sub-custodian. The other funds listing the Bank of England as a sub-custodian are:
1) iShares Gold Trust (IAU). JP Morgan lists the Bank of England with the identical clause used for GLD.
2) iShares Silver Trust (SLV). This fund uses the same custody agreement template. The Bank of England appears alongside Scotia Bank, Deutschebank, ICBC-Standard Chartered, JP Morgan, and UBS.
3) Granite Shares Gold Trust (BAR). Its gold custodian is ICBC Standard Chartered. The Bank of England is listed as a permitted sub-custodian.
4) Perth Mint Physical Gold ETF (AAAU). The gold custodian here is JP Morgan. The Bank of England is named in Paragraph 8.1.
5) Sprott Physical Gold Trust (closed-end, TSX: PHYS). The Bank of England is cited as a sub-custodian "from time to time" with no tonnage disclosed.
All five funds use virtually the same paragraph about custodianship, copied from the London Bullion Market Association model custody agreement.
From the iShares Silver Trust custodian information it appears that the Bank of England also may be storing physical silver, although the LBMA says the bank does not store physical silver. So maybe the bank's sub-custodian role for the fund is just a contingency matter.
Has any other central bank ever been publicly named as a sub-custodian for gold and silver exchange-traded funds?
An extensive search of U.S. Securities and Exchange Commission EDGAR (8-K, S-1, 10-K) filings for every U.S.-listed bullion ETF (IAU, SLV, BAR, SGOL, AAAU, OUNZ, GLDM, PHYS, PSLV, SGLN, etc.) finds no reference to the Federal Reserve Bank of New York, Banque de France, Bundesbank, Swiss National Bank, Banca d'Italia, European Central Bank, People's Bank of China, Bank of Canada, Riksbank, the Austrian Mint, and other institutions.
Among central banks only the Bank of England appears in filed agreements as custodians or sub-custodians. All other custodians are commercial LBMA members (Scotiabank, Deutschebank, ICBC-Standard Chartered, JP Morgan, UBS, HSBC, Brinks, Malca-Amit, and Loomis).
For some years GATA has reported suspicions that BIS gold swaps represent double-counted gold where at least two parties considered that they had good title to the same metal. The problems that the Bank of England and UK Treasury are having -- with finalizing the audited annual report of the EEA and the delays shipping out gold while possibly trying to buy gold via the Comex -- and then the bank's recently recalled role as a sub-custodian to various investment funds -- raise concerns that the Bank of England may be involved in some way as both a recipient of swapped gold and as the physical source of that gold as well.
In any case it is reasonable to wonder exactly what the Bank of England is doing with the gold held in the EEA and the gold of others, and why it is doing it. Does this include gold price control or suppression?
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Robert Lambourne is a retired business executive in the United Kingdom who consults for GATA about the Bank for International Settlements and U.S. government debt.
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