Global companies including Volkswagen, Tesla, Nokia, and Amazon have listed four gold refiners sanctioned by the US, EU, or UK as potentially present in their supply chains, according to Financial Times analysis of regulatory filings. More than 160 US firms and at least 10 others included one or more of the blacklisted entities — Russia's Uralelectromed and Krastsvetmet, Uganda's African Gold Refinery, and Rwanda's Gasabo Gold Refinery — in their latest conflict minerals disclosures.

The findings underscore legal risks under US sanctions rules, which impose strict liability for indirect dealings with sanctioned entities even through multiple intermediaries. A former US Treasury official warned companies could be "held legally culpable" regardless of awareness. However, lawyers note de minimis indirect dealings are not currently an enforcement priority.

Companies stress that inclusion does not confirm actual use of materials from these refiners. Amazon listed Krastsvetmet but said it was "unable to validate the accuracy of the list." VW included all four, noting its disclosure covers "potential suppliers" it can neither confirm nor deny. The gap between regulatory breadth and firms' ability to trace every supply chain link remains a critical compliance challenge.