Dated: 1 March 2021
Independent Inspection and Audit Reports (PDF Downloads) (You will need Adobe Reader to open the Documents)
Brink’s means Brink’s Global Services Ltd.
BullionVault means the service offered by Galmarley Ltd through website domains under BullionVault.com, and potentially other websites, whereby BullionVault Customers are able to buy, own, store and sell gold or silver bullion.
BullionVault Clients Ltd means company 08672704 registered in England and Wales.
BullionVault Customers means customers of Galmarley Ltd who have an account at BullionVault held open under the prevailing Terms and Conditions of the BullionVault service.
Galmarley Ltd means company 04943684 registered in England and Wales.
Lloyds means Lloyds Bank plc.
Loomis means Loomis International (UK) Limited.
Malca-Amit means Malca-Amit Global Limited.
Owners means both Galmarley itself and all BullionVault Customers who own gold or silver through the BullionVault service.
Wells Fargo means Wells Fargo Bank N.A.
As the Directors of Galmarley Ltd we are responsible for the identification of control objectives relating to customer property and related transactions in the provision of custody services and the design, implementation and maintenance of control procedures to provide reasonable assurance on an ongoing basis that the control objectives are achieved.
We set out in this report a description of the control procedure known as the DAILY AUDIT on the BullionVault website – which operated during the period 1-November-2019 to 31-October-2020.
We confirm that
For and on behalf of the Board of Directors
Dated: 1 March 2021
The control objective of the DAILY AUDIT is to verify the aggregate of customer-by-customer property records within BullionVault to third party documents.
The third party documents are provided by Loomis, Brink’s and Malca-Amit, who hold BullionVault Customers’ gold, silver and platinum, and Lloyds and Wells Fargo, who hold BullionVault Customers’ money.
Loomis, Brink’s and Malca-Amit provide bar lists which detail the gold, silver and platinum bullion held on behalf of BullionVault. These are re-issued the day after any change in the amount of gold or silver stored.
Similarly Lloyds and Wells Fargo provide daily end-of-day bank statements with regard to BullionVault Customer money.
BullionVault maintains all the customer-by-customer records of gold, silver, platinum and money ownership. These are modified by trading activity. At all times the BullionVault accounting records should be in a position where the total amount of Owners’ gold equates exactly to the sum of gold on the Loomis, Brink’s and Malca-Almit’s bar lists, the total amount of Owners’ silver equates exactly to the sum of silver on the Loomis and Brink’s bar lists, the total amount of Owners’ platinum equates exactly to the sum of platinum on the Loomis bar lists, and the total amount of Owners’ money equates exactly to the sum of money on the bank statements for the customer segregated bank accounts.
The DAILY AUDIT procedure verifies this and posts the result on-line for public inspection. However it disguises the identity of individual BullionVault Customers by listing their holdings of gold, silver, platinum and money against an alias, which is known only to BullionVault and the customer.
The DAILY AUDIT produces three important elements of verification:-
This report is made solely for use of the Directors of Galmarley Ltd, and solely for the purpose of reporting on the procedure known as the ‘Daily Audit’ as described in your report on page 1, in accordance with the terms of our engagement letter dated 9 October 2020.
Our work has been undertaken so that we might report to the Directors those matters that we have agreed to state to them in this report and for no other purpose. Our report must not be recited or referred to in whole or in part in any other document nor made available, copied or recited to any other party, in any circumstances, without our express prior written permission.
We permit the disclosure of this report, in full only, by the Directors at their discretion to customers of Galmarley Ltd using the BullionVault service and to the auditors of such customers, to enable customers and their auditors to verify that a report by Reporting Accountants has been commissioned by the Directors of Galmarley Ltd and issued in connection with the ‘Daily Audit’ procedure, and without assuming or accepting any responsibility or liability to customers or their auditors on our part.
To the fullest extent permitted by law, we do not accept or assume responsibility to anyone other than the Directors and Galmarley Ltd for our work, for this report or for the conclusions we have formed.
This report covers solely:
The Directors’ responsibilities are set out on pages 1 and 2 of your report. Our responsibility is to form an independent conclusion, based on the work carried out in relation to the operation of the ‘Daily Audit’ procedure of the company as described in your report for the period from 1 November 2019 to 31 October 2020 and report this to you as Directors of Galmarley Ltd. Our responsibility is to report on whether the ‘Daily Audit’ procedure operated as described in your report and does not include any responsibility to evaluate the design and effectiveness of the procedure.
Our work was based on obtaining an understanding of the ‘Daily Audit’ procedure as described on page 3 of the report by the Directors, and included specific tests of the ‘Daily Audit’ procedure, to obtain evidence about the operation of this procedure. The nature, timing and extent of the tests we applied are detailed on pages 8 and 9.
We also obtained confirmation in respect of the Independent Inspection and Audit Reports issued by Alex Stewart (International) Corporation on 11 November 2020 (1 report), 19 November 2020 (1 report), 20 November 2020 (3 reports), 1 December 2020 (1 report), 2 December 2020 (2 reports) and 17 December 2020 (1 report).
Our tests are related to Galmarley Ltd and its subsidiaries as a whole rather than planned to meet the needs of any particular customer.
Control procedures designed to address specified control objectives are subject to inherent limitations and, accordingly, errors or irregularities may occur and not be detected. Such control procedures cannot guarantee protection against (among other things) fraudulent collusion especially on the part of those holding positions of authority or trust. Furthermore, our conclusion is based on historical information and the projection of any information or conclusions in the attached report to any future periods would be inappropriate.
In our opinion:
Armstrong Watson Audit Limited
10 South Parade
DATE: 1 March 2021