John Bullock

John Bullock provides legal services to refiners and users of precious metals: gold, silver, platinum and palladium. After graduation from law school and private practice for ten years, John Bullock joined Handy & Harman, an old and internationally famous precious metals company, as its Environmental Counsel in 1986. In that role he was involved in refining operatons and associated air, water, superfund and waste issues. He then served as General Counsel, Secretary and Director of Handy & Harman Refining Group, with broad corporate responsibilities. In 1999 Mr. Bullock returned to private practice, with clients limited to the precious metals industry. Current issues include Conflict Gold ("Conflict Gold: The Good, the Bad, and the Ugly", a paper presented at the 2011 Conference of the London Bullion Market Association), chloroplatinate sensitization ("Chloroplatinate Toxicity and Merget", a paper presented at the 2010 IPMI Annual Conference), metals recovery from electronic scrap, and anti-money laundering. In the Conflict Gold issue, Mr. Bullock participates in the OECD Gold Working Group and Drafting Committee, the EICC-GeSI Gold Working Group, the RJC Standards Committee, and in meetings of the LBMA and WGC. Mr. Bullock has closely followed development of the regulation of the U.S. Treasury requiring that a "dealer in precious metals" create and implement an anti-money laundering program, and was pricipal author of a guidance issued by the intergovernmental Financial Action Task Force. The final U.S. regulation is reviewed in "AML for Precious Metals - Beyond the Final Rule", a paper presented at the 2005 Annual Conference of the International Precious Metals Institute. His AML implementation for Metalor Technologies USA, a major gold refiner for which he serves as Compliance Monitor, is described in "Practical Lessons in AML Implementation", a paper presented at the 2006 IPMI Annual Conference. A discussion of AML suspicious activity reporting is presented in "Communication of AML Suspicion by Dealers in Precious Metals: Defamation and Defenses", a paper presented at the 2009 IPMI Annual Conference. Mr. Bullock represents the IPMI on the U.S. Treasury's Bank Secrecy Act Advisory Group. In addition, Mr. Bullock has served the precious metals industry from 1988 to 2012 as Chairman of the Environmental & Regulatory Affairs Committee of the IPMI, as its representative to the Basel Convention and to the World Trade Organization. Mr. Bullock is the only representative of an industry organization to have attended all of the meetings of the Conference of the Parties to the Basel Convention (Piriapolis,Uruguay, 1992; Geneva, Switzerland 1994 and 1995; Kuching, Malaysia 1998; Basel, Switzerland 1999, Geneva, Switzerland 2002 and 2004; Nairobi, Kenya 2006; Bali, Indonesia 2008; Cartagena, Colombia 2011), and he has also attended numerous meetings of working groups, as the representative of the IPMI and the International Chamber of Commerce.