JOHN BULLOCK

ATTORNEY


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 chloroplatinate sensitization ("Chloroplatinate Toxicity and Merget", a paper presented at the 2010 IPMI Annual Conference), metals recovery from electronics, and anti-money laundering. 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 Officer, 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 the present 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), and he has also attended numerous meetings of working groups, as the representative of the IPMI and the International Chamber of Commerce. Mr. Bullock represents the IPMI on the U.S. Department of Commerce International Trade Administration Advisory Committee for Nonferrous Metals, and has represented the IPMI as the last three Ministerial Conferences of the World Trade Organization (Cancun, Mexico 2003; Hong Kong 2005; Geneva 2009)

Mr. Bullock's experience has given him an understanding of precious metals and of the interests and concerns of persons who use and manage them.

This site contains additional information about Mr. Bullock, including copies of recent papers written by him, in his resumé, and about how to contact him.

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