GLAN engages with the LME to enquire whether the Exchange has any mechanism in place to ensure that metals traded on it are not produced through severe environmental harm.

GLAN sends a notice to the LME's senior management alerting them of the risk of proceeds of environmental crime being traded on the Exchange (GLAN Notice), in particular as respects to copper produced at the Grasberg mine in West Papua and asking the LME to address this risk. GLAN's notice is also shared with the FCA - the LME's regulator - to alert them of the issue.

GLAN and the LMN file a claim for judicial review against the LME's policy where it admits metals for trade on the Exchange. The claim argues that this policy failed to account for the risk of money laundering of proceeds of environmental crime.

GLAN and the LMN are refused permission to apply for judicial review on the ground that there existed an alternative remedy in the form of a complaint to the FCA. GLAN and LMN decided not to renew their application for permission to apply for judicial review, but instead, follow the High Court's advice.

GLAN and the LMN submit a formal complaint to the FCA about the trading of Grasberg copper based products on the LME and flag the risk of criminal property laundering.

FCA answers GLAN and the LMN's complaint, after multiple follow ups, and concludes that the LME was compliant with its statutory duty to have appropriate measures in place to ensure that its Exchange is not used for a purpose connected with financial crime, including the laundering of proceeds of environmental crime.