Gold Investors New (Old) Aims

Gold companies are involved in quarter of all suspect financial transactions across the FinCEN Files

‘Free money’ for banks as investors pile into fractured gold market

Reuters

https://www.mining.com/web/free-money-for-banks-as-investors-pile-into-fractured-gold-market/

September 21, 2020

Banks are making huge profits from gold as investors flood into a market fractured by the coronavirus crisis.

The world’s largest 50 investment banks are on track to double their income from precious metals this year to around $2.5 billion, most of it from gold, Coalition, a banking consultancy, told Reuters.

“$1.2 billion was the earnings pool last year. This year we already crossed that number,” said Coalition research director Amrit Shahani.

The juicy rewards, which have not previously been reported, mark a stunning reversal of fortune for bullion banks. In March, some had to wipe hundreds of millions of dollars off their trading books as the global pandemic snarled the supply of gold bars.

That disruption sowed the seeds for the current bonanza.

Stung by the losses, many big banks lowered their trading limits on the Comex exchange in New York, the biggest gold futures market, creating a lack of liquidity that pushed prices there above prices in London, the main hub for trading physical gold, and elsewhere.

The divergence created a lucrative opportunity for banks who have the infrastructure to buy metal outside the United States and deliver it to New York to profit on the difference, especially during a pandemic, when investor demand has pushed gold prices to record levels of around $2,000 an ounce.

Reduced trading by large banks also drove prices of later-dated futures far above near-dated ones — an opportunity for those with gold to sell it forward for more than enough money to cover the cost of storage and capital.

The confluence of events has created a boom in profits on Comex, 13 sources at banks, brokers and funds told Reuters.

“It’s free money,” said an executive at one of the largest bullion-trading banks.

Even banks that reduced activity on Comex are making more money there than before, industry players said, none of whom was authorised to speak to the media.

“It’s double the profit on half the position,” a second banker said.

Banks, some hedge funds and asset managers that did little or no business on Comex have stepped up their activity, sources said and data from CME Group, which runs the Comex exchange, showed.

CME provides little data showing activity of individual actors on its market, but numbers that are available show banks including Goldman Sachs, Morgan Stanley and Citi have ramped up trade in gold in vaults registered with the exchange in recent months, either delivering metal or accepting bars which they can sell forward.

Lenders such as Wells Fargo, BNP Paribas, Royal Bank of Canada and Barclays have also made or taken deliveries of gold against futures contracts after long periods of little or no activity.

With profits running high, not only from Comex but also from trading, financing and storing gold outside the futures exchange, some banks are hiring.

Deutsche Bank is adding a third person to its recently revived precious metals team, four sources said.

Citi, Bank of America, French lender Natixis and Australia’s Westpac have also hired in precious metals this year, according to sources and LinkedIn profiles.

The banks either declined to comment or did not respond to requests for comment.

“We have seen strong growth in our precious metals markets this year, as new and existing customers use our products to manage uncertainty in today’s global economy,” said CME’s head of metals, Young-Jin Chang.

The cash and carry opportunity

Before the pandemic struck, banks such as HSBC and JPMorgan that dominate gold trading would buy metal in London and hedge their price risk by selling futures on Comex.

This allowed them to create liquidity in both places, but rested on assumptions that gold could quickly be shipped to New York if needed and that prices in the two markets would remain close together.

Those assumptions fell apart in March, when the virus shut supply routes. The link between London and New York ruptured, prices diverged sharply, and activity fell in both markets.

Futures prices became unmoored from London rates, sometimes trading cheaper but often $20 or more an ounce higher, and higher still compared to Asian countries.

With supply routes now reopened and the price premium outweighing the cost of making and shipping bars, which bankers say has ranged between $0.50 and $10 an ounce this year, more than 700 tonnes of gold worth some $45 billion at current prices has moved to New York since March, CME data show.

Before that influx, vaults registered with the exchange held less than 300 tonnes.

Flows of gold to the United States have begun to ebb, but another money making opportunity also opened in a transaction known as a roll, in which, every few months, investors in futures must swap expiring contracts for later-dated ones.

To swap the February 2020 contract for the April one cost around $6 per ounce of gold, CME and Refinitiv data show — or around $240 million in total for the roughly 400,000 100-ounce contracts trading.

When the London-futures connection broke and banks became reluctant to sell in unlimited quantities, the price rose. To roll from June to August cost around $15 an ounce on average. The longer, four-month roll from August to December cost $25 an ounce — or $1 billion in total for 400,000 contracts.

A boon for the seller, the market is costly for futures buyers.

“There is no free lunch,” said a source at a large U.S. bank. “Somebody has to lose money along the way … those people (with long positions) are every time paying money to those willing to take the other side.”

The scope for big profits has attracted more sellers into the market, from smaller banks to hedge funds and asset managers.

A further uptick in futures supply could eventually temper profits, particularly if it’s accompanied by a drop in demand, but in the meantime, banks are coining it, both by managing their own trading books and facilitating trades by new entrants.

“The amount of business we’ve done with hedge funds around this is unprecedented,” said one banker, adding that his desk’s profits from gold were already double last year’s total.

“It’s a glaringly obvious cash and carry opportunity.”

(By Peter Hobson; Editing by Veronica Brown and Carmel Crimmins)

US Treasury Department abandoned major money laundering case against Dubai gold company

The Kaloti probe offers rare insight into the illicit gold trade.

Kyra Gurney

https://www.icij.org/investigations/fincen-files/us-treasury-department-abandoned-major-money-laundering-case-against-dubai-gold-company/

September 21, 2020

After three years of digging, investigators in the United States had accumulated a mountain of evidence that they believed sealed the case against Kaloti Jewellery Group, one of the largest gold traders and refiners in the world.

The Dubai-based conglomerate had become a key cog in the dirty gold trade, buying the precious metal from sellers suspected of laundering money for drug traffickers and other criminal groups, a U.S. Drug Enforcement Administration-led task force determined. Kaloti often paid in cash — sometimes so much it had to be hauled in wheelbarrows — and wired money for suspect clients to other businesses, investigators believed.

In 2014, the task force recommended that the Treasury Department designate Kaloti a money laundering threat under the USA Patriot Act, a seldom-used measure known as the financial “death penalty” because it can freeze a firm out of the international banking system.

But the Treasury Department never took action against Kaloti. Former Treasury officials said a decision on whether to move ahead was deferred for fear of angering the United Arab Emirates, a key U.S. ally in the Middle East. When attempts to convince the UAE to act on its own against Kaloti fizzled, the investigation was mothballed.

Investigators told the International Consortium of Investigative Journalists they were baffled and disappointed. Money laundering cases are extraordinarily difficult to crack and the U.S. has struggled to police the murky gold trade. With Kaloti they thought they had a rare opportunity to send a message to the entire gold industry.

“I was incredibly frustrated,” one former official said. “What’s really sad is a lot of really, really good investigators, some really talented people, put a lot more time than they got paid for into trying to uncover a huge wrong.”

The U.S. investigation of Kaloti has not been previously reported. The outcome points to challenges common to money laundering cases: Investigators must follow money across borders and through companies based in secrecy havens, like Dubai, that have shown little interest in cracking down. Bringing cases against powerful actors also requires political will and agreement among different U.S. agencies with competing priorities.

The investigation came to light in a batch of secret bank filings that describe the flow of more than $2 trillion in suspicious transactions through the global banking system. JPMorgan Chase, Deutsche Bank and other financial institutions flooded the Treasury Department’s Financial Crimes Enforcement Network with warnings about Kaloti, flagging as suspicious thousands of transactions, worth $9.3 billion, that occurred between 2007 and 2015, the reports show.

In some reports, the banks described money flows that they said had the earmarks of money laundering. Several banks launched their own investigations and severed ties with the company — or said they planned to do so.

The documents, called suspicious activity reports, or SARs, were obtained by BuzzFeed News and shared with ICIJ and 108 media partners as part of the FinCEN Files investigation. SARs reflect the concerns of bank compliance officers and are not necessarily indicative of any criminal conduct or other wrongdoing. Some of the documents in the FinCEN Files were gathered as part of U.S. Senate committee investigations into Russian interference in the 2016 U.S. presidential election while others were gathered following requests to FinCEN from law enforcement agencies.

ICIJ confirmed additional details about the government inquiry into Kaloti with nine current or former law enforcement and other officials with knowledge of the investigation, who agreed to discuss it on the condition that their names not be used. They are not authorized to speak publicly about the case and fear repercussions for discussing it.

In a statement, a Kaloti spokesperson said the company “vehemently denies any allegations of misconduct” and has never “knowingly engaged with any criminal or criminal group.” Kaloti regularly conducts “all appropriate and required” due diligence and anti-money laundering checks, including searching criminal and regulatory databases, the statement said, and these checks have “never identified any such criminality, or its likelihood, amongst any active clients of Kaloti’s.” The gold company has never been accused or questioned by any regulator or legal authority “about any material wrongdoing of the kind alleged or any other kind,” the statement said.

A spokesman for the DEA said the Kaloti case is now closed and declined to answer questions about the investigation.

U.S. investigators said they never questioned Kaloti directly. Because the case did not result in charges or a Treasury designation, Kaloti never had a chance to see or challenge any of the evidence investigators had gathered.

Law enforcement has long seen the gold trade as a key vulnerability in the global fight against money laundering. Drug gangs and armed militant groups use gold to launder money and fund conflicts. In the process, they have supported illegal mining operations that destroy pristine rainforest and are hubs for sex trafficking and child labor. In Peru, Latin America’s biggest gold producer and the world’s second-largest cocaine supplier, the illegal gold trade is now twice as big as drug trafficking.

“There is no better mechanism in the world for laundering money than gold,” said David Soud, head of research and analysis at I.R. Consilium, a consulting firm that specializes in analyzing resource-related crime. “It is concentrated, portable wealth, has essentially the same value anywhere in the world, and can be moved outside the global financial system.”

For these reasons, it is not unusual for a precious metal transaction to attract bank scrutiny. Gold companies are involved in roughly a quarter of all suspect transactions across the FinCEN Files.

But the FinCEN Files show that inquiries into Kaloti went beyond routine monitoring. As the U.S. investigation was gaining momentum, concerns about the company’s business practices also made headlines in the United Kingdom.

In 2014, a former partner at EY’s Dubai office reported that Kaloti had accepted gold exported from Morocco disguised as silver, with falsified paperwork. Auditors at the global accountancy firm, formerly known as Ernst & Young, also discovered that Kaloti had purchased gold from Sudan — where the precious metal has financed a militia group under investigation for genocide — without properly vetting its suppliers, according to the former EY partner. The following year, Kaloti’s refinery lost an important industry accreditation.

A spokesperson for Kaloti said the company has not been found by any regulators, international bodies or auditors to have conflict minerals, “or even the likelihood of such,” in its supply chains.

Kaloti has managed to maintain business ties with major corporations, including the Swiss refiner Valcambi, according to Global Witness, an anti-corruption advocacy group. Kaloti recently opened a new refinery in Dubai.

General Electric, Amazon, General Motors and dozens of other U.S. companies reported that Kaloti may have processed or provided gold as part of their supply chains in 2019, according to paperwork filed with the Securities and Exchange Commission.

GE and General Motors said they do not source gold directly from Kaloti. GE said it had asked the supplier who reported using Kaloti to remove the company from its supply chain. Amazon, GE and General Motors said they are committed to having an ethical supply chain.

Dubai gold rush

Gold courses through the global economy. Investors trade contracts pegged to future deliveries on major commodities exchanges in London, Chicago and Shanghai. Banks buy it from mining companies and other suppliers to resell to manufacturers, which turn it into wedding bands and iPhone circuits. Middlemen hawk it in late-night infomercials.

The price of gold can fluctuate greatly. It rose to $1,895 a troy ounce in 2011, fell to $1,062 in 2015 and is now hovering around $1,900. And yet it is often seen as a haven by investors spooked by volatile markets. That’s partly because the metal has staying power. Gold has underpinned world powers as distinct as 16th-century Spain, which built a global empire with gold looted from Latin America, and the 21st-century United States, which holds more than 261 million troy ounces (8,000 metric tons) worth more than $11 billion in government vaults.

For Munir Al Kaloti, the founder of the Kaloti Jewellery Group, gold was the foundation of a business empire.

Al Kaloti fled Jerusalem to what is now the UAE in the 1960s, when it was still a dusty backwater with few paved roads. He got his start scavenging scrap metal and later imported goats for the then-ruler of Dubai, he said in a 2013 interview with a local news site.

In 1988, Al Kaloti opened a jewelry shop with his son-in-law, who had trained as a jeweler in Italy. It wasn’t long before they were buying gold. “People carrying scrap gold and gold from mines in Africa and Asia were coming in more and more and they are asking who can handle this, who can buy this?” Al Kaloti recalled in the interview. “So we said: ‘Why not?’”

Over the next quarter-century, Dubai grew into a major financial and business center. It also became an important hub in the gold trade, aided by low tax rates, proximity to Africa and Asia, and a reputation for secrecy.

In 2000, the Kaloti Jewellery Group began trading gold bars. By 2008, it was making its own bars at a refinery in the neighboring city of Sharjah. It soon became one of the largest gold trading and refining conglomerates in the Middle East, with branches in Asia. Still, it remained a family business: Munir Al Kaloti’s son-in-law served as the general manager. One of his sons operated a gold buying office in a crowded Dubai souk.

Behind the scenes, Kaloti’s dealings had started to attract the attention of U.S. law enforcement.

Operation Honey Badger

In late 2010, a DEA-led task force in central Florida started getting calls from DEA agents investigating a money laundering scheme that spanned five continents as part of a law enforcement campaign called Project Cassandra.

An international criminal network was piping illicit cash from Colombian cocaine sales in Europe to Africa, where it was combined with proceeds from used-car sales in Benin, prosecutors later alleged. Cash couriers connected to Hezbollah, a Shiite militant group and Lebanese political party backed by Iran, allegedly moved the cash to Beirut in exchange for a cut.

The Lebanese Canadian Bank, based in Beirut, and money exchange businesses allegedly wired hundreds of millions of dollars to the U.S. for the criminal network to purchase still more used cars, completing the money laundering cycle. The network also sent funds through the bank to consumer goods companies in Asia to buy products that were shipped to South America and sold to pay cocaine suppliers.

In early 2011, the U.S. Treasury Department designated the Lebanese Canadian Bank a “primary money laundering concern” — the same financial “death penalty” that the government would later also consider for Kaloti.

A DEA-led task force scouring bank records at its central Florida office soon noticed that money sent to some of the used-car companies implicated in the Lebanese Canadian Bank case now appeared to be passing through Kaloti, a gold trader that at the time they knew little about.

“Overnight the wire transfers you saw with Lebanese Canadian Bank and these other companies switched over to Kaloti, like a light switch,” recalled one former official. “We were, like: ‘Who’s Kaloti?’”

Kaloti soon became one of the targets of a new probe, code-named Operation Honey Badger after the fierce mammal known for hunting pythons and cobras.

Investigators were especially interested in two Kaloti clients that they suspected were involved in laundering drug money through gold: Salor DMCC, based in Dubai, and a business in Benin called Trading Track Company.

Scouring financial records, investigators noticed large wire transfers, sometimes more than once a day, from Kaloti to Salor. In payment details, Kaloti referenced gold trading and Trading Track.

Salor often wired money to used-car dealers the same day, according to law enforcement records viewed by ICIJ.

“Kaloti was used to mask the source of a lot of those funds,” a former investigator said. “You had to follow the bouncing ball.”

Also a red flag for investigators: Kaloti made cash payments worth millions of dollars to suppliers. Cash is difficult to trace, making it a preferred payment method for criminal groups. Documents viewed by ICIJ show that Kaloti paid Salor $414 million in cash for gold in 2012. It paid Trading Track $28 million in cash for the precious metal that same year.

Kaloti said it couldn’t comment on its relationship with Trading Track and Salor due to confidentiality obligations. The company said it only accepts customers after conducting “robust due diligence” and that any cash transactions “were not in any way improper.”

Kaloti added that while cash is “a common method of payment” in the UAE, it made a commercial decision to stop conducting cash transactions and had stopped dealing in cash by August 2013.

Salor and Trading Track have the same owner, a lawyer for the companies said. He would not reveal who it is. Neither company has ever taken part in money laundering or other illegal or unethical conduct, the lawyer said. The companies were not informed of the U.S. investigation and have not been charged with wrongdoing in the United States or elsewhere, the lawyer added. Salor said that all of its activities in Dubai were subject to regulatory oversight and approval.

In a July interview, Trading Track manager Nemer Talj told ICIJ media partner Banouto in Benin that Trading Track transports gold for Salor that is then entrusted to Kaloti for refining.

What the banks saw

The United States is the top global enforcer of anti-money-laundering laws. The reason has a lot to do with the primacy of the U.S. dollar in global financial transactions and with the leading role major Wall Street banks play in processing payments that zip around the world.

The upshot: To do business in the U.S., a financial institution must play by U.S. rules, which means alerting the Treasury Department’s Financial Crimes Enforcement Network when it “knows, suspects, or has reason to suspect” that a transaction moving through its accounts could be part of a scheme to launder money, violate sanctions or fund a terrorist group or has no apparent business purpose.

The DEA-led task force began subpoenaing bank records, apparently putting the institutions on high alert.

The FinCEN Files show a flurry of activity in 2012 and 2013 as banks rushed to tell authorities what they’d seen.

In 2012, Kaloti began transferring large sums from its Deutsche Bank accounts to its Emirates NBD bank account in Dubai. Agents for the company then began withdrawing so much cash from Emirates NBD that the money had to be moved in wheelbarrows, a former Deutsche Bank employee later claimed.

Deutsche Bank reported the withdrawals to U.S. authorities the next year, FinCEN Files show. The bank wrote that some traders on the London commodities exchange “seemed to be backing away” from Kaloti and that Deutsche Bank planned to do the same.

With Gold Rallying, Mining CEOs Say ESG Scrutiny Is Intensifying

Steven Frank, Yvonne Yue Li and Felix Njini

https://www.bloomberg.com/news/articles/2020-09-20/with-gold-rallying-mining-ceos-say-esg-scrutiny-is-intensifying

September 20, 2020

Skyrocketing gold is providing a welcome windfall to the mining industry, but it’s also attracting a broader base of investors who are demanding greater attention to environmental, social and governance topics.

Interest in ESG issues has moved to the forefront in conversations with stakeholders in the past year, top executives said in the run-up to the Denver Gold Group’s Americas conference, a key annual event in the precious-metals world. Such talks come as investors snap up billions of dollars in stock offerings from once-shunned gold miners.

Generalists are looking at bullion because of the high prices and “the strong argument that the gold price can go higher,” according to Sean Boyd, chief executive officer of Agnico Eagle Mines Ltd., a top-10 gold producer. And those investors tend to judge mining companies through an ESG lens.

“They don’t want to take a lot of risk, and a big part of the risk assessment is the ESG side of things,” Boyd said in a phone interview.

The Denver conference, which began Sunday and is being held virtually, is also expected to generate discussions about fiscal responsibility, given gold’s near-30% rise this year, and how much free cash flow should go to shareholders. But ESG is the one issue that can rile up investors and miners even more than cash.

“Often it’s the first, and sometimes the only, discussion when we’re meeting with investors in Europe,” Tom Palmer, CEO of top producer Newmont Corp., said by phone. At the World Economic Forum in Davos in January, many times “the only topic of discussion was around carbon intensity and the work that’s being done to reduce greenhouse-gas emissions.”

Like any extractive industry, mining by its nature damages the environment. Companies also come into conflict with local communities or raise the ire of shareholders on corporate governance issues. In an open letter to the mining industry released Sunday, prominent gold investors targeted issues including executive compensation and directors who don’t have enough skin in the game.

But unlike miners of copper or battery-metals, for instance, gold producers may face more skepticism from ESG-minded investors. That’s because gold, which is mainly used to produce jewelry and acts as a store of value in bars and coins -- has less utility in advancing a green economy.

“Gold’s an odd thing because most of it sits in vaults around the world gathering dust,” B2Gold Corp. CEO Clive Johnson said by phone.

Checkered Reputation

Still, the sector has had to overcome a sometimes checkered reputation on environmental, social and management issues. And high-profile incidents in and outside the gold-mining industry have stymied the rehabilitation process. High gold prices boost the appeal to dig for gold and threaten to increase illegal operations.

ESG has really “taken a spotlight” in the past five years, said Jon Lamb, a portfolio manager at Orion Resource Partners. Events like the fatal Vale SA tailings-dam disaster in Brazil in 2019 or the destruction of Aboriginal heritage sites at a Rio Tinto Group mine in Australia this year have made such issues even more prominent.

“All these items put a very vivid image for people in the sector, people outside the sector, as to what the damage could be from mining,” Lamb said by phone.

For Newmont’s Palmer, the most important part of ESG is governance.

“That G should almost be at the front of the acronym,” he said. “Strong governance is the essential foundation in order to be able to support sustainable environmental and social performance.”

Gold Investors Take New Aim at Miners With Returns Falling Short

Steven Frank

https://www.bloomberg.com/news/articles/2020-09-20/gold-investors-take-new-aim-at-miners-with-returns-falling-short

September 20, 2020

A coalition of gold investors, including firms backed by billionaires John Paulson and Naguib Sawiris, is urging changes at miners as performance “continues to fall short” in some areas even as prices rise.

In an open letter to the mining industry, prominent gold investors including money managers at Franklin Templeton, VanEck Funds and members of the Shareholders’ Gold Council are targeting issues including executive compensation and directors who don’t have enough skin in the game because they don’t hold a meaningful amount of shares in the firms they represent. The signatories offered 16 suggestions to better align the interest of managers, boards and shareholders.

Gold has been on a record-setting tear as the pandemic threatens to derail global economic growth, sending investors on a flight to safe havens. That comes at a time when real yields are falling as governments unleash massive stimulus programs. Precious-metal miners have seen their shares skyrocket with a gauge of senior gold producers climbing almost 80% in the past year.

“Though the performance of gold mining stocks has been noteworthy recently, we believe that performance continues to fall short in the areas of corporate governance, alignment of incentives and strategic vision & communication with investors,” the group said in the letter released Sunday. That was the first day of the Denver Gold Group’s Americas conference, a key annual event for the industry.

Shareholder payouts will be a key topic for gold miners this year as higher prices leave companies with large piles of cash. Historically, bullion producers have focused on growth rather than cash returns, were overoptimistic about projects and had poor capital discipline, which were “key drivers of value destruction by the gold miners,” UBS Group AG analysts including Daniel Major said in a Sept. 15 report.

The Shareholders’ Gold Council -- spearheaded by Paulson & Co. at the Denver conference in 2017 and formally launched a year later -- has agitated for change using the clout of a membership that includes influential investors and fund managers. The open letter, which also includes investors outside the Council, didn’t name particular companies and instead argued the group was not focused on criticism but wanted to offer solutions instead.

“Despite strong performance, mining shares are still episodically inexpensive,” the group said. “We believe that adoption of these suggested measures will improve current low equity valuations by attracting a wider audience of generalist investors and thereby lower the industry’s cost of capital to the benefit of all stakeholders.”

Among this year’s suggestions were calls for board-level changes such as setting up “a clear disclosed process for selecting directors that includes meaningful dialog with shareholders.” It also wants companies to establish “strict term limits for directors who do not have meaningful stock ownership,” an issue that the Shareholders’ Gold Council had addressed in the past.

On the management level, the coalition is asking companies to include and disclose to investors “per-share value metrics in calculating compensation,” and define -- at the beginning of the year rather than retroactively -- how teams’ annual compensation will be assessed.

In terms of general strategy, the investors want gold miners to maintain active data rooms “without onerous entry conditions,” some of which they say prevent potential buyers from taking offers directly to shareholders. They also want gold producers to set out “a capital return framework which balances the allocation of free cash flow towards dividends, share buybacks, and manageable growth initiatives.”

“Adoption of these suggested measures will improve current low equity valuations by attracting a wider audience of generalist investors and thereby lower the industry’s cost of capital to the benefit of all stakeholders,” the group says in its letter.

In a 2018 report, the Council took aim at mining executives who had a low ownership-to-pay ratio in a comparison of executives and chairmen at 17 gold companies. Last year, a second report said “significantly mismanaged” gold companies could unlock $13 billion in value through mergers and cost cuts.

Interest in environmental, social and governance topics has moved to the forefront in conversations with stakeholders in the past year, industry executives say. Rising gold prices will only increase that pressure, with Newmont Corp. Chief Executive Officer Tom Palmer saying ESG is sometimes the only topic of discussion when talking to shareholders in Europe.

There are 24 signatories in the letter including Karim Nasr, group CEO of the Sawiris family’s La Mancha Holding S.a.r.l; David Neuhauser, managing director at Livermore Partners; and John Hathaway, a senior portfolio manager at Sprott Asset Management LP. Other signatories included money managers from Invesco Ltd., Mackenzie Investments, CI Investments and Kopernik Global Investors LLC.