Ghana [Large-scale mine own export] → United Arab Emirates · Reconcile assays and pay the balance

Mine, process and smelt ore into doré at the mine under the mining lease

من

Large-scale mining company (mining lease holder)

يتطلب

Mining lease

الشكل

Ore (in situ / run-of-mine) → Doré bar - unstamped

The doré product is from the GoldBod 20% arrangement description

Keep prescribed records at a notified address in Ghana for Minerals Commission inspection, and file the monthly report (within 15 days after month end: minerals won, quantities sold, revenue received, royalties payable and paid, taxes paid) and the half-yearly and annual reports

من

Large-scale mining company (mining lease holder)

[ocr] L.I. 2173 read in OCR; reg 23 figures not checked against the page image.

• Minerals and Mining Act, 2006 (Act 703) s.19; Minerals and Mining (General) Regulations, 2012 (L.I. 2173), Act 703 s.19; L.I. 2173 reg 23(1), (3)-(6)

Grade, assay, weigh and value the export consignment

من

GoldBod assay laboratory (Kotoka International Airport)

يُصدر

GoldBod assay and valuation certificate

الشكل

Doré bar - unstamped → Doré bar - stamped/exporter-sealed

The Act gives GoldBod this sole authority over all exported gold; how it is done at mine sites was not found

• Ghana Gold Board Act, 2025 (Act 1140), s.3(2)(a)

Export the doré under the mining lease and its approved marketing plan, after GoldBod assay and valuation; any Ministerial licence to deal in gold (a power Act 1140 kept) or GoldBod authorisation for exportation is not documented

من

Large-scale mining company (mining lease holder)

يتطلب

GoldBod assay and valuation certificate; Mining lease

يُصدر

GoldBod export approval / export permission

[inferred] Read in the texts: Act 703 s.6 (Minister's licence to export) and L.I. 2173 reg 3 (the mining-lease holder's export licence, Form Two) were repealed/revoked "as pertains to gold" by Act 1140 s.75(1)(b) and (3); s.75(2) keeps "the power of the Minister responsible for Mines to grant a licence to a large-scale mining company to purchase and deal in gold"; a mining lease authorises disposal of minerals "in accordance with the holder's approved marketing plan" (Act 703 s.46(c)); Act 1140 s.26(1)-(2)(f) requires a GoldBod licence for any business or related activity in the gold trading and marketing industry, including exportation, with no exception for large-scale miners. Which of these a large-scale miner holds today for each export was not found (gh.gap-lsm-export-auth).

Apply to the Ghana National Chamber of Commerce and Industry for a certificate of origin for the consignment (gold wholly obtained in Ghana), where the buyer or the importing country's customs requires one

من

Large-scale mining company (mining lease holder)

يتطلب

Commercial invoice

يُصدر

GNCCI certificate of origin

[summary] GNCCI as issuer from a summarised read (Ghana Shippers Authority item); [blocked] GNCCI's own page returned 403; [unconfirmed] whether gold exporters in practice obtain a GNCCI certificate, and its fee and form, were not found. [inferred] Treated as optional because no Ghanaian rule requiring it on export was found.

• Customs Act, 2015 (Act 891), s.70(3) (wholly obtained goods originate in Ghana); s.70(6) (certificate of origin provided to the proper officer on request)

Obtain a Bank of Ghana Exchange Control Form A2 from the bank (traditional export); lodge the customs declaration electronically on ICUMS with the export approval, invoice and other certificates attached; present the gold at the exit port or station for customs inspection; release for export

من

Large-scale mining company (mining lease holder)

يتطلب

GoldBod export approval / export permission; Commercial invoice

يُصدر

Bank of Ghana Exchange Control Form A2 (from the exporter's bank, traditional exports); ICUMS customs export declaration

[unconfirmed] The GRA procedure is general to traditional exports (it names "Unprocessed gold"); the gold-specific attachments and whether a state exporter uses Form A2 were not found. [not-read] The export-entry sections of the Customs Act 2015 were not read.

• GRA Customs export procedure (traditional exports); Customs Act, 2015 (Act 891)

Ship doré to a refinery abroad, mainly LBMA refiners in Switzerland

من

Large-scale mining company (mining lease holder)

يتطلب

ICUMS customs export declaration

يُصدر

Air waybill

Pay royalty monthly on revenue received (sliding scale 5-12% from 10 Mar 2026), with a year-end reconciliation

من

Large-scale mining company (mining lease holder)

يُصدر

Monthly mineral royalty payment and annual reconciliation

[conflict] gh.div-conflict-royalty. [summary] Rates and deadlines from TaxLawGH (summarised read); L.I. 2517 not held.

• Minerals and Mining (Royalties) Regulations, 2025 (L.I. 2517)

Pre-contract KYC on the Nigerian exporter: corporate docs, UBO, MBC/export-permit evidence, mine-of-origin declaration

من

DMCC importer / trader

يتطلب

Bank-to-bank reference confirmation (not a public letter) on the Nigerian exporter

يُصدر

Importer's KYC/due-diligence pack on the Nigerian exporter; Evidence pack from the Nigerian exporter: export licence/permit, mine location, legal existence of the ASM operation

[conflict] For an ordinary DMCC trader the binding CDD duties are those of CR 134/2025 (Arts. 5-14); DMCC RBD-GPM binds only its Accredited Members (see ae.div-dmcc-role). [inferred] "Highest-scrutiny category" for ASM is the model's reading of Rule 1.6, not a phrase in the Rules.

• DMCC RBD-GPM Rules v2/2020; Cabinet Resolution 134/2025, DMCC Rules 1.4-1.8 (KYC; Rule 1.6 specific requirements for ASM supply), Rules 2.4-2.8 (red flags); CR 134 Art. 25(1) (records at least 5 years)

File the Dubai Customs declaration on Mirsal 2 with invoice, packing list, certificate of origin and air waybill (for a free-zone consignee the Customer Guide's 'FZ Transit In' type appears to apply, not import to local); disclose the precious metals crossing the border

من

DMCC importer / trader

يتطلب

Air waybill; Certificate of origin; Origin country's export authorisation for the gold (permit, licence or clearance issued by the mining or trade authority); Commercial invoice; Packing list

يُصدر

Dubai Customs declaration filed online (for goods entering a free zone: "FZ Transit In"); Disclosure of precious metals crossing the UAE border (cargo included)

No UAE import permit for gold: Dubai Customs lists DMCC as restricting authority only for "Pearls, Diamonds, Rough Diamonds etc." (Customer Guide App. I). FZ Transit In (s.15.12.2): "foreign goods originated from any country may be brought into the free zones without being subject to customs duties or taxes. The owner of the goods in the Documents shall be a Free Zone Licensee"; documents MAWB/HAWB, commercial invoice, certificate of origin, packing list, delivery order. Mainland duty: the GCC exempted list's gold line is printed "71060000" (silver's heading) [summary][blocked]. Cross-border disclosure: see ae.doc-pm-disclosure-ae. [unconfirmed] Neither Dubai Customs guide names the declaration type for gold into a DMCC company or the DMCC Vault. [conflict] Supporting documents are due within 14 days (Customer Guide s.15.7) or 30 days (Service Guide v9 App. A) - see ae.div-customs-doc-deadline. KPMG (secondary): periodic "Goods Consumption within FZ" declaration under Dubai Customs Notice 17/2020.

• Dubai Customs Customer Guide v3.03; Dubai Customs Service Guide v9; Federal Decree-Law 10/2025, Customer Guide s.15.12.2 (FZ Transit In), App. J (DMCC declarations at the Customer Service Center at DMCC); FDL 10/2025 Art. 10 (cross-border disclosure)

Import VAT: registered importer accounts for VAT on its own return (reverse charge); investment-grade gold is zero-rated, doré is not

من

DMCC importer / trader

يُصدر

Import VAT accounted on the importer's own VAT return (registered importer)

Investment precious metals = gold, silver or platinum of 99% purity or more, in a form tradeable in global bullion markets (ER Art. 36(2), not amended in the consolidation to CD 100/2025); their supply or import is zero-rated (Art. 45(8)). [inferred] Doré below 99% does not qualify. [unconfirmed] DMCC's absence from the Designated Zones was checked only against the 2017 list (secondary copy). [not-read] FDL 16/2025 amendments (from 1 Jan 2026) not held.

• Federal Decree-Law 8/2017 on VAT; Executive Regulation (Cabinet Decision 52/2017, as amended; consolidated to CD 100/2025), Law Art. 45(8), 48(1), 49; ER Art. 36(2), 48(1), 48(5), 50(1)

If the importer sells the doré to the refiner (rather than toll-refining it): refiner gives two written statements before supply; importer issues a tax invoice without VAT (reverse charge)

من

DMCC importer / trader

يُصدر

Refiner's two written statements: VAT-registered, and buying to resell or use in production; Tax invoice without VAT for the importer-to-refiner sale

[inferred] Conditional: the model reads the reverse charge as not applying where the refiner only toll-refines metal the importer keeps title to; the sources read do not address toll refining.

• Cabinet Decision 127/2024; VAT Executive Regulation, CD 127 Art. 2(1), 2(3) (two written declarations before supply; supplier keeps them and verifies registration), 2(4) (no declarations: no reverse charge); ER Art. 59(1)(l)

Deposit refined bars into DMCC Vault (operated by Brink's)

من

DMCC Vault (operated by Brink's)

يتطلب

Manufacturer certificate accompanying UAEGD bars (states year of manufacture if not stamped)

يُصدر

DMCC Vault deposit/withdrawal receipt; DMCC Tradeflow warrant (optional; used for pledging and title transfer)

DMCC: the Vault is "Owned by DMCC and operated by Brink's Global Services" and "DMCC can assist with all customs processes". [not-read] Deposit/withdrawal documents and any bonded status of the Vault are not published; the receipt document is inferred.

Reconcile the provisional (origin) assay against the Dubai refiner's outturn assay: within the contract's splitting limit the two assays are commonly averaged; beyond it an umpire assay decides (the assay closer to the umpire's is used, and the party further from it pays the umpire); settle the difference and pay the final balance

من

DMCC importer / trader

يتطلب

Refiner outturn/assay report; Commercial invoice

يُصدر

Final invoice from the Nigerian exporter (against Dubai outturn assay); Reconciliation of provisional vs outturn assay; Balance/final payment wire; DPMSR filed in goAML for the final settlement

[unconfirmed] Debit and credit notes are not described in the two contracts read; the Johnson Matthey contract settles by metal credit, adjusted after the umpire result.

• Refining/sale contract settlement clause -- splitting limit + umpire assay if the two figures diverge beyond it

Sell FX from gold exports to commercial banks (spot and funded forwards) and supply the rest to the Bank of Ghana for reserves under GANRAP (from 3 Aug 2026; Aug 2026: US$668.21m to banks, US$646.59m to BoG)

من

Ghana Gold Board (state buyer and exporter)

يُصدر

FX sale confirmation (spot or funded forward)

Repatriate export proceeds through sales of FX and bullion to the Bank of Ghana and transfers through Ghanaian commercial banks, keeping any retention account the Minister for Finance allows

من

Large-scale mining company (mining lease holder)

Act 703 s.30(2) read: the Minister for Finance may permit a lease holder with foreign-exchange earnings to keep "not less than twenty five percent" in a retention account. [summary] A BoG notice of 30 Oct 2025 (reported by GhanaWeb) requires exporters to repatriate proceeds through their nominated bank within 120 days of shipment (one 60-day extension); the notice and the Foreign Exchange Act 2006 (Act 723) are not held. Share repatriated is disputed: Chamber of Mines ~70% (70.8% in 2024) vs GoldBod 20%.

• Minerals and Mining Act, 2006 (Act 703), s.30(2)