Zimbabwe [state buyer/exporter (FGR) or gold dealing licensee] → Russian Federation (refine) → United Arab Emirates · Reconcile assays and pay the balance

Register as an exporter in CEPECS through the authorised dealer

من

Gold exporter (FGR or other gold dealing licence holder with RBZ approval)

يُصدر

CEPECS exporter registration

• RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.1

Obtain the Gold Export Certificate for the lot

من

Gold exporter (FGR or other gold dealing licence holder with RBZ approval)

يُصدر

Gold Export Certificate

[unconfirmed] Issuer and form of the 'Gold Export Certificate' are stated in no text held (FX Guidelines, Gold Trade Act and Regulations, Exchange Control Regulations and General Order all read); requested (zw.gap-gec).

Prepare assays and a pro-forma invoice showing the quantity, price and total value of the gold

من

Gold exporter (FGR or other gold dealing licence holder with RBZ approval)

يتطلب

FGR bar list for the export lot

يُصدر

Assays supporting the RBZ export application; Pro-forma invoice: quantity, price and total value of gold to be exported (FXG 3.2.30)

• RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.30

Submit the export application on the RBZ Document Management System with the Gold Export Certificate, Gold Dealership Licence, assays and pro-forma invoice

من

Authorised dealer bank

يتطلب

Gold Export Certificate; Gold dealing licence ('Gold Dealership Licence'); Assays supporting the RBZ export application; Pro-forma invoice: quantity, price and total value of gold to be exported (FXG 3.2.30); CEPECS exporter registration

• Exchange Control Regulations SI 109/1996; RBZ Foreign Exchange Guidelines FXD5/2026, Regulations s.20(1)(e) (no export of gold unless authorised by an exchange control authority); Guidelines para 3.2.30 ('All exports of Gold require prior Reserve Bank approval')

Approve the gold export within 24 working hours and issue an approval reference number

من

Reserve Bank of Zimbabwe

يُصدر

RBZ gold export approval (approval reference number on the Document Management System)

• RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.30

Raise the CEPECS Form CD1 quoting the RBZ approval reference

من

Authorised dealer bank

يتطلب

RBZ gold export approval (approval reference number on the Document Management System)

يُصدر

CEPECS Form CD1 (exchange control export form)

• RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), paras 3.2.5, 3.2.30

Issue the commercial invoice to the foreign buyer/refiner (attached to the export entry)

من

Gold exporter (FGR or other gold dealing licence holder with RBZ approval)

يُصدر

Commercial invoice

ZIMRA lists 'Suppliers' invoices' for the export entry; the pro-forma invoice goes to the RBZ (3.2.30). [blocked] ZIMRA page via WebFetch only.

Lodge the export bill of entry (Form 21) through a registered clearing agent in ASYCUDA World before the gold leaves, with the CEPECS Form CD1, the invoice and the RBZ approval; pay the clearance fee - 'No duties are payable on export'

من

Gold exporter (FGR or other gold dealing licence holder with RBZ approval)

يتطلب

CEPECS Form CD1 (exchange control export form); RBZ gold export approval (approval reference number on the Document Management System); Commercial invoice

يُصدر

Customs export bill of entry (Form 21, lodged in ASYCUDA World)

[blocked] The ZIMRA clearance page was read only through WebFetch. [unconfirmed] Any gold-specific customs examination is not described.

• Customs and Excise Act [Chapter 23:02]; Customs and Excise (General) Regulations 2001, Act s.54(1), s.61; Regulations s.62(1)(a); Exchange Control Regulations s.21

Where the buyer or the importing country's customs requires one (e.g. the UAE import declaration, ae.st-18), obtain a certificate of origin from the Zimbabwe National Chamber of Commerce on its form: the exporter declares 'that all the goods are of ZIMBABWE ORIGIN' and the chamber certifies it; the form carries the invoice, consignee and destination, transport, tariff number, description, net weight and the bill of entry number

من

Gold exporter (FGR or other gold dealing licence holder with RBZ approval)

يتطلب

Commercial invoice; Customs export bill of entry (Form 21, lodged in ASYCUDA World)

يُصدر

ZNCC certificate of origin for the gold consignment

ZNCC's own form read in full (a chamber, not a regulator). [unconfirmed] Whether FGR or other gold exporters obtain one in practice, its fee and turnaround were not found (requested from ZNCC). [inferred] Treated as optional: no Zimbabwean export rule requires it. [blocked] ZIMRA origin page via WebFetch only.

• Customs and Excise Act [Chapter 23:02]; Customs and Excise (General) Regulations 2001, Act s.89(1)(a) ('wholly grown or produced' test for unmanufactured goods); Regulations s.25 (certificates of origin for lower duty - imports)

An officer authorises loading by stamping the consignment note or air waybill; the airline accepts the sealed consignment as valuable cargo under the air waybill and the gold must leave Zimbabwe within ten days of the authority

من

Secure logistics provider / airline

يتطلب

Customs export bill of entry (Form 21, lodged in ASYCUDA World)

يُصدر

Air waybill

[inferred] Air freight from Harare is assumed; no Zimbabwe source names the route or carriers.

• Customs and Excise (General) Regulations 2001; Customs and Excise Act, Regulations s.63(1), (3); Act s.55(1)

File the FPP import-control application in GIIS DMDK with the foreign-trade contract, specification, document on precious-metal content and special-registration record

من

Importer of gold-bearing material for refining (refiner or special-registered company)

يتطلب

Special-registration register entry (FPP); Assay certificate (fineness and fine weight); Commercial invoice

يُصدر

FPP application for import control

• EEC Board Decision 30, Annex 14, Annex 2 (Rules) para 4(a), Rules para 4(a)

State control at a specialised customs post (all goods except ores and concentrates), within 5 working days; act of state control

من

Federal Assay Chamber

يتطلب

FPP application for import control

يُصدر

Act of state control on import

• Presidential Decree 1137 para 19¹; EEC Board Decision 30, Annex 14, Annex 2 para 10, para 19¹

Declare the goods at a specialised customs post for release or processing, presenting the act of state control, and take delivery to the refinery

من

Importer of gold-bearing material for refining (refiner or special-registered company)

يتطلب

Act of state control on import

يُصدر

EAEU goods declaration for import / customs processing

[not-read] Import duty and import VAT treatment of gold-bearing material not read.

• EEC Board Decision 30, Annex 14 paras 4, 8, Regulation para 8

Receive the lot, weigh, sample and assay; record receipt in GIIS DMDK

من

Refining organisation on the Government list

يتطلب

ESD for dispatch of dore/placer gold to the refiner; Refining (tolling) agreement miner-refiner

يُصدر

Refiner receipt: weighing and sampling record; Refiner assay of the incoming lot (metallurgical balance)

• Government Decree 972, Procedure paras 3, 7, paras 3, 7

Refine to standard bars (gold at least 995 fine; usually 999.9)

من

Refining organisation on the Government list

الشكل

Doré bar - unstamped → 999.9 kilobar

[unconfirmed] 999.9 as the usual fineness is market practice; the legal minimum for refined gold is 995 parts per 1,000 (41-FZ art. 1).

• 41-FZ art. 1 (definition of refining), art. 20(1), art. 1

Issue the quality document for each bar - a passport for a standard bar or a certificate for a measured bar (FPP Order 154n, to 28 Feb 2027); from 1 Mar 2027 a single certificate generated in GIIS DMDK (FPP Order 144n); prepare the bar list

من

Refining organisation on the Government list

يُصدر

Passport for standard bar / certificate for measured bar of refined precious metal (FPP Order 154n; replaced by a single certificate under Order 144n from 1 Mar 2027); Bar list (serials, weights, fineness)

• Government Decree 972, Procedure para 7¹; FPP Orders 154n and 144n, para 7¹

Deliver bars to the owner (or to the buyer on the owner's instruction) with a GIIS DMDK ESD; metal is booked on the owner's balance and enters civil circulation

من

Refining organisation on the Government list

يتطلب

Passport for standard bar / certificate for measured bar of refined precious metal (FPP Order 154n; replaced by a single certificate under Order 144n from 1 Mar 2027)

يُصدر

ESD for shipment of refined bars to the owner or buyer

• Federal Law 41-FZ, art. 20(3)

Screen buyer and destination: Russian-origin gold exported after the sanctions dates cannot be imported into the EU, UK, US, Switzerland or Japan, and Russian bars made from 7 Mar 2022 are not LBMA Good Delivery; sales go to non-sanctioning markets

من

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

Sign the export contract and issue the commercial invoice

من

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

يُصدر

Export contract with foreign buyer; Commercial invoice

Apply to Minpromtorg for an export licence (one-off for a contract, or a general licence under Decree 1126 or 867); Minfin approves the application in GIIS DMDK within 10 working days (Order 10n from 1 Sep 2026), except credit organisations' applications for refined gold, silver, platinum and palladium bars since 8 May 2026

من

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

يتطلب

Export contract with foreign buyer; Special-registration register entry (FPP)

يُصدر

Minfin conclusion (permissive document) approving an export-licence application (Order 10n from 1 Sep 2026); EAEU export licence issued by Minpromtorg (one-off or general)

Licence validity and issue time from EEC Council Decision 125 Rules paras 9 and 13: a one-off licence is valid up to 1 year from its start (may be limited to the contract term); a general licence up to 1 year; the licensing authority decides within 15 working days of receiving the documents unless the Commission decision introducing the measure sets another term. [unconfirmed] Decision 125's own in-force date depends on the Protocol of 25.05.2023 (see ru.law-eec-125).

• Presidential Decree 1137, Regulation paras 4 and 22; Minfin Order 10n, paras 4, 22

File the application letter for FPP state control through GIIS DMDK with: the export licence copy (table-1 goods), the contract, the specification, the invoice, the calculation of the value of the precious metals (within 5% of world prices), special-registration record or bank licence, proof of lawful ownership, the precious-metal content document, technical documentation, the subsoil licence (mining subjects) and the document on the State Fund's refusal to buy (mining and producing subjects)

من

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

يتطلب

EAEU export licence issued by Minpromtorg (one-off or general); Export contract with foreign buyer; Commercial invoice; Document on the authorised bodies' refusal (non-exercise) to purchase; Passport for standard bar / certificate for measured bar of refined precious metal (FPP Order 154n; replaced by a single certificate under Order 144n from 1 Mar 2027)

يُصدر

Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK; Calculation of the value of precious metals in the consignment

[transcription] EEC Board Decision 30 read in the ConsultantPlus copy published by the FPP; the FPP list reproduces the same paragraph.

• EEC Board Decision 30, Annex 14, Annex 2 (Rules) para 4(b); Minfin Order 11n (valuation), Rules para 4(b)

State control of the whole consignment within 5 working days: check against documents, origin, compliance with transaction rules, valuation, optional sampling; issue the act of state control (3 copies; the first for customs) or a refusal

من

Federal Assay Chamber

يتطلب

Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK

يُصدر

Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber

• EEC Board Decision 30, Annex 14, Annex 2 (Rules) paras 3, 8, 10; 41-FZ art. 26², Rules para 10

Lodge the export declaration at a specialised customs post, presenting the export licence and the act of state control

من

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

يتطلب

EAEU export licence issued by Minpromtorg (one-off or general); Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber; Commercial invoice

يُصدر

Export goods declaration (accepted and released by customs); Certificate of origin (general form) for non-EAEU destinations

[not-read] The customs rules on the declaration itself were not read.

• EEC Board Decision 30, Annex 14 paras 4-5; Presidential Decree 1137 para 19¹, Regulation paras 4-5

Carry the sealed consignment to the airport and hand to the airline (valuable cargo)

من

Secure carrier of valuables

يتطلب

Export goods declaration (accepted and released by customs)

يُصدر

Packing list; Air waybill

The armed-escort rule (41-FZ art. 29(3)) covers transport to the airport; no rule on the hand-over to the airline was read.

• Federal Law 41-FZ, art. 29(3)

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

Receive payment within three months (90 days) from export or when contractually due

من

Gold exporter (FGR or other gold dealing licence holder with RBZ approval)

يُصدر

Receipt of export proceeds

• Exchange Control Regulations SI 109/1996; Exchange Control (General) Order SI 110/1996; RBZ FX Guidelines FXD5/2026, Regulations ss.5, 21; General Order s.13(2) ('within three months from the date of export'); Guidelines para 3.2.2

Pre-acquit the Form CD1 within 48 hours of receiving the proceeds

من

Authorised dealer bank

يُصدر

CD1 acquittal (proceeds received)

• RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.7

Sell 30% of gross proceeds to the RBZ at the weighted-average willing-buyer willing-seller interbank rate; the exporter keeps 70% indefinitely (50% surrender where proceeds were overdue)

من

Authorised dealer bank

يُصدر

Sale of 30% surrender portion to RBZ at the WBWS interbank rate

[unconfirmed] Whether the general 30% surrender applies to FGR's own gold export proceeds is not stated. The February 2026 MPS (para 233) keeps 70% retention for all sectors 'with the exception of small-scale gold producers, whose retention shall be 90%'.

• RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026); FXD5/2026, FXG para 3.2.3; FXD5 para 2.2