Switzerland (refine) → United Kingdom · Loco London OTC sale and settlement

Weigh-in, seal-check, drill/dip-sample, fire-assay (ASTM E1335/ISO 11426) the incoming 995 bar

من

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

يتطلب

Refining/re-refining agreement, Swiss refiner; Refiner file on the Dubai supplier: identity, commercial-register extract, proof of lawful acquisition (export permit/declaration, mining licence where applicable), SECO embargo check, origin clarification (kept for the period the EMKV sets: zehn Jahren)

يُصدر

Refiner outturn/assay report (Switzerland); Purchase book: customer, ID proof, acceptance date, description and marking, weight on acceptance, weight after melting, completion

[unconfirmed] Weigh-in, seal check and ISO 11426 are not in the sources read; ASTM E1335-24 covers fire assay of bullion, and Valcambi describes fire assay of drillings from samples taken from the melt of the received material.

• Fire assay standard practice

Pay the Dubai counterparty for the imported bar once the Swiss refiner's own assay confirms fine content

من

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

يتطلب

Refiner outturn/assay report (Switzerland)

يُصدر

Final invoice from the Dubai seller (against Swiss outturn assay); Settlement wire, Swiss refiner -> Dubai counterparty

• Refining/sale contract; SWIFT MT103

Wohlwill electrolytic re-refine to 999.9, or cast directly to LBMA Good Delivery 400oz spec (995 min) if already qualifying

من

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

يتطلب

Refiner outturn/assay report (Switzerland)

الشكل

Pre-refined 995 bar (e.g. 'Dubai 995') → LBMA Good Delivery 400oz bar

[unconfirmed] Wohlwill electrolytic refining to 999.9 is industry practice not described in the Good Delivery Rules, which set only the bar specification (350-430 fine troy ounces, minimum fineness 995.0).

• LBMA Good Delivery Rules (bar spec, marking)

Stamp each bar with the melting-licence holder's stamp (Stempelzeichen); bars for resale are assayed by a control office or sworn trade assayer and marked with fineness and the assayer's mark; for LBMA Good Delivery bars also serial number, fineness to four figures and year

من

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

يُصدر

Bar list (serials, weights, fineness)

Serial number and year are LBMA requirements, not Swiss law. The earlier wording "registered responsibility mark" was wrong for bars (that mark, EMKG Art. 9, applies to finished wares). EMKV marking articles (Arts. 169, 173) were read only as restated by the BAZG (Vorschriften Dec 2023, held); the EMKV text is not yet held.

• PMCA (EMKG, SR 941.31); BAZG R-247; LBMA Good Delivery Rules, EMKG Art. 31(1); R-247 s.3.4.1; LBMA GD Rules s.2.1.7

File annual LBMA RGG independent assurance report; and (if volume threshold met) CO 964j-l conflict-minerals public report

من

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

يُصدر

LBMA Responsible Gold Guidance annual assurance report; CO 964j-l conflict-minerals due-diligence public report

[time-limited] RGG v9 applies until RGG v10 takes effect: implementation 1 Jan-31 Dec 2027, first v10 audits for the reporting year ending 31 Dec 2027 (consultation closed 10 Jul 2026).

• LBMA RGG v9; CO Art. 964j-964l

Screen the bars, buyer and destination against Swiss sanctions before release: no purchase, import, transit or related services (including brokerage and financing) for gold of Russian origin exported after 4 Aug 2022 or gold processed from it in third countries

من

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

[transcription] Art. 14d paras 1-4 read in an unofficial third-party English translation (as at 22 Mar 2024, held in laws/); Annex 26 covers 7108, 7112 91 and ex 7118 90 gold coins; Annex 27 ex 7113 and ex 7114. [unconfirmed] The official consolidation is now Stand 21 Sep 2026 and was not read (the fetch tool truncates before Art. 14d); changes after March 2024 are not ruled out. The ordinance contains no explicit ban on selling gold to Russia; the export-side effect is through the services ban.

• Ordinance of 4 March 2022 on measures in connection with the situation in Ukraine (SR 946.231.176.72), Art. 14d

Release the bars from the refinery vault or free port against the owner's instruction and prepare the weight list (bar list), commercial invoice and packing list for the shipment

من

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

يُصدر

Outbound weight list / bar list; Commercial invoice to the foreign buyer; Packing list

The weight list is sourced to LBMA Annex C; commercial invoice and packing list are standard export practice, not read in a Swiss source.

• LBMA Good Delivery Rules, Annex C (weight lists); Customs Act Arts. 62-66 (free ports)

Lodge the electronic export declaration in Passar (HS 7108; e-dec Export was usable only to end-2025); the declarant must make it binding and physically export the goods within 120 days of its acceptance in the IT system

من

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

يُصدر

Passar export declaration (HS 7108)

R-10-10 (valid 1 Jan 2026) cites Art. 25-29 ZG and Art. 79-83 ZV for the declaration duty, says declarations are electronic in principle, and sets the 120-day limit from acceptance in the IT system. R-10-10 held and read in full on 2026-09-28; the Customs Act and Ordinance texts themselves were not read. R-10-10 has no gold-specific rule.

• Customs Act (ZG, SR 631.0); BAZG R-10-10, ZG Arts. 25-29 (as cited in R-10-10)

Receive the export assessment notice (Veranlagungsverfuegung Ausfuhr), the evidence that the goods were properly cleared for export

من

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

يُصدر

Veranlagungsverfuegung Ausfuhr

R-10-10 cites Art. 38 and 69 ZG and Art. 92 ZV for the export assessment notice and says it is evidence of proper assessment and of export for VAT. R-10-10 held and read in full on 2026-09-28.

• Customs Act (ZG); BAZG R-10-10, ZG Arts. 38 and 69; ZV Art. 92 (as cited in R-10-10)

Treat the sale as a VAT-exempt export (supply of goods directly transported abroad) and keep the export assessment notice as evidence

من

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

يتطلب

Veranlagungsverfuegung Ausfuhr

Art. 23(2) no. 1 read in the held MWSTG (Stand 1 Jan 2025, German wording current). Art. 23(3): direct export includes export into an open customs warehouse or a free port. Investment gold of at least 995 fineness is separately exempt with credit under Art. 23(2) no. 12 (see ch.tax-import-vat).

• Federal VAT Act (MWSTG, SR 641.20), Art. 23(2) no. 1

Hand the sealed consignment to a secure valuables carrier and fly it out (Zurich or Geneva) under an air waybill

من

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

يُصدر

Air waybill (outbound)

Carrier practice. Cantonal licensing: in the Canton of Zurich "Sicherheitstransporte von Personen, Gütern und Wertsachen" require a licence under the Polizeigesetz, 9. Abschnitt (cantonal page, read by WebFetch 2026-09-28; PolG text not read). Geneva and other cantons not checked. No Swiss source read describes the outbound air leg for gold.

Apply customer due diligence to the foreign seller before buying (identity, beneficial owner, purpose, risk assessment, sanctions/PEP screening)

من

Bullion dealer / trader (importer of record, usually an LBMA member)

يُصدر

Supplier KYC pack received by the UK buyer; MLR customer due diligence file

[unconfirmed] Whether a non-bank wholesale bullion trader paid by wire is within the MLR at all (e.g. as a financial institution under reg 10) - consolidated MLR not held. [not-read] Reg 27 quoted via WebFetch; MLR not held.

• Money Laundering Regulations 2017, reg 27

Establish that the gold is not Russian-origin gold exported from Russia on or after 21 Jul 2022, not relevant processed gold incorporating such gold, and not Russian gold jewellery exported on or after 29 Oct 2022; check where the goods were originally consigned or exported from; if Russian origin is possible, apply to DBT's Import Sanctions Team for a licence or contact it; declare document code 9022 (not subject to / exempt from sanctions) or 9011 (licence) on CDS and keep the evidence to produce on demand

من

Bullion dealer / trader (importer of record, usually an LBMA member)

يتطلب

Export customs declaration accepted by the dispatching country's customs

يُصدر

Importer's Russia-sanctions origin evidence file

[inferred] The guidance and tariff do not list specific evidence documents; the required kinds are this module's inference.

• Russia (Sanctions) (EU Exit) Regulations 2019 as amended by SI 2022/850 and SI 2022/1110, regs 46Z11, 46Z16B, 46Z16C

Fly the bars into the UK as valuable cargo (typically Heathrow) under an air waybill

من

Secure valuables carrier

يُصدر

Air waybill, inbound valuables consignment

UK valuables-cargo handling not researched in this pass.

Submit a full import declaration on CDS (procedure code, commodity code 7108 12 00 00 for unwrought gold, DUCR, consignor/consignee, value, licences; EORI); declare sanctions document code 9022 or 9011; claim the investment-gold VAT exemption with additional code VATE where the bars are 995+ of a weight accepted by the bullion markets

من

Customs agent / declarant using CDS software

يتطلب

EORI number of importer/exporter; Importer's Russia-sanctions origin evidence file; Air waybill, inbound valuables consignment; Air waybill; Commercial invoice; Bar list (serials, weights, fineness)

يُصدر

CDS full import declaration

[conflict] gb.div-cpc-chief - VAT Notice 701/21 s.8.1 still gives CHIEF CPC 40 00 073; the tariff (28 Sep 2026) shows the exemption as additional code VATE. [not-read] The CDS procedure code and DE 1/10-1/11 entries for investment gold not read (UK Trade Tariff Vol. 3 listed in gb-fetch.tsv).

Account for import VAT: exempt for investment gold (additional code VATE); 20% standard rate (code 03020) on non-investment gold (dore, grain, scrap, sub-995 bars, non-qualifying coins); customs duty 0.00% (third-country rate on 7108 12, S.I. 2020/1430)

من

Bullion dealer / trader (importer of record, usually an LBMA member)

يتطلب

CDS full import declaration

• VAT Act 1994 Sch 9 Group 15; VAT Notice 701/21, Notice s8.1, s10.7

Clear the goods (CDS message when cleared), or ask for supporting documents for a customs check; for 7108 the Russia/Belarus measures read "Import allowed after control"; HMRC enforces trade sanctions at the border

من

HMRC (customs and VAT authority)

يتطلب

CDS full import declaration

يُصدر

CDS clearance notification (goods released)

Give the custodian written notice of the deposit (amount, Availability Date, and the carrier and packing for physical delivery, or the source account for book-entry); advise the vault manager of the vehicle registration and driver's identity

من

Bullion dealer / trader (importer of record, usually an LBMA member)

يتطلب

CDS clearance notification (goods released)

يُصدر

Deposit notice to London custodian

• LPMCL Allocated Account Agreement; LBMA Good Delivery Rules, Allocated cl. 3.3 (Unallocated cl. 3.2); GD Rules Annex B s.2

Weigh the bars under the London weighing procedures (the receiving party may charge for weighing if not weighed by an Approved Weigher) and produce the machine-readable, dated weight list stating whether an Approved Weigher weighed the metal; a copy travels with the bars

من

LBMA Approved Weigher

يُصدر

Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)

• LBMA Good Delivery Rules, Annex B

Receive bars on pallets; before crediting, verify compliance with the Rules and weigh them per LBMA practice against the notified amount; the vault manager may refuse bars not meeting Good Delivery standards and may ask LBMA to appoint independent inspectors

من

London commercial vault / custodian (typically a clearing or custodian bank)

يتطلب

Deposit notice to London custodian; Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)

• LPMCL Allocated/Unallocated Account Agreements; LBMA Good Delivery Rules, Allocated cl. 3.1(b), 3.4, 3.5; Unallocated cl. 3.1(b), 3.3, 3.4; GD Rules 2.4 and Annex B

For bars of the six suspended Russian refiners: accept only bars produced while the refiner was listed and already in the loco London/Swiss markets before 7 Mar 2022; clearing banks attest conformity

من

London commercial vault / custodian (typically a clearing or custodian bank)

يتطلب

Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)

Separately, UK law bans import of Russian gold exported from Russia on or after 21 Jul 2022. [unconfirmed] GD Rules 2026 s.1.4 says bars of a refiner moved to the Former List for sanctions reasons may lose Good Delivery status; LBMA's specific Russian-bars page keeps pre-7 Mar 2022 loco London/Swiss stocks as Good Delivery - the model follows the specific page.

• LBMA Good Delivery List suspension notice (7 Mar 2022)

Credit the client: an allocated account (specific bars, title stays with client, weight list issued) or an unallocated account (a metal debt claim on the custodian); statements at least annually

من

London commercial vault / custodian (typically a clearing or custodian bank)

يتطلب

Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)

يُصدر

Allocated weight list (bar number, gross weight, fineness, fine weight, brand) or unallocated balance statement

• LPMCL Account Agreements, Allocated cl. 2.3, 7.3 and Schedule (bar numbers, purity, gross and fine weight, brand); Unallocated cl. 1.1, 2.3, 3.3

Central-bank channel: hold Good Delivery bars in an allocated account at the Bank of England (off the Bank's balance sheet)

من

Bank of England (gold custodian)

الشكل

LBMA Good Delivery 400oz bar → Monetary gold (central bank reserve)

Monetary state applies when held as reserves by a monetary authority.

Report month-end holdings to LBMA (London vault data) and, from Dec 2026, aggregated vault data into the Gold Bar Integrity database (bar-level reporting planned from 2027)

من

London commercial vault / custodian (typically a clearing or custodian bank)

يُصدر

Custodian holdings return to LBMA (London vault data / GBI)

Onboard the counterparty: MLR customer due diligence and sanctions representations in the account agreement

من

LPMCL clearing member bank

يُصدر

MLR customer due diligence file

[not-read] MLR reg 27 quoted via WebFetch; MLR not held.

• MLR 2017; LPMCL account agreements, MLR reg 27; LPMCL Allocated cl. 10 / Unallocated cl. 8

Agree the OTC trade (spot/forward) under the 1994 International Bullion Master Agreement (IBMA) or an ISDA Master Agreement with the 1997 ISDA Bullion Definitions; LBMA Members must comply with the Global Precious Metals Code

من

Bullion dealer / trader (importer of record, usually an LBMA member)

يتطلب

MLR customer due diligence file

يُصدر

OTC bullion trade confirmation (IBMA 1994 / ISDA Bullion Definitions 1997)

Apply the VAT treatment: investment gold between LBMA members is zero-rated (TMO); gold held in the UK between central banks, or between a central bank and an LBM member, is zero-rated (VATA Sch 8 Group 10); investment gold between an LBMA member and a taxable non-member is standard-rated under the special accounting scheme (the buyer accounts for the VAT); to private individuals it is exempt; other investment gold is exempt unless the supplier has opted to tax; standard-rated gold (fine gold, grain, scrap, opted investment gold) between VAT-registered traders goes under the compulsory special accounting scheme

من

Bullion dealer / trader (importer of record, usually an LBMA member)

يتطلب

OTC bullion trade confirmation (IBMA 1994 / ISDA Bullion Definitions 1997)

[conflict] gb.div-tmo-member-category. [not-read] TMO arts 3-7 and VATA s.55 not held; the member/non-member rule is from VGOLD1600 ("Supplies of investment gold between members and non-members who are taxable persons are now standard-rated") and Notice 701/21 ss. 11.2, 11.5.

• VAT (Terminal Markets) Order 1973; VATA 1994 s.55, Sch 8 Group 10, Sch 9 Group 15

Settle loco London: book transfer between unallocated accounts through LPMCL members (client instructions by 16:00, inter-member by 16:30 London), or transfer of specific allocated bars

من

LPMCL clearing member bank

يتطلب

OTC bullion trade confirmation (IBMA 1994 / ISDA Bullion Definitions 1997); Allocated weight list (bar number, gross weight, fineness, fine weight, brand) or unallocated balance statement

يُصدر

Loco London settlement: transfer between unallocated accounts via LPMCL members, or allocated bar transfer

Cut-offs (client instructions until 4.00pm, LPMCL members until 4.30pm London time) confirmed in the held 2017 OTC Guide; the current web section not held.

Pay the cash leg against metal settlement

من

LPMCL clearing member bank

يتطلب

Loco London settlement: transfer between unallocated accounts via LPMCL members, or allocated bar transfer

يُصدر

Cash-leg payment for the metal

Cash-leg timing and DvP arrangements not documented in the sources read.

For exempt investment gold: issue an invoice with a unique number and the prescribed details for each sale over GBP 5,000 (or smaller sales once a customer passes GBP 10,000 in 12 months); keep the accounting and customer records (identity from one List 1 and one List 2 document) for at least 6 years; notify HMRC in writing within 28 days of the first exempt supply over GBP 5,000 or when supplies to one customer exceed GBP 10,000 in 12 months; failures attract a penalty normally of 17.5% of the transactions' value

من

Bullion dealer / trader (importer of record, usually an LBMA member)

يتطلب

Loco London settlement: transfer between unallocated accounts via LPMCL members, or allocated bar transfer

يُصدر

Investment gold invoice (VAT tertiary legislation s.3 / VAT Regs reg 31A); Investment gold customer records and identity evidence; Notification to HMRC of exempt investment gold dealing (within 28 days)

Tertiary legislation (force of law, held). [unconfirmed] The general 6-year retention and the 17.5% penalty are in Notice 701/21 ss. 7.7 and 9.4, outside the passages marked as having force of law.

• VAT Regulations 1995; VAT tertiary legislation (gold), reg 31A

Keep MLR records 5 years; nominated officer files a suspicious activity report where there is suspicion

من

LPMCL clearing member bank

يتطلب

MLR customer due diligence file

يُصدر

Suspicious activity report to the National Crime Agency

MLR record-keeping regulation not held; 5 years from the end of the relationship or completion of the transaction per HMRC guidance.

Identify contracting party and beneficial owner; assess source of wealth/funds for the specific bullion; sanctions/PEP screening

من

Swiss bank (bullion buyer)

يُصدر

Bank KYC file (CDB 20): name, date of birth, nationality, domicile and ID for natural persons; company name, registered office and proof for entities; Form A - declaration of the beneficial owner of the assets; Form K - controlling persons with 25%+ of an operating entity (CDB 20 Art. 20-21)

Downgraded 2026-09-28 from primary-law: the provisions cited are CDB 20 (a self-regulatory agreement of the SBA, held and read for Arts. 4, 7, 20-21, 27-28); the AMLA itself was not read for this step. The SBA says the revised CDB will not be available until 1 Jan 2027 at the earliest. [unconfirmed] Source-of-wealth assessment and sanctions/PEP screening were not found in the CDB 20 text read. [time-limited] The GwG consolidation of 1 Oct 2026 amends the AMLA widely; effects not assessed.

• AMLA; SBA Agreement on due diligence (CDB 20), CDB 20 Art. 4 (identification; precious-metals trading and cash transactions over CHF 15,000 are separate cases), Art. 7 (data recorded), Art. 20-21 (controlling persons 25%+, Form K), Art. 27-28 (beneficial owner, Form A)

Seller presents bar list, refiner's assay certificate, chain-of-custody documentation, commercial invoice, proof of title

من

Swiss bank (bullion buyer)

يُصدر

Commercial invoice from the seller to the bank (VAT law requires one only if the buyer asks for it: MWSTG Art. 26(1); contents Art. 26(2); the sale of investment gold is VAT-exempt: Art. 23(2) Ziff. 12)

A bar not from an LBMA Good-Delivery-listed refiner generally cannot be sold to a major bank without re-refining - this is market practice, not itself a statute Commercial invoice and delivery receipt are practice (no primary source); "proof of title" for allocated bars is the weight list plus the custody contract - no statutory title document found.

Verify bars against the bank's accepted-refiner list / Good Delivery List; settle loco Zurich or loco London, allocated or unallocated

من

Swiss bank (bullion buyer)

يُصدر

Settlement confirmation / custody account entry; Allocated account weight list (specific bars = ownership) or unallocated account statement (contractual claim only)

Record the transaction and the clarifications made; retain the records for at least ten years after the end of the business relationship or completion of the transaction

من

Swiss bank (bullion buyer)

The official fedlex consolidation of the GwG is now held on the server and the article was read there; this replaces the earlier reading on droit-bilingue.ch and fedlex by WebFetch. The ten-year retention is written in words in the law (zehn Jahren), so it is kept in words here and not as an amount: the verifier reads number words in English only.

• Anti-Money Laundering Act (AMLA/GwG) (articles in refs), GwG Art. 7 Abs. 1 (records of transactions and clarifications)

  “Der Finanzintermediär muss über die getätigten Transaktionen und über die nach diesem Gesetz erforderlichen Abklärungen Belege so erstellen, dass fachkundige Dritte sich ein zuverlässiges Urteil über die Transaktionen und Geschäftsbeziehungen sowie über die Einhaltung der Bestimmungen dieses Gesetzes bilden können.”

• Anti-Money Laundering Act (AMLA/GwG) (articles in refs), Art. 7 Abs. 3 (kept at least ten years)

  “Nach Beendigung der Geschäftsbeziehung oder nach Abschluss der Transaktion be- wahrt er die Belege mindestens während zehn Jahren auf.”

• Anti-Money Laundering Act (AMLA/GwG) (articles in refs), Art. 2 Abs. 2 Bst. a (banks are financial intermediaries)

  “Finanzintermediäre sind: a.10 die Banken nach Artikel 1a des Bankengesetzes”