Sudan [concession company (70/30)] → Singapore (refine) → United Arab Emirates · Reconcile assays and pay the balance
القانون العام والإرشادات الرسمية منشورة بوصفها أبحاثاً. ليست مشورة قانونية أو ضريبية أو مالية.
البحث نفسه مكتوب بالإنجليزية. العناوين والوسوم مترجمة؛ أما النتائج والاقتباسات فغير مترجمة.
اسأل البحث
المسار مرحلة بمرحلة
كل خطوة وضريبة وضابط كما يسجلها البحث، مع أساسها القانوني ومدى وثوق البحث بها.
السودان (Doré bar - unstamped → Doré bar - stamped/exporter-sealed) ⟶ سنغافورة (Doré bar - stamped/exporter-sealed → 999.9 kilobar) ⟶ الإمارات العربية المتحدة (999.9 kilobar)
غير مدروس: السودان → سنغافورة, سنغافورة → الإمارات العربية المتحدة
المرحلة 1: السودان
حيث تبدأ البضاعة
Doré bar - unstamped → Doré bar - stamped/exporter-sealed
- 1
Obtain gold documentation for the lot (holding or storing undocumented gold illegal from Aug 2025); transfer fee for moving artisanal gold to city markets waived since 2024
- من
- Gold trader in a traditional mining market
- يتطلب
- SMRC receipt for royalty / fees collected at the mining market
- يُصدر
- Gold ownership / origin documentation (required to hold or store gold, from Aug 2025)
مصدر ثانويForm and issuer of the documentation not found.
- 2
Carry gold to a city market (Atbara, Abu Hamad, Port Sudan) and sell to an exporter or to CBOS
- من
- Gold trader in a traditional mining market
- يتطلب
- Gold ownership / origin documentation (required to hold or store gold, from Aug 2025)
مصدر ثانوي - 3
Screen the supplier and lot: dealers in metals or precious stones concluding cash transactions above the Minister's threshold must do CDD, keep records and report suspicious transactions to the FIU
- من
- Gold exporter (Sudanese legal person)
نص القانونThreshold decision not held.
Anti-Money Laundering and Counter-Terrorist Financing Act 2014, s.3, s.5, s.6
- 4
Mine and process under the mining contract; report stockpiles, CIL processing, smelting and ingots on Minerals Gate
- من
- Concession (mining contract) company
- يتطلب
- Mining contract / small-scale mining contract
- يُصدر
- Production and export return via Minerals Gate
- الشكل
- Ore (in situ / run-of-mine) → Doré bar - unstamped
إرشاد رسمي - 5
Sell the remaining 30% of net output (after in-kind government shares) to CBOS or its delegate, whether or not the 70% is exported
- من
- Concession (mining contract) company
- يتطلب
- SMRC document confirming in-kind deduction of government shares
- يُصدر
- CBOS purchase note for the compulsory 30% share (concession and small-mining companies)
إرشاد رسميCBOS Circular 2/2025, ثالثاً-1(ب)
- 6
Export up to 70% of net output with CBOS written approval, an SSMO certificate and a Ministry of Minerals export-approval certificate; concession companies keep proceeds inside or outside Sudan as their agreements allow; small-mining companies use advance payment from abroad or confirmed sight L/C and a gold export account (21 working days)
- من
- Concession (mining contract) company
- يتطلب
- CBOS purchase note for the compulsory 30% share (concession and small-mining companies)
- يُصدر
- Ministry of Minerals export-approval certificate; SSMO certificate / weight and assay documents (and hallmark); CBOS gold export approval (prior written approval / export certificate); Customs export declaration
- الشكل
- Doré bar - unstamped → Doré bar - stamped/exporter-sealed
إرشاد رسمي[conflict] Press reported 100% advance payment and local refining for concession exports in Sept 2025; Circular 2/2025 (still in force) says otherwise.
CBOS Circular 2/2025, ثانياً; ثالثاً-1(أ), ثالثاً-2
الضرائب والرسوم
Royalty (al-'awa'id al-jalila) on traditional (artisanal) gold mining
10% of the product (in gold or cash); alternatively 20% of the ore produced Traditional (artisanal) gold mining under a traditional mining contract
نص القانونالمبلغ غير مؤكدTraditional Gold Mining Regulation 2016, art.8; Schedule (art.20)
Corporation tax on gold companies
18% (reduced from 28%, 2024); USGS 2019 reported 15%
مصدر ثانويالمبلغ غير مؤكدRoyalty on gold (concession companies)
5-7% of mineral value (2019 policy)
مصدر ثانويالمبلغ غير مؤكدRegulation on the Exploitation of Minerals 2016, arts.13(6), 15
Community (social) responsibility contribution on gold producers
4% in kind of tailings companies' gold output; 1% in cash of concession companies' gold production value (based on the previous year's output)
نص القانونالمبلغ غير مؤكدMoF Decision No. 90 of 2021, ثالثاً
Fee for transferring artisanal gold from mining areas to city markets
Waived (2024)
مصدر ثانويLicence and contract fees
MMDA Schedule (SDG): mining contract application 3,000, issue 15,000, transfer/assignment 50,000; small mining contract 3,000 / 10,000 / 50,000; traditional mining contract application 3,000, issue 7,000, regularisation 40,000, new contract 15,000; certificates 100 (samples up to 20 kg), 500 (ore export), 200 (other). Traditional Gold Mining Regulation Schedule (SDG): traditional mining licence 3,000; contract fee 7,000 (well), 50,000 / 150,000 / 250,000 (small / medium / large pit); sieve licences 10,000 / 50,000 / 100,000; miner card 100. Exploitation Regulation 2016 (EUR): ore export certificate 500; sample export 100 per 20 kg; tailings-processing contract signing bonus and renewal SDG 5,000,000 each.
نص القانونالمبلغ غير مؤكدMMDA 2015, s.20(1); Schedule
Implicit levy: CBOS indicative price set USD 10/oz below the international price
USD 10 per troy ounce
إرشاد رسميالمبلغ غير مؤكدCBOS Circular 13/2026, items 1-3
State share in concessions
30% of concessions (reported); plus a reported '40% tax on any gold sold' (unexplained)
مصدر ثانويالمبلغ غير مؤكدMMDA 2015 s.27أ (2023); Circular 2/2025 ثالثاً
الضوابط
Dealers in metals or precious stones are "non-financial institutions" under the AML/CFT Act 2014 when they conclude cash transactions above a threshold the Minister sets by decision (s.3): customer due diligence (s.5), record keeping and suspicious-transaction reports to the Financial Information Un…
Cash transactions above the Minister's threshold (not found)
نص القانونAnti-Money Laundering and Counter-Terrorist Financing Act 2014, s.3, s.5, s.6
EU ban on selling, supplying, transferring or exporting mercury (CN 2805 40) and sodium cyanides (CN 2837 11) to Sudan, with related services; humanitarian exceptions; sodium cyanide contracts concluded before 15 Jul 2026 may be executed until 16 Jan 2027.
نص القانونCouncil Regulation (EU) 2026/1724, art.1b
Banks may not finance the purchase of gold and its tailings (CBOS 2026 policies, list of prohibited financing, item vii "شراء الذهب ومخلفاته"). Gold buyers and exporters must use own funds or foreign advance payments.
إرشاد رسميCBOS monetary and financial policies for 2026
Sudan is an active conflict zone with both SAF and RSF financing themselves from gold; downstream refiners following OECD/LBMA due diligence must treat all Sudanese gold as high-risk, including gold from state-owned producers now under UK sanctions. Sudan itself has no conflict-minerals law found.
مصدر ثانوي2014 version: banks may not complete gold export banking procedures for any company exporting gold, including mining and tailings companies, without CBOS prior written approval (Circular 11/2014). Superseded in substance by the 2025-2026 approval rules (sd.ctl-export-approvals-2025).
إرشاد رسميCBOS Circular 11/2014
14 Sep - 5 Nov 2025 (Circular 14/2025): purchase of free (artisanal) and tailings gold inside Sudan reserved to CBOS or its delegate; export reserved to CBOS alone and banned for any natural or legal person; purchases executed by Sudan Gold Refinery. Concession and small-mining companies stayed unde…
إرشاد رسميCBOS Circular 14/2025, ثانياً 1-4
Concession companies may export 70% of the output remaining after in-kind deduction of the government's zakat, royalty and profit shares, and must sell the other 30% to CBOS or its delegate whether or not they export; small-mining companies likewise (Circular 2/2025 ثالثاً). Earlier versions: …
30% of net output (after in-kind government shares)
إرشاد رسميالمبلغ غير مؤكدCBOS Circular 2/2025, ثالثاً-1(ب), ثالثاً-2(د)
Every person entering or leaving Sudan must declare to customs the currency and bearer negotiable instruments carried, at amounts set by regulations (AML/CFT Act 2014 s.31(1)); customs may seize them on suspicion or false declaration (s.32); breach of s.31 is punished by a fine equal to twice the am…
نص القانونAnti-Money Laundering and Counter-Terrorist Financing Act 2014, s.31, s.32, s.38(4)
EU ban on purchasing, importing or transferring, directly or indirectly, gold (CN 7108, 7112 91, ex 7118 90) that originates in Sudan and was exported from Sudan into the EU or any third country after 15 July 2026, and on related technical assistance, brokering, financing and financial assistance. E…
نص القانونCouncil Regulation (EU) 2026/1724, art.1a
Approvals banks must see before completing a gold export: concession and small-mining gold - CBOS written approval, an SSMO certificate and a Ministry of Minerals export-approval certificate (Circular 2/2025 ثانياً); tailings gold - CBOS written approval (17/2025 ثالثاً-5; restated by 18…
إرشاد رسميCBOS Circulars 2/2025 and 17/2025
Free and tailings gold may be exported by any legal person (شخص اعتباري) after all export procedures (Circular 17/2025 ثالثاً-1); exports by government bodies and by foreigners, individuals or companies, are banned except concession companies in gold mining (خامساً-4). Individu…
إرشاد رسميCBOS Circular 17/2025, ثالثاً-1; خامساً-4
No export, including export for manufacture and return, of precious metals or gemstones as bars or jewellery without hallmarking by SSMO's Hallmarking and Precious Metals Control Department as regulations provide; imports need the Department's approval, assay and hallmark unless a mutual-recognition…
نص القانونPrecious Metals and Gemstones Act 2008, s.20; s.7
2014 directions: raw gold exports prohibited and company exports refined at the Khartoum refinery (historical). Current texts: CBOS purchases are executed by Sudan Gold Refinery with fineness set by SSMO (Circular 2/2025 رابعاً; 14/2025 ثانياً-4); exporters must comply with Sudan Gold Re…
إرشاد رسميCBOS Circular 17/2025, خامساً-1
Minimum gold export contract 10 kg "or as MoIT decides" (Circular 17/2025 خامساً-2, from 5 Nov 2025); replaced on 13 May 2026 by a 1 kg minimum for free-gold export contracts (Circular 11/2026 item 3).
1 kg per free-gold contract since 13 May 2026 (10 kg, 5 Nov 2025 - 12 May 2026)
إرشاد رسميالمبلغ غير مؤكدCBOS Circular 11/2026, item 3
Payment by advance payment or by confirmed sight documentary credit whose terms contain no condition on the goods such as overseas assay ("calibration"); L/C proceeds on acceptance of documents and at most 30 days from shipment (Circular 17/2025 ثالثاً-2; same for small-mining companies under …
إرشاد رسميCBOS Circular 17/2025, ثالثاً-2
CBOS prices gold for export daily at the international 24-carat price less USD 10 per ounce, in USD per gram, announced on the XAR system to MoIT and the unified gold export window; exporters are settled at this price and no shipment passes if the proceeds fall below the value at the announced price…
إرشاد رسميCBOS Circular 13/2026, items 1-3
L/C proceeds within 30 days of shipment (17/2025 ثالثاً-2). Proceeds are credited to a "gold export account" in the exporter's name and may stay there at most 21 working days, after which the bank buys them for CBOS at its announced rate (ثالثاً-3). Free-gold proceeds may be used for the…
30 days from shipment; 21 working days in the gold export account; 21 working days in the import account
إرشاد رسميالمبلغ غير مؤكدCBOS Circulars 17/2025, 11/2026 and 12/2026, 17/2025 ثالثاً-2, ثالثاً-3
Offences (MMDA s.32(1)): exploring without a licence - up to 2 years (أ); extracting without a mining contract - up to 3 years (ب); withholding production data - up to 5 years (ج); false information - fine of at least SDG 100,000 (د); transporting, exporting, storing, possessing or dealing in mi…
نص القانونMMDA 2015, s.32(1), s.32(2), s.33
13 May - 21 Sep 2026: CBOS bought 100% of tailings (mining-waste) companies' gold at its announced price after in-kind deduction of profits and royalties from total production (Circular 11/2026 item 2). Cancelled and replaced on 21 Sep 2026 by Circular 18/2026 (see sd.ctl-tailings-sale-2026-09).
إرشاد رسميCBOS Circular 11/2026, item 2
Since 21 Sep 2026 (replacing sd.ctl-tailings-100pct): tailings companies may sell all their gold to CBOS, its delegate or exporters; tailings gold may be exported by advance payment (priced daily by CBOS) or confirmed sight L/C with proceeds within 30 days of shipment; proceeds held in a gold export…
إرشاد رسميCBOS Circular 18/2026, items 1-6
The UAE, which took about 88-95% of Sudan's official gold exports, suspended trade with Sudan in August 2025, forcing a search for other buyers (Qatar refinery agreement, Egypt, Turkey, India, Hong Kong).
مصدر ثانويUK asset freezes (16 Jul 2026) on three Sudanese state-owned mining companies - Omdurman Mining and Ariab Mining Company (suspected of generating gold revenue for the SAF) and Sudamin Company Ltd (suspected of channelling conflict-gold revenue to both SAF and RSF, incl. past links to Al Junaid) - pl…
إرشاد رسميThe Sudan (Sanctions) (EU Exit) Regulations 2020
Transporting, exporting, storing, possessing or dealing in minerals or tailings whose source of production one does not own, without a licence or Ministry permission, is an offence (MMDA s.32(1)(هـ), added 2019; up to five years). Press reported that the Aug 2025 measures made holding undocumented…
نص القانونMMDA 2015, s.32(1)(هـ)
US designations under EO 14098: Al Junaid Multi Activities Co (RSF-controlled; gold mining and export since the 2017 takeover of Jebel Amer) on 1 Jun 2023; on 7 Jan 2025 RSF leader Hemedti and UAE companies incl. Al Zumoroud and Al Yaqoot Gold & Jewellers (bought Sudanese gold for the RSF and moved …
إرشاد رسميExecutive Order 14098
المرحلة 2: سنغافورة
في الطريق
Doré bar - stamped/exporter-sealed → 999.9 kilobar
- 7
Screen the foreign supplier and its owners against MHA terrorist-designation lists, MAS targeted financial sanctions lists and UN lists (myPal); apply enhanced checks if the supplier is in a FATF call-for-action or increased-monitoring jurisdiction; record in the supplier file
- من
- Registered bullion dealer / trader (PSPM registered dealer)
- يتطلب
- Certificate of registration as a regulated dealer (PSPM Act); ML/TF/PF enterprise risk assessment and IPPC (internal policies, procedures and controls)
- يُصدر
- Supplier KYC file (incl. sanctions screening); Sanctions/terrorist-designation screening record (MHA lists, MAS TFS lists, myPal)
إرشاد رسمي[inferred] PSPM CDD is triggered by designated transactions and prescribed circumstances (cash/cash equivalent, or gold/DPT payment, above S$20,000), which bank-paid wholesale imports usually are not; supplier screening rests on the entity-level risk assessment (reg 14) and the targeted-financial-sanctions duty (reg 16), and the Guidelines' supplier red flags.
PMLTFPF Regulations 2019 regs 14, 16; ACD Guidelines v5.1
- 8
Ship bars by secure air freight to Changi with commercial invoice, packing list and bar list naming the producing refiner
- من
- Foreign supplier (refiner, bank or trader abroad)
- يتطلب
- Export customs declaration accepted by the dispatching country's customs; Refiner's certificate for the bars it produced (serials, fineness, weights, year)
- يُصدر
- Inbound air waybill; Foreign supplier's commercial invoice; Packing list; Bar list from the foreign supplier (serials, weights, fineness, refiner)
إرشاد رسمي - 9
File a TradeNet In-Non-Payment (GST Relief) permit: declaration type GTR, place of receipt IGPM, HS 7108.13.00 (bars/wafers) or 7108.12.10 (ingots), CA/SC product code BAR/INGOT/WAFER, purity in CA/SC code 1, and the producing refiner's name as supplier
- من
- Declaring agent (TradeNet)
- يتطلب
- Foreign supplier's commercial invoice; Packing list; Inbound air waybill; Commercial invoice; Packing list; Air waybill
- يُصدر
- TradeNet In-Non-Payment (GST Relief) permit for IPM (declaration type GTR, place of receipt IGPM)
إرشاد رسميGST Act 1993; RIER, s.8(4), s.22(1A); RIER reg 3(1), (2A)
- 10
Clear the consignment at Changi against the approved permit; no customs duty (gold is not a dutiable good) and no import GST for qualifying IPM
- من
- Singapore Customs
- يتطلب
- TradeNet In-Non-Payment (GST Relief) permit for IPM (declaration type GTR, place of receipt IGPM)
إرشاد رسمي - 11
Receive the bars, check serials, weights and hallmarks against the bar list, and book them to the depositor's allocated account
- من
- Vault operator / precious-metals custodian (incl. in the Changi FTZ Freeport)
- يتطلب
- Bar list from the foreign supplier (serials, weights, fineness, refiner); TradeNet In-Non-Payment (GST Relief) permit for IPM (declaration type GTR, place of receipt IGPM)
- يُصدر
- Inbound weight and serial check; Vault deposit receipt and allocated weight list
ممارسة السوق - 12
Keep the import permit, purchase order, invoice and delivery note to support the exempt import; exempt IPM imports are not reported in the GST return
- من
- Registered bullion dealer / trader (PSPM registered dealer)
- يتطلب
- TradeNet In-Non-Payment (GST Relief) permit for IPM (declaration type GTR, place of receipt IGPM); Foreign supplier's commercial invoice
إرشاد رسميIRAS IPM e-Tax Guide (20th ed.) para 8.2; Customs: keep trade documents 5 years
- 13
Weigh in the lots and record gross weight per lot against the supplier's packing list
- من
- Refinery in Singapore (LBMA Good Delivery listed; ARCS Approved Refiner)
- يتطلب
- Refining Agreement (fee schedule, assay/settlement formula)
- يُصدر
- Refinery weigh-in record
ممارسة السوق - 14
Melt, sample and assay; issue the outturn statement with fine gold content
- من
- Refinery in Singapore (LBMA Good Delivery listed; ARCS Approved Refiner)
- يتطلب
- Refinery weigh-in record
- يُصدر
- Refiner outturn statement (weigh-in, assay, fine gold credited)
- الشكل
- Doré bar - stamped/exporter-sealed → Smelted button/bar
ممارسة السوق - 15
Refine to 999.9 and cast kilobars/small bars (or 995+ 400oz bars), stamp with the refiner's hallmark, serial, fineness and weight
- من
- Refinery in Singapore (LBMA Good Delivery listed; ARCS Approved Refiner)
- يتطلب
- Refiner outturn statement (weigh-in, assay, fine gold credited)
- يُصدر
- Singapore refiner's bar list / product certificate (serial, fine weight, fineness, hallmark)
- الشكل
- Smelted button/bar → 999.9 kilobar
ممارسة السوق - 16
Settle with the supplier: credit fine gold to its metal account or buy the gold (first sale of newly refined IPM is exempt); issue debit/credit note between provisional and final assay; charge refining fee (9% GST if supplied locally, zero-rated if to an overseas customer)
- من
- Refinery in Singapore (LBMA Good Delivery listed; ARCS Approved Refiner)
- يتطلب
- Refiner outturn statement (weigh-in, assay, fine gold credited); Refining Agreement (fee schedule, assay/settlement formula)
- يُصدر
- Allocated or unallocated metal account statement; Debit/credit note (provisional vs final assay reconciliation); Invoice for an exempt supply of IPM
إرشاد رسميGST Act 1993 Fourth Schedule Part 1 para 1A; GST (General) Regulations reg 46A; IRAS ARCS e-Tax Guide paras 4.7, 4.21
- 17
Account for ARCS goods: track material from import through refining to customer; report imports under the scheme (Box 9), exempt IPM sales (Box 3) and zero-rated exports (Box 2) in the GST return
- من
- Refinery in Singapore (LBMA Good Delivery listed; ARCS Approved Refiner)
- يتطلب
- IRAS ARCS approval letter (Approved Refiner / Approved Consolidator)
- يُصدر
- GST return (GST F5) reporting IPM exempt supplies, zero-rated exports and imports under ARCS (Box 9)
إرشاد رسميIRAS ARCS e-Tax Guide paras 5.3, 8.2-8.11, App. 1
- 18
Open a custody account after KYC of the depositor; agree allocated (serial-numbered) or pooled storage, insurance and audit rights
- من
- Vault operator / precious-metals custodian (incl. in the Changi FTZ Freeport)
- يُصدر
- Vault deposit receipt and allocated weight list
ممارسة السوق - 19
Hold bars in the allocated register and issue periodic weight-list statements
- من
- Vault operator / precious-metals custodian (incl. in the Changi FTZ Freeport)
- يتطلب
- Vault deposit receipt and allocated weight list
- يُصدر
- Allocated or unallocated metal account statement
ممارسة السوق - 20
Store non-IPM gold (or goods not entered for home use) in a free trade zone or a licensed zero-GST warehouse with GST suspended until the goods enter customs territory for local use; storing gold as a "listed good" in a zero-GST warehouse needs Customs' written approval and beneficial-owner records
- من
- Vault operator / precious-metals custodian (incl. in the Changi FTZ Freeport)
نص القانون[summary] the listed-goods approval and beneficial-owner records are Customs ZGS scheme conditions (official guidance), not statute.
Free Trade Zones Act 1966 ss.2, 5; GST Act 1993 s.37(1); GST (General) Regulations 1993 reg 94; Singapore Customs FTZ and Zero-GST Warehouse guidance
- 21
Hold foreign central banks' and sovereign entities' gold under the MAS central bank gold vaulting service; MAS also extends gold accounts to selected Singapore bullion banks to manage those holdings
- من
- Monetary Authority of Singapore (central bank gold custody service)
إرشاد رسمي[unconfirmed] launch not confirmed as of 28 Sep 2026; terms of the service not published in the texts held.
- 22
Release bars on the account holder's instruction against a delivery order to a carrier or another vault account
- من
- Vault operator / precious-metals custodian (incl. in the Changi FTZ Freeport)
- يتطلب
- Allocated or unallocated metal account statement
- يُصدر
- Outbound bar list
ممارسة السوق - 23
Screen the buyer and destination: UNSC sanctions (gold may not be traded with the DPRK), FATF call-for-action jurisdictions, and designated persons
- من
- Registered bullion dealer / trader (PSPM registered dealer)
- يتطلب
- ML/TF/PF enterprise risk assessment and IPPC (internal policies, procedures and controls)
- يُصدر
- Sanctions/terrorist-designation screening record (MHA lists, MAS TFS lists, myPal)
نص القانونRIER regs 5A, 6(2)(c) and Seventh Schedule; PMLTFPF Regulations regs 7, 16
- 24
Apply for a UNSC-sanctions permit at least 3 working days before shipment
- من
- Declaring agent (TradeNet)
- يُصدر
- TradeNet permit for goods to/from a UNSC-sanctioned country
إرشاد رسمي[unconfirmed] the 3-working-day lead time is Customs guidance, not in the RIER text.
RIER, regs 5A, 6(1)(b)
- 25
Obtain the TradeNet export permit before the cargo is lodged with the air cargo handler
- من
- Declaring agent (TradeNet)
- يتطلب
- Singapore seller's export commercial invoice; Outbound bar list
- يُصدر
- TradeNet export (Out) permit
نص القانونRIER, reg 3(1)(b), (3)
- 26
Where the buyer or the importing country asks for it, obtain an ordinary (non-preferential) certificate of origin from Singapore Customs or an authorised chamber, or issue one on the exporter's own account; the origin stated is the country where the bars were produced (refined), not Singapore, unless they were substantially transformed in Singapore
- من
- Registered bullion dealer / trader (PSPM registered dealer)
- يتطلب
- Singapore seller's export commercial invoice; Outbound bar list
- يُصدر
- Ordinary (non-preferential) certificate of origin
نص القانون[inferred] that refined bars re-exported from Singapore carry the origin of the refining country follows from Circular 06/2025 (wholly obtained or substantially transformed); no gold-specific ruling was found.
Regulation of Imports and Exports Regulations Part III, regs 23, 24, 24A; Fifth Schedule
- 27
Invoice the foreign buyer as a zero-rated export and keep the export permit and shipping documents as evidence
- من
- Registered bullion dealer / trader (PSPM registered dealer)
- يُصدر
- Singapore seller's export commercial invoice
نص القانونGST Act 1993 s.21(1)-(2); IRAS IPM e-Tax Guide para 5.2
- 28
Collect the bars from the vault, lodge them at Changi and fly them out under the AWB
- من
- Secure logistics carrier
- يتطلب
- TradeNet export (Out) permit
- يُصدر
- Outbound air waybill
إرشاد رسمي
الضرائب والرسوم
Customs duty on gold
None All gold (HS 7108 etc.); only liquor, tobacco, motor vehicles and petroleum products are dutiable
إرشاد رسميالمبلغ غير مؤكدImport GST suspension under ARCS
Suspended Materials imported by Approved Refiners/Consolidators for refining into IPM; supplies between ARCS persons (except refining services)
نص القانونGST (General) Regulations, reg 46A(8), (12)
GST on exports of gold
0% (zero-rated) Export of IPM and non-IPM gold with export documentation
نص القانونالمبلغ غير مؤكدGST Act 1993, s.21(1)-(2)
Import GST - IPM exemption
Exempt Gold bars, ingots, wafers of 99.5%+ from current/former LBMA GD refiners (or ESG-endorsed), with hallmark; prescribed coins; not decorative/collector bars
نص القانونالمبلغ غير مؤكدGST Act 1993, s.8(4), s.22(1A); Fourth Schedule Part 2 paras 1(a), 1A; Part 3 para 2
GST on non-IPM gold
9% Import and supply of doré, scrap, jewellery, non-qualifying bars (e.g. from non-LBMA refiners, decorative)
نص القانونالمبلغ غير مؤكدGST Act 1993, s.16(cb)
GST on non-IPM gold (2023 rate)
8% Import and supply of doré, scrap, jewellery, non-qualifying bars
نص القانونالمبلغ غير مؤكدGST Act 1993, s.16(ca)
GST on refining services
9% local; zero-rated to overseas customers Refining/toll-refining fees
إرشاد رسميالمبلغ غير مؤكدGST on local supply of IPM
Exempt Sale of qualifying IPM in Singapore
نص القانونالمبلغ غير مؤكدGST Act 1993, s.22(1); Fourth Schedule Part 1 para 1A
Regulated dealer registration fees
S$120 application fee (not on renewal since 10 Apr 2021); S$250 (Class A) or S$350 (Class B) per year per place of business
نص القانونالمبلغ غير مؤكدPMLTFPF Regulations 2019, regs 17-18
الضوابط
Cash transaction report on Form NP 784 to a Suspicious Transaction Reporting Officer for every designated transaction, not later than 15 business days after the date the transaction is entered into; a copy goes to the Registrar at the time of submission or immediately after (e-filing through SONAR f…
Cash or cash equivalent exceeding S$20,000 (payments in gold other than jewellery, or in digital payment tokens, are prescribed circumstances for CDD, not designated transactions, and need no CTR)
نص القانونPSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.17(1)
“A regulated dealer who enters into any designated transaction must submit to a Suspicious Transaction Reporting Officer, within the prescribed time, a cash transaction report relating to that transaction in the prescribed form and manner.”
PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.17(1A)
“A regulated dealer must not, without reasonable excuse, submit a cash transaction report under subsection (1) that is incomplete or inaccurate.”
PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.17(2)
“A regulated dealer must keep a copy of each cash transaction report submitted under subsection (1) for the prescribed period.”
PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.17(3)
“A regulated dealer must, at the time of submitting a cash transaction report under subsection (1) or immediately thereafter, submit a copy of the cash transaction report to the Registrar.”
PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.17(4)
“A regulated dealer who fails to comply with subsection (1), (1A), (2) or (3) shall be guilty of an offence and shall be liable on conviction to a fine not exceeding $20,000 or to imprisonment for a term not exceeding 2 years or to both.”
PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.15 "designated transaction" (a)
“a sale of any precious stone, precious metal, precious product or asset-backed token by a regulated dealer to a customer, for which cash or a cash equivalent exceeding the threshold amount is received as payment;”
PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.15 "threshold amount"
“"threshold amount" means $20,000 or its equivalent in value, or an amount prescribed in substitution.”
PSPM Act; PMLTFPF Regulations (sections in refs), PMLTFPF Regulations reg 4A(1)(a): gold payment is a prescribed circumstance for CDD (s.16(1)(d)), not a designated transaction
“for which gold (except in the form of jewellery) the value of which exceeds the threshold amount is received as payment;”
PSPM Act; PMLTFPF Regulations (sections in refs), reg 4A(1)(c)
“for which digital payment tokens the value of which exceeds the threshold amount are received as payment;”
PSPM Act; PMLTFPF Regulations (sections in refs), PMLTFPF Regulations reg 12(1)(a)
“the prescribed form for a cash transaction report is Form NP 784 as set out at the website at https://www.police.gov.sg; and”
PSPM Act; PMLTFPF Regulations (sections in refs), reg 12(1)(b)
“the prescribed time for the submission of a cash transaction report is not later than 15 business days after the date on which the designated transaction is entered into.”
PSPM Act; PMLTFPF Regulations (sections in refs), reg 12(2)
“For the purposes of section 17(2) of the Act, the period for which a copy of a cash transaction report must be kept is 5 years after the date of submission of the cash transaction report.”
PSPM Act; PMLTFPF Regulations (sections in refs), STRO Cash Transaction Reporting page
“When you e-file through SONAR, your CTR will automatically be forwarded to ACD on your behalf.”
PSPM Act; PMLTFPF Regulations (sections in refs), ACD Compliance Toolkit, footnote 6 (conflicting definition)
“The dealer sells or barters a precious stone, precious metal, precious product or asset-backed token and receives payment in cash or cash equivalent or gold (except in the form of jewellery) or digital payment tokens, where the value exceeds S$20,000 in total value.”
Enhanced CDD (senior-management approval, income, source of wealth and funds, enhanced monitoring) where the customer, principal or beneficial owner is a PEP or family/associate, resides in or originates from a FATF call-for-action jurisdiction (DPRK, Iran countermeasures; Myanmar enhanced due dilig…
نص القانونPMLTFPF Regulations 2019, reg 7(2)(a)(ii), (3), (4)
IPM imports need an In-Non-Payment (GST relief) permit: air freight above S$400 CIF (non-controlled air imports up to S$400 need no permit, RIER reg 3(2A)), all sea and land freight, all commercial hand-carry, and personal hand-carry above 0.5 kg; parcel post needs no permit (reg 3(2)(b)).
S$400 CIF (air); 0.5 kg (personal hand-carry)
إرشاد رسميالمبلغ غير مؤكدRegulation of Imports and Exports Regulations, reg 3(1), (2)(b), (2A)
Code of Practice issued by the Registrar of Regulated Dealers under the PSPM Act codes-of-practice power (issued 2 April 2026): dealers apply the A.C.T. framework (Add immediate intervention, Check the customer's behaviour against anti-scam information, Tell the customer to call the ScamShield Helpl…
S$20,000
إرشاد رسميPSPM Act, codes of practice power (section in refs), CoP para 1.1
“This Code of Practice ("CoP") is issued by the Registrar of Regulated Dealers under section 35(1) of the Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act 2019 ("PSPM Act").”
PSPM Act, codes of practice power (section in refs), CoP para 5.1
“PSMDs should apply the A.C.T. framework at paragraph 5.2 when encountering customers making purchases under the following circumstances, regardless of payment mode:”
PSPM Act, codes of practice power (section in refs), CoP para 5.1(a)
“Single transaction of more than S$20,000; or”
PSPM Act, codes of practice power (section in refs), CoP para 5.1(b)
“Multiple transactions below S$20,000 that collectively exceed S$20,000, whether conducted on the same day or over a few days.”
PSPM Act, codes of practice power (section in refs), CoP Annex B-2 item 7 (A.C.T.)
“A - Add immediate intervention by asking the customer for reasons behind the purchase.”
PSPM Act, codes of practice power (section in refs), CoP para 5.2 (C)
“Check for the customer's”
PSPM Act, codes of practice power (section in refs), CoP para 5.2 (T): call the ScamShield Helpline
“Tell the customer that”
PSPM Act, codes of practice power (section in refs), CoP para 5.3(a)
“Conduct enhanced customer due diligence in accordance with the Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Regulations 2019;”
PSPM Act, codes of practice power (section in refs), CoP para 5.3(e)
“Escalate the matter to the supervisor or senior management and document the customer's behaviour and the basis for proceeding with the transaction;”
PSPM Act, codes of practice power (section in refs), CoP para 5.3(f)
“Call the police at 999 if the customer chooses to proceed with the purchase despite repeated warnings that red flags are present; and”
PSPM Act, codes of practice power (section in refs), CoP para 5.3(g)
“File a Suspicious Transaction Report ("STR").”
PSPM Act, codes of practice power (section in refs), CoP para 5.4
“For online sales, in-person collection should be required for purchases above S$20,000.”
PSPM Act, codes of practice power (section in refs), ACD News: issuance of the CoP
“2 April 2026 ## Issuance of Code of Practice on AML Measures for PSMDs to Combat Scam Related Money Laundering Cases”
PSPM Act, codes of practice power (section in refs), PSPM Act s.35(5)
“Any code of practice, guideline or standard of performance has no legislative effect.”
PSPM Act, codes of practice power (section in refs), PSPM Act s.35(6)
“Any failure by a regulated dealer to comply with any code of practice, guideline or standard of performance applicable to the regulated dealer does not of itself render the regulated dealer liable to criminal proceedings, but the failure may, in any proceedings (criminal or otherwise), be relied on by any party to those proceedings as tending to establish or negate any liability which is in question in those proceedings.”
PSPM Act, codes of practice power (section in refs), PSPM Act s.35(1)
“The Registrar may issue, approve, amend or revoke one or more codes of practice, guidelines or standards of performance for all or any of the following purposes:”
STR to a Suspicious Transaction Reporting Officer as soon as reasonably practicable on knowledge or reasonable grounds to suspect (CDSA), or the TSOFA disclosure where it applies, with a copy to the Registrar at the time of disclosure or immediately after (PSPM Act); records of every designated tran…
نص القانونCDSA; PSPM Act; PMLTFPF Regulations (sections in refs), CDSA s.45(1) (parsed into section a1-s-42 of this record)
“Where a person knows or has reasonable grounds to suspect that any property -”
CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), CDSA s.45(1)
“the person must disclose the knowledge or suspicion or the information or other matter on which that knowledge or suspicion is based to a Suspicious Transaction Reporting Officer as soon as is reasonably practicable after it comes to the person's attention.”
CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.21(1)
“A regulated dealer must, if circumstances exist that require the regulated dealer to do so, make a disclosure under whichever of the following is applicable:”
CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.21(2)
“A regulated dealer must, at the time of disclosing a matter under subsection (1) or immediately thereafter, submit a copy of the information so disclosed to the Registrar.”
CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.18(1)(a)
“a record of every designated transaction (whether or not completed) and every other transaction for which the customer due diligence measures mentioned in section 16 must be performed, containing the prescribed information on that transaction;”
CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.18(1)(b)
“a record of all information relating to a customer which is obtained through the customer due diligence measures performed under section 16;”
CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.18(1)(c)
“a copy of each supporting document relied on in support of any information referred to in paragraph (b);”
CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.19(1)
“A regulated dealer must, in relation to the regulated dealer's business of regulated dealing or business as an intermediary for regulated dealing, implement adequate programmes and measures to prevent money laundering, terrorism financing and the financing of proliferation of weapons of mass destruction.”
CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PMLTFPF Regulations reg 13(1)
“For the purposes of section 18(1) or (1A) of the Act, the period for which the documents and information in that section must be kept is 5 years after whichever of the following dates is applicable:”
CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 13(3)(f)
“a record of the following information for each period of 6 months beginning on 1 January or 1 July of any year:”
CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 13(5)
“the prescribed manner of making any record kept under paragraph (3)(f) available to the Registrar is by submitting the record to the Registrar through the electronic system of the Ministry of Law at https://acd.mlaw.gov.sg.”
CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 14(1)(b)(i)
“document the risk assessments;”
CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 14(1)(c)
“develop and implement internal policies, procedures and controls, which must be approved by its senior management, to manage and effectively mitigate the risks of money laundering, terrorism financing and proliferation financing identified by it or notified to it by the Registrar, including -”
CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 14(1)(c)(i)
“making appropriate compliance management arrangements, including the appointment of a compliance officer; and”
CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 14(1)(c)(ii)
“applying adequate screening procedures when hiring employees;”
CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 14(1)(e)
“have an ongoing programme to train employees on the internal policies, procedures and controls in sub-paragraph (c); and”
CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 14(2)
“A regulated dealer that carries out one or more designated transactions must, in addition to the matters mentioned in paragraph (1), have an independent audit function to test the internal policies, procedures and controls in paragraph (1)(c).”
CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), Guidelines v5.1 para 12.2.1
“is required to submit an STR to STRO as soon as reasonably practicable upon the establishment of suspicion (i.e. no longer than 5 business days).”
Before dealing, dealers must assess whether the customer, principal or beneficial owner is a terrorist or terrorist entity (TSOFA), a designated person under UN Act regulations, or a Registrar-notified person; if suspected they must decline or terminate the transaction, report to the police and copy…
نص القانونPMLTFPF Regulations 2019 reg 16; TSOFA s.8
CDD before any designated transaction (sale for cash or cash equivalent above S$20,000, single or same-day aggregate; purchase by a secondhand-goods dealer from a non-dealer for cash above S$20,000; token redemptions for cash above S$20,000), on suspicion of ML/TF/PF, or on doubts about earlier CDD;…
S$20,000
نص القانونPSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.16(1)(a)
“before entering into a designated transaction;”
PSPM Act; PMLTFPF Regulations (sections in refs), s.16(1)(b)
“where the regulated dealer has reason to suspect money laundering, terrorism financing or the financing of proliferation of weapons of mass destruction;”
PSPM Act; PMLTFPF Regulations (sections in refs), s.16(1)(c)
“where the regulated dealer has reason to doubt the veracity or adequacy of information obtained from earlier customer due diligence measures;”
PSPM Act; PMLTFPF Regulations (sections in refs), s.16(1)(d)
“under circumstances prescribed for the purposes of this section.”
PSPM Act; PMLTFPF Regulations (sections in refs), s.16(5)(a)
“decline to enter into any transaction with the customer;”
PSPM Act; PMLTFPF Regulations (sections in refs), s.16(5)(b)
“terminate any transaction entered into with the customer;”
PSPM Act; PMLTFPF Regulations (sections in refs), s.16(5)(c)
“determine whether to make a disclosure under section 45 of the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 or section 8 or 10 of the Terrorism (Suppression of Financing) Act 2002;”
PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.15 "designated transaction" (a)
“a sale of any precious stone, precious metal, precious product or asset-backed token by a regulated dealer to a customer, for which cash or a cash equivalent exceeding the threshold amount is received as payment;”
PSPM Act; PMLTFPF Regulations (sections in refs), s.15 (b)
“2 or more sales of any precious stone, precious metal, precious product or asset-backed token in a single day by a regulated dealer to the same customer, or to customers whom the regulated dealer knows act on behalf of the same person, for which cash or a cash equivalent in total exceeding the threshold amount is received as payment;”
PSPM Act; PMLTFPF Regulations (sections in refs), s.15 (c)
“a purchase of any precious stone, precious metal or precious product from a customer (who is not a regulated dealer) by a regulated dealer (who is a secondhand goods dealer), for which cash or a cash equivalent exceeding the threshold amount is received as payment;”
PSPM Act; PMLTFPF Regulations (sections in refs), s.15 "threshold amount"
“"threshold amount" means $20,000 or its equivalent in value, or an amount prescribed in substitution.”
PSPM Act; PMLTFPF Regulations (sections in refs), PMLTFPF Regulations reg 4(1)(a)
“a redemption of an asset-backed token from a customer (who is not a regulated dealer) by a regulated dealer, for cash or a cash equivalent exceeding the threshold amount;”
PSPM Act; PMLTFPF Regulations (sections in refs), reg 4(1)(c)
“2 or more redemptions of any asset-backed token in a single day by a regulated dealer from the same customer”
PSPM Act; PMLTFPF Regulations (sections in refs), reg 4A(1)
“For the purpose of section 16(1)(d) of the Act, each of the following circumstances are circumstances in which a regulated dealer must perform the prescribed customer due diligence measures in regulations 5 and 6”
PSPM Act; PMLTFPF Regulations (sections in refs), reg 4A(1)(a)
“for which gold (except in the form of jewellery) the value of which exceeds the threshold amount is received as payment;”
PSPM Act; PMLTFPF Regulations (sections in refs), reg 4A(1)(c)
“for which digital payment tokens the value of which exceeds the threshold amount are received as payment;”
PSPM Act; PMLTFPF Regulations (sections in refs), reg 5(1)
“the customer due diligence measures to be performed by a regulated dealer before entering into any designated transaction with a customer who is an individual are all of the following:”
PSPM Act; PMLTFPF Regulations (sections in refs), reg 6(1)
“the customer due diligence measures to be performed by a regulated dealer before entering into any designated transaction with a customer who is an entity or a legal arrangement are all of the following:”
Anyone moving physical currency or bearer negotiable instruments above the prescribed amount (S$20,000, CMR Regulations reg 2A) into or out of Singapore must report it: travellers on Form NP 727 within 72 hours before immigration clearance; senders and commercial carriers of cash by post or courier …
S$20,000
نص القانونالمبلغ غير مؤكدCDSA 1992 Part 6A; CDSA (Cross Border Movements of Physical Currency and Bearer Negotiable Instruments) Regulations 2007, CDSA ss.59-62; regs 2A, 3, 4, 4A, 5
Anyone carrying on a business of manufacturing, importing or possessing for sale, selling or offering for sale, or buying for resale any precious metal (gold, silver, platinum group metals, and alloys with at least 2% in weight of them, in manufactured or unmanufactured state), precious stone or pre…
No value floor for bullion; unregistered dealing: fine up to S$75,000 or imprisonment up to 3 years or both, plus up to S$7,500 for every day of a continuing offence
نص القانونPSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), PSPM Act s.6(1)
“A person must not act as or hold out to be a regulated dealer unless the person is a registered dealer.”
PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), PSPM Act s.6(2)
“A person who contravenes subsection (1) shall be guilty of an offence and shall be liable on conviction to a fine not exceeding $75,000 or to imprisonment for a term not exceeding 3 years or to both and, in the case of a continuing offence, to a further fine not exceeding $7,500 for every day or part of a day during which the offence continues after conviction.”
PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), s.2 "regulated dealing" (a)
“manufacturing any precious stone, precious metal or precious product;”
PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), (b)
“importing or possessing for sale any precious stone, precious metal or precious product;”
PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), (c)
“selling or offering for sale any precious stone, precious metal or precious product;”
PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), (d)
“selling or redeeming asset-backed tokens;”
PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), (e)
“purchasing any precious stone, precious metal or precious product for the purposes of resale;”
PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), s.2 "regulated dealer" (b)
“business as an intermediary for regulated dealing, but excludes a pawnbroker and any other person as may be prescribed;”
PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), s.2 "precious metal"
“"precious metal" means any precious metal specified in Part 1 of the Schedule in a manufactured or unmanufactured state;”
PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), the Schedule Part 1 item 9 (items 1-8: gold, silver, platinum, iridium, osmium, palladium, rhodium, ruthenium)
“An alloy with at least 2% in weight of any substance mentioned in items 1 to 8”
PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), ACD Regulatory Regime page
“"Precious metals" include gold, silver, platinum, iridium, osmium, palladium, rhodium, ruthenium, and alloys with at least 2% in weight of any of the metals stated above.”
PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), Exempt Persons Order para 3
“Every financial institution that carries on a business of regulated dealing, or business as an intermediary for regulated dealing, in Singapore is exempt from -”
PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), Order para 4(1)
“A foreign dealer carrying on a business of regulated dealing, or business as an intermediary for regulated dealing, in Singapore on a transitory basis, is exempt from -”
PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), Order para 4(2)
“A foreign dealer carries on business in Singapore on a transitory basis if the foreign dealer carries on business in Singapore for not more than a total of 90 days in a year.”
PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), PSPM Act Legislative History item 1
“Commencement : 10 April 2019”
Gold may not be imported, transhipped or brought in transit from the DPRK (Seventh Schedule, prohibited imports item (9)), nor exported, transhipped or brought in transit to the DPRK (luxury items, prohibited exports item (5)(k) "gold, silver and platinum"); any goods for trade with a person in the …
نص القانونRegulation of Imports and Exports Regulations, regs 5A, 6(1)(b), 6(2)(c); Seventh Schedule item 2 (DPRK)
GST-exempt status depends on the bar: gold of at least 99.5% purity in bar, ingot or wafer form, refined by a refiner who is or was on the LBMA Good Delivery list (or an Enterprise Singapore-endorsed intending refiner — none endorsed on 28 Sep 2026), bearing a mark internationally accepted as guar…
نص القانونGST Act 1993, Fourth Schedule, Part 2 paras 1(a), 1A; Part 3 para 2
No Singapore statute requires importers, dealers or refiners to verify mine origin or apply OECD/CAHRA due diligence: the PSPM Act and Regulations impose customer (not supplier-origin) due diligence, the GST investment-precious-metal exemption turns on form, purity, a refiner on the LBMA Good Delive…
نص القانونPSPM Act s.2 "customer"
“"customer" means a person with whom a regulated dealer enters into or intends to enter into a transaction;”
PSPM Act s.16(1): CDD is on the customer
“a regulated dealer must perform the prescribed customer due diligence measures in any of the following circumstances:”
PMLTFPF Regulations reg 5(1)
“the customer due diligence measures to be performed by a regulated dealer before entering into any designated transaction with a customer who is an individual are all of the following:”
reg 6(1)
“the customer due diligence measures to be performed by a regulated dealer before entering into any designated transaction with a customer who is an entity or a legal arrangement are all of the following:”
GST Act Fourth Schedule Part 2 para 1(a)(i) (parsed into section sch-3 of this record)
“is in the form of a bar, an ingot or a wafer;”
para 1(a)(ii)
“is of a purity of at least 99.5%; and”
Fourth Schedule Part 2 para 2(a)(i)
“in the case of gold or silver, a refiner who is or was in the "Good Delivery" list of the London Bullion Market Association;”
para 2(b)
“it bears a mark or characteristic that is internationally accepted as guaranteeing its quality.”
Singapore Customs IPM page, permit field "Supplier name"
“Name of refiner who produced the bar/wafer/ingot”
Guidelines v5.1 Annex D, red flag indicators
“Supplier/ introducer is evasive when being asked about the source of its gold supply.”
Singapore's Russia measures ban the export, transhipment and transit to Russia of military goods and of dual-use goods in Categories 3 (electronics), 4 (computers) and 5 (telecommunications and information security) of the Strategic Goods (Control) Order 2021 as in force on 16 Mar 2022 (RIER reg 6(2…
نص القانونRegulation of Imports and Exports Regulations, reg 6(2B); Eighth Schedule
Goods to or from UNSC-sanctioned countries need a TradeNet permit applied for at least 3 working days before shipment. Iran lists cover nuclear, arms and S/2015/546 items, not gold.
إرشاد رسميRegulation of Imports and Exports Regulations, regs 5A, 6(1)(b), 6(2)(c)
Zero-GST warehouse licensees may store "listed goods" (incl. HS 7108 gold, silver, platinum and precious stones) only with Singapore Customs' written approval, at least a Type II licence, and records of the persons controlling and beneficially owning the goods, screened and kept up to date (since 1 …
إرشاد رسمي
المرحلة 3: الإمارات العربية المتحدة
حيث تصل البضاعة
- 29
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
إرشاد رسمي[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)
- 30
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)
إرشاد رسميNo 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)
- 31
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)
نص القانونInvestment 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)
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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
نص القانون[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)
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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)
إرشاد رسميDMCC: 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.
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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
مصدر ثانوي[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
الضرائب والرسوم
Customs duty on gold imports
0% for goods entering a free zone (FZ Transit In); mainland imports of gold: 0% under the GCC exempted-commodities list (read via WebFetch only) Unwrought and semi-manufactured gold
إرشاد رسميالمبلغ غير مؤكدDubai Customs Customer Guide v3.03; GCC common customs law; UAE list of exempted commodities, Customer Guide s.9 (duty suspended for goods admitted into free zones), s.15.12.2
Domestic reverse charge on precious metals and precious stones between registered businesses
Recipient accounts for VAT Supplies of gold, silver, platinum, palladium, precious stones and jewellery made of them, for resale or production, between VAT-registered persons, with the buyer's written declaration (CD 127/2024, replacing CD 25/2018)
نص القانونCabinet Decision 127/2024; FTA VATP043, Art. 1 (Goods: precious metals - gold, silver, palladium, platinum - precious stones and jewellery mostly of them), Art. 2(1)-(4), Art. 4 (repeals CD 25/2018)
“Precious Metals, Precious Stones and jewelry made of any Precious Metals or Precious Stones”
Special reverse charge on gold and diamonds between registrants (Cabinet Decision 25/2018)
Registered recipient accounts for VAT Gold and products mostly of gold not qualifying for zero-rating, and diamonds, supplied between registrants; exports of gold items and investment precious metals outside its scope (VATP029)
إرشاد رسميCabinet Decision No. 25 of 2018
Import VAT
5% standard; 0% for investment precious metals (99%+ purity, tradeable form) Doré is not investment gold, so it is standard-rated; refined bars of 99%+ are zero-rated
نص القانونالمبلغ غير مؤكدFederal Decree-Law 8/2017 on VAT; Executive Regulation, Art. 3 (5%), 45(8), 48(1), 49; Exec. Reg. Art. 36(2), 48, 50(1)
“a standard rate of 5% Tax shall be imposed on any supply or Import”
الضوابط
Precious metals crossing the UAE border must be disclosed; declarations are also required for precious metals over AED 60,000 crossing through cargo, mail or shipments, cargo being declared through the official customs systems.
AED 60,000
نص القانونالمبلغ غير مؤكدFederal Decree-Law 10/2025; CBUAE Regulation on the Declaration of Currencies, BNIs, and Precious Metals and Stones (OG 703, 31 May 2021), FDL 10/2025 Art. 10 (duty to disclose, per the disclosure system issued by the ICP with the Central Bank), Art. 41(3) (regulations under FDL 20/2018 remain effective insofar as not conflicting), Art. 34 (penalty)
“Any person entering into or departing from the State shall be under the obligation to make a disclosure whenever they carry currencies, bearer negotiable instruments, precious metals, or valuable stones, in accordance with the disclosure system issued by the Federal Authority for Identity, Citizenship, Customs and Port Security, in coordination with the Central Bank”
Dealers in precious metals and stones are DNFBPs for any single cash transaction, or linked transactions, of AED 55,000 or more (CR 134/2025 Art. 3 item 3), and keep records for at least 5 years (Art. 25). The DPMSR report, including for dealings with companies of AED 55,000 or more paid in cash or …
AED 55,000
نص القانونCabinet Resolution 134/2025; MoET Supplemental Guidance for DPMS 2026, CR 134 Art. 3(3), Art. 25(1); Guidance s.1.4.1
“when carrying out any single cash transaction or several transactions that appear to be linked and whose value equals or exceeds fifty-five thousand dirhams (AED 55,000)”
Supply-chain entities and precious-metals dealers must have due-diligence management systems, identify and assess supply-chain risks and adopt a risk-management strategy (Decree Art. 1(A)); refiners must also appoint an independent third-party auditor and submit a due-diligence report (Art. 1(B)), u…
نص القانونMinisterial Decree 68/2024; MoE Due Diligence Regulations v1 (2022), Decree Art. 1(A), 1(B), Art. 3 (penalties under the AML law)
المرحلة 4: السودان
العودة إلى بلد المنشأ: عائدات التصدير
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Receive proceeds into the exporter's gold export account (L/C: on acceptance of documents, at most 30 days from shipment); balances older than 21 working days are bought for CBOS
- من
- Commercial bank (authorised FX dealer)
- يُصدر
- Export proceeds repatriation record (bank)
إرشاد رسميCBOS Circular 17/2025, ثالثاً-2, ثالثاً-3
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Use the proceeds for the holder's imports (any goods MoIT allows, via an import account, 21 working days) or sell them to the exporter's bank, another bank or CBOS
- من
- Gold exporter (Sudanese legal person)
إرشاد رسميCBOS Circulars 11/2026 and 12/2026, 11/2026 item 1; 12/2026 items 1, 3
العبور بين الدول
السودان → سنغافورة غير مدروس
المستندات العابرة: Ministry of Minerals export-approval certificate; SSMO certificate / weight and assay documents (and hallmark); CBOS gold export approval (prior written approval / export certificate); Customs export declaration
سنغافورة → الإمارات العربية المتحدة غير مدروس
المستندات العابرة: Inbound air waybill; Foreign supplier's commercial invoice; Packing list; Bar list from the foreign supplier (serials, weights, fineness, refiner); TradeNet In-Non-Payment (GST Relief) permit for IPM (declaration type GTR, place of receipt IGPM); Refinery weigh-in record; Refiner outturn statement (weigh-in, assay, fine gold credited); Singapore refiner's bar list / product certificate (serial, fine weight, fineness, hallmark); TradeNet permit for goods to/from a UNSC-sanctioned country; TradeNet export (Out) permit; Ordinary (non-preferential) certificate of origin; Outbound air waybill
ثغرات المستندات
sg.st-02 expects Refiner's certificate for the bars it produced (serials, fineness, weights, year); the earlier legs don't model this paper