Australia (refine) → Hong Kong (China SAR) · Sale on HKGX or OTC, with payment and AML duties

Enrol with AUSTRAC within 28 days of starting a designated service and adopt an AML/CTF program (bullion dealing; from 31 Mar 2026 also buying or selling precious metal for $10,000 or more in physical currency or virtual assets, with obligations from 1 Jul 2026)

من

Bullion dealer / dealer in precious metal

يُصدر

AUSTRAC enrolment; AML/CTF program

• AML/CTF Act 2006, s.6(3) table 2 items 1-2; ss.26B, 51B

  “buying or selling one or more of the following items in the course of carrying on a business, where the purchase involves the transfer of physical currency or virtual assets (or a combination of physical currency and virtual assets) with a total value of not less than $10,000, whether the purchase is made in a single transaction or in several transactions that are linked or appear to be linked: (a) precious metal; (b) precious stones; (c) precious products”

Carry out customer due diligence before providing the designated service; enhanced due diligence in higher-risk cases

من

Bullion dealer / dealer in precious metal

يتطلب

AUSTRAC enrolment

يُصدر

Customer due diligence file

• AML/CTF Act 2006, s.28 (initial CDD); s.39E item 11 (bullion under $5,000)

  “A reporting entity must not commence to provide a designated service to a customer if the reporting entity has not established on reasonable grounds each of the matters in subsection (2)”

Sell or buy bars: input-taxed supply of precious metal (no GST charged, no input credits), or GST-free if it is the refiner's first supply after refining to a dealer

من

Bullion dealer / dealer in precious metal

يتطلب

Customer due diligence file

يُصدر

Commercial invoice (GST-free / input-taxed treatment stated)

• A New Tax System (Goods and Services Tax) Act 1999, s.40-100; s.38-385

Report each threshold transaction (transfer of $10,000 or more in physical currency) to AUSTRAC within 10 business days

من

Bullion dealer / dealer in precious metal

يُصدر

Threshold transaction report

• AML/CTF Act 2006, s.43; s.5 threshold transaction

Report suspicious matters to AUSTRAC (within 3 business days, or 24 hours for terrorism financing suspicions)

من

Bullion dealer / dealer in precious metal

يُصدر

Suspicious matter report

• AML/CTF Act 2006, s.41

Hold a granted mining lease (or state equivalent) with approvals to mine

من

Mining tenement holder (mining lease) operating a gold mine and mill

يتطلب

Mining lease

[not-read] Mining proposal and closure plan approvals not read.

• Mining Act 1978 (WA), ss.71, 78, 85

Mine ore, process (CIL/gravity), and pour doré bars at the mine site; mark each bar

من

Mining tenement holder (mining lease) operating a gold mine and mill

يُصدر

Mine doré bar number and mine mark

الشكل

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

Mine-site processing described only generally.

Collect doré under secure transport and deliver to the refinery

من

Secure precious-metals carrier / airline

يتطلب

Refining (toll) agreement between miner and refiner

Receive, weigh and sample the doré; issue receipt. For WA royalty, gold metal is taken to be produced on delivery to the refinery if delivered within 3 months of the gold-bearing material being obtained; otherwise on the day after the 3-month period

من

Australian gold refiner (LBMA Good Delivery-listed)

يُصدر

Refinery receipt and weigh-in of doré

• Mining (Royalties) Regulations 2025 (WA), rr. 29, 31-32

Assay the doré and issue the outturn statement; credit the miner's metal account with fine gold (or buy the gold outright)

من

Australian gold refiner (LBMA Good Delivery-listed)

يتطلب

Refinery receipt and weigh-in of doré

يُصدر

Outturn / assay statement; Metal account statement

First sale of refined gold: GST-free where it is the first supply after refining by or on behalf of the supplier, by a refiner of precious metal, to a dealer in precious metal; otherwise the supply of precious metal is input taxed

من

Mining tenement holder (mining lease) operating a gold mine and mill

يتطلب

Metal account statement

يُصدر

Commercial invoice (GST-free / input-taxed treatment stated)

[conflict] au.div-gst-scrap (refining from scrap).

• A New Tax System (Goods and Services Tax) Act 1999, s.38-385; s.40-100; s.195-1

Refine doré to 999.9 kilobars/minted bars or 995+ Good Delivery bars; cast, mark (refiner mark, serial, fineness) and record

من

Australian gold refiner (LBMA Good Delivery-listed)

يتطلب

Outturn / assay statement

يُصدر

Bar list for refined bars

الشكل

Doré bar - unstamped → 999.9 kilobar

Maintain LBMA Good Delivery and RGG compliance; publish the annual RGG compliance report with independent assurance

من

Australian gold refiner (LBMA Good Delivery-listed)

يُصدر

Refiner RGG report and assurance

Report suspicious matters to AUSTRAC (refiner bullion business is a reporting entity)

من

Australian gold refiner (LBMA Good Delivery-listed)

يُصدر

Suspicious matter report

[inferred] The refiner is a reporting entity because it buys and sells bullion in a bullion-dealing business (s.6 table 2 item 1); the Perth Mint enforceable undertaking confirms it for that refiner.

• AML/CTF Act 2006, s.6(3) table 2 item 1; s.41

Prepare commercial invoice and bar list; no export permit or licence is required for gold

من

Exporter of bars (refiner, dealer or miner selling offshore)

يتطلب

Bar list for refined bars

يُصدر

Commercial invoice (GST-free / input-taxed treatment stated)

[inferred] Absence of a gold export permit read from the Regulations as a whole; commercial invoice and bar list are commercial practice.

• Customs (Prohibited Exports) Regulations 1958 (no gold item)

Lodge the export declaration in the Integrated Cargo System (required for consignments above $2,000 FOB) and obtain the export entry advice (authority to deal) with its number before loading; a declaration may be refused if the intended export day is more than 6 months ahead; if not exported within 30 days of the intended day, withdraw or amend within 7 days; keep commercial documents 5 years

من

Licensed customs broker

يتطلب

Commercial invoice (GST-free / input-taxed treatment stated)

يُصدر

Export declaration and export entry advice (authority to deal, with export entry advice number)

• Customs Act 1901, ss.113, 114, 114C, 116, 240(1A); Customs Regulation 2015 r. 82

  “an FOB value not exceeding $2,000 or such other amount as is prescribed”

Obtain a certificate of origin only if the buyer or the destination requires one (e.g. to claim an FTA preference); an exporter claiming Australian origin for a preferential tariff in China, Hong Kong or the UK may be required by the ABF to produce origin records and answer questions for verification by the importing customs

من

Exporter of bars (refiner, dealer or miner selling offshore)

يُصدر

Certificate of origin (on request)

[not-read] Issuing bodies and forms for certificates of origin not researched (au.gap-cert-origin); no Australian export rule requires one for gold.

• Customs Act 1901, Divisions 4J, 4K, 4M (ss.126AOA-126AOD, 126APA-126APD, 126ARA-126ARD)

Ship by secure air freight under air waybill

من

Secure precious-metals carrier / airline

يتطلب

Export declaration and export entry advice (authority to deal, with export entry advice number)

يُصدر

Air waybill

Carrier practice not documented in the sources read.

Onboard the supplier: KYC and source-of-supply review. Hong Kong law makes CDD mandatory for a Category B registrant only for specified cash transactions (AMLO s.5A(5A)); for bank-paid purchases the pack is the importer's own risk choice, with LBMA/OECD guidance applying where the buyer or refiner is bound by it

من

Registered bullion dealer / trader (DPMS registrant)

يتطلب

DPMS Category A registration certificate; Commercial invoice

يُصدر

Supplier KYC pack held by the Hong Kong importer; Customer due diligence file (Category B, specified cash transaction); Supplier's commercial invoice

[inferred] No Hong Kong rule found that requires origin documents for imported gold; the KYC pack is commercial practice outside cash transactions. The legal scope of CDD is read in the Ordinance.

• AMLO s. 5A and Sch. 2 (only for specified cash transactions), s. 5A(5A)-(5B)

  “An AML/CTF requirement that applies to a DNFBP who is a Category B PMS registrant only applies when, by way of business, the registrant carries out, in Hong Kong with a customer, a specified cash transaction that is not an excluded transaction”

Fly the consignment into HKIA and deliver it to the importer's vault. If it is transhipment cargo (consigned on a through bill of lading or through air waybill to a place outside Hong Kong) or transit cargo, no Hong Kong declaration is required and the gold never enters the Hong Kong market

من

Secure logistics carrier / forwarder

يتطلب

Supplier's commercial invoice; Air waybill; Export customs declaration accepted by the dispatching country's customs

يُصدر

Inbound air waybill

• Import and Export (Registration) Regulations (Cap. 60E), reg. 3(a)-(b); Cap. 60 s. 2 (transhipment cargo, article in transit)

Receive the bars, weigh them and check serials against the bar list; credit the importer's allocated account

من

Precious-metals vault operator

يتطلب

Inbound air waybill

يُصدر

Weight and quality verification record; Bar list (serials, weights, fineness); Allocated account weight list

[inferred] Vault intake practice is not documented in an official source; the clearing press release confirms designated vaults record deposits.

Lodge the import declaration within 14 days after the day of importation using the specified system (Trade Single Window, or during the transition a government-appointed service provider). Gold bars of fineness 995.0 or above (HKHS 7108 1210, 7108 2010) go on Form 1B with no declaration charge; other gold pays the charge. No customs duty or VAT; gold is not an exempted article

من

Registered bullion dealer / trader (DPMS registrant)

يتطلب

Inbound air waybill; Supplier's commercial invoice

يُصدر

Hong Kong import declaration (Cap. 60E, lodged electronically within 14 days)

• Import and Export (Registration) Regulations (Cap. 60E), regs 3, 4(1)-(2), 7, 8(1), (1AA), (4), 18

If the gold is paid for with physical currency or BNIs above HK$120,000 carried across the boundary, declare the cash (not the gold) to C&ED: advance CDS declaration for cargo, red channel for arriving travellers

من

Registered bullion dealer / trader (DPMS registrant)

يُصدر

CBNI advance electronic declaration (CDS) for cash moved as cargo

• Cap. 629, ss. 2, 4, 9, 11; Sch. 4

Agree price and terms: loco-London or loco-Hong Kong OTC off the LBMA Gold Price or dealer quotes (the HAU ticker, launched on Bloomberg on 7 July 2026, gives indicative loco-HK bid/offer); or trade on HKGX by open outcry or electronically

من

Registered bullion dealer / trader (DPMS registrant)

يُصدر

Sale and Purchase Agreement (price clause); Price reference (LBMA Gold Price, or HAU ticker quotes for loco Hong Kong); HKGX trade record / transaction code

Before any specified cash transaction (cash of HK$120,000 or more, single or linked) with a customer, a Category B registrant identifies and verifies the customer and beneficial owner, verifies anyone acting for the customer, applies PEP and high-risk measures and keeps records at least 5 years. Only a Category B registrant may carry out such a transaction; cash paid only between two Category B registrants is excluded from CDD

من

Registered bullion dealer / trader (DPMS registrant)

يتطلب

DPMS Category B registration certificate

يُصدر

Customer due diligence file (Category B, specified cash transaction)

• AMLO s. 5A and Sch. 2; C&ED Guideline for Category B registrants, s. 5A(5A)-(5B); s. 53ZUE(2); Sch. 2 ss. 2, 3(1)(b), 10, 15, 20

  “for a period of at least 5 years beginning on the date on which the transaction is completed”

A visiting non-Hong Kong dealer that completes a cash transaction of HK$120,000 or more files a cash transaction report (Form CED418) with C&ED within one day or before leaving, whichever is earlier

من

Non-Hong Kong dealer (visiting)

يُصدر

Cash transaction report by a non-Hong Kong dealer (Form CED418)

• AMLO (Cap. 615) Part 5C, s. 53ZVK; Sch. 3J

Buyer pays by bank transfer (or ledger transfer through central clearing); seller issues the final invoice; title passes by vault transfer or clearing-ledger entry

من

Authorised institution (bank) dealing in bullion

يتطلب

Sale and Purchase Agreement (price clause)

يُصدر

SWIFT MT103 payment confirmation (bank-to-bank, authenticated); Final invoice (against outturn assay); Settlement confirmation / custody account entry; Central clearing ledger entry (unallocated gold balance)

[inferred] Settlement mechanics for bilateral OTC outside central clearing are market practice.

Report any knowledge or suspicion that property is crime proceeds to JFIU through STREAMS 2 (applies to everyone, not only registrants); do not tip off

من

Registered bullion dealer / trader (DPMS registrant)

يُصدر

Suspicious transaction report to JFIU (STREAMS 2)

• OSCO (Cap. 455), DTROP (Cap. 405), UNATMO (Cap. 575), Cap. 455 s. 25A(1), (5), (7); Cap. 405 s. 25A(1); Cap. 575 s. 12(1), (5)

  “Where a person knows or suspects that any property— (a) in whole or in part directly or indirectly represents any person’s proceeds of; (b) was used in connection with; or (c) is intended to be used in connection with, an indictable offence, he shall as soon as it is reasonable for him to do so disclose that knowledge or suspicion … to an authorized officer”

Price the sale against the LBMA Gold Price (commonly in AUD) or a forward/hedge contract

من

Mining tenement holder (mining lease) operating a gold mine and mill

يُصدر

LBMA Gold Price PM (AUD) reference

Commercial pricing practice not documented; the LBMA PM fix is the statutory WA royalty reference.

Transfer metal from the miner's metal account to the buyer, or deliver bars, against payment

من

Australian gold refiner (LBMA Good Delivery-listed)

يُصدر

Payment for gold sold