Nigeria → United States → United Arab Emirates · Reconcile assays and pay the balance

Extract ore within licensed area; process by gravity concentration and, commonly, mercury amalgamation

من

Miner (artisanal/small-scale or licensed company)

الشكل

Ore (in situ / run-of-mine) → Sponge gold

• NMMA, s.90 (area of a Small-scale Mining Lease, rehabilitation of mined-out areas, mining restricted to established zones of mineralisation)

Smelt sponge gold with flux into a button/bar

من

Miner (artisanal/small-scale or licensed company)

يُصدر

Unique reference number on each doré bar or sealed container of alluvial gold

الشكل

Sponge gold → Doré bar - unstamped

[unconfirmed] Smelting with flux is common practice not described in the OECD Supplement on Gold (3rd ed. 2016), whose "Gold sources" definitions say alluvial gold "may be easily melted and/or semi-refined into small ingots (normally of 85% - 92 % purity)" and "can ordinarily be directly refined", and associate doré with medium and large-scale mines.

Pay royalty monthly and file two returns: 15% ad valorem on gold concentrate (Nigeria Tax Act 2025, Eighth Schedule, from 1 Jan 2026), valued at the Ministry of Solid Minerals' official selling price or ruling international prices; monthly production return (Form 17) to the Mines Inspectorate before the 20th, and monthly royalty self-assessment return to the Nigeria Revenue Service by the 21st

من

Miner (artisanal/small-scale or licensed company)

يُصدر

Royalty payment receipt; Monthly return on Form 17 ("Monthly returns on mineable & quarriable minerals", headed "Regulation 112 (a)" in the Cadastre Office copy): licence number, mineral, location, labour and wages (Nigerians / non-Nigerians), quantities won, used, sold and left on hand (tons or m3) with values, State, zone, remarks; certified by the lease manager or responsible person; due on the 20th day of the following month; Monthly royalty self-assessment return to the NRS: licence number, mineral and weight, location and labour, quantity won/sold/used/on hand, buyers, computation, evidence of payment, signed declaration - due by the 21st

[conflict] ng.div-tax-act-versions: two texts of the NTA and NTAA are held. The royalty table (Eighth Schedule, gold concentrate 15%) is the same in both; the gazetted NTAA s.20(1)(b) cites the "Seventh" schedule and the National Assembly text the "Ninth" - neither is the Eighth; printed commencement 26 June 2025 (gazette) vs 1 January 2026 (National Assembly text; the date applied). [inferred] The Eighth Schedule lists only "GOLD CONCENTRATE" (15%) and "ANY OTHER MINERAL" (10%); the OECD Gold Supplement defines concentrate as an intermediate still needing processing "to produce doré", so whether doré or alluvial gold is charged 15% or 10% is interpretive. [time-limited] NMMA s.33 (royalty "as prescribed in the regulations") was deleted by NTA s.197(9) (gazette numbering); Regs Schedule 4 (3%) and the MSMD notice of 4 July 2024 (3% on N1,081,200/oz) applied to 31 Dec 2025. [unconfirmed] no official selling-price list newer than July 2024 found. [ocr] reg 123 checked against gazette page image p.104; Form 17 read from the Cadastre Office page image. [blocked] Rev360 is a login shell, so the return form fields come from NTAA s.20(2).

• Nigeria Tax Act 2025; Nigeria Tax Administration Act 2025; Minerals and Mining Regulations 2011, NTA s.64(3)-(4) and Eighth Schedule paras 1-3, item 25 (gold concentrate 15%); NTAA s.20(1)-(2), s.63, s.123; Regs 99(1)-(2), 123

Customer due diligence on the miner / mining company before buying: identity (incl. NIN), proof of the company's existence, beneficial owners, source of funds; screen and keep records 5 years

من

Mineral Buying Centre (MBC)

يُصدر

Buying centre CDD file on the miner / mining company: identity (incl. NIN), the company's name, legal form and proof of existence, beneficial owners (5%+), source of funds

[inferred] For a company, proof of existence is usually its Corporate Affairs Commission (CAC) documents; the Regulations do not name them.

• MLPPA 2022; EFCC AML/CFT/CPF Regulations for DNFBPs 2024, s.4, s.8, s.30; regs 18(2), 24(3), 40(5)-(6)

Sell gold to a licensed Mineral Buying Centre and obtain a valid sales receipt

من

Miner (artisanal/small-scale or licensed company)

يتطلب

Buying centre CDD file on the miner / mining company: identity (incl. NIN), the company's name, legal form and proof of existence, beneficial owners (5%+), source of funds; Unique reference number on each doré bar or sealed container of alluvial gold

يُصدر

Sales receipt from the Mineral Buying Centre to the miner (NMMA s.95); Bank transfer record for payment to the miner

• NMMA 2007; MLPPA 2022, s.95 (sale to buying centre, valid sales receipts); MLPPA s.2(1) (cash limit)

Log the purchase, recording which mine the mineral came from

من

Mineral Buying Centre (MBC)

يُصدر

MBC purchase/sale record naming mine of origin (NMMA s.96)

[ocr] Regs 133(4)(a) and 232(i) read in the gazette OCR and the Cadastre Office text.

• NMMA 2007; Minerals and Mining Regulations 2011, s.96(2); Regs 133(4)(a), 232(i)

If a single transaction, lodgment or transfer of funds exceeds N5m (individual) / N10m (body corporate): report it to SCUML in writing within 7 days. A cash payment above those sums is itself unlawful unless made through a financial institution

من

Mineral Buying Centre (MBC)

يُصدر

Report to SCUML of any single transaction, lodgment or transfer of funds above N5m (individual) / N10m (body corporate), in writing within 7 days

Conditional step. MLPPA read in full in the gazette text (NFIU copy) 2026-09-28.

• MLPPA 2022, s.11(1) (report to SCUML within 7 days); s.2(1) (cash payment limit)

Negotiate and sign a Sale and Purchase Agreement: price = LBMA AM/PM reference on an agreed pricing date, +/- a premium/discount for location and form

من

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

يُصدر

SPA between exporter and Dubai importer: price = LBMA reference +/- premium/discount, pricing-date mechanism; LBMA AM/PM gold price on the agreed pricing date

• Contract law; LBMA Gold Price administered by ICE Benchmark Administration

Consolidate gold purchased across multiple miners or buying centres, keeping each lot's purchase record and evidence of its source of supply

من

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

يتطلب

MBC purchase/sale record naming mine of origin (NMMA s.96)

يُصدر

Exporter's record verifying weight and quality declared by the producer; Evidence of source of supply (purchase records and receipts tracing each lot to licensed buying centres / titles)

The export permit asks for evidence of source of supply; the royalty evidence it asks for is the export-stage royalty receipt (ng.gold.st-54), not the miner's receipt, which buying centres do not collect.

• reg 131(3)(iv)-(v)

  “Evidence of source of supply; (v) Evidence of the payment of royalties on the minerals to be exported”

Obtain fire-assay of the consolidated lot

من

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

يُصدر

Fire-assay report, National Geosciences Research Laboratory Centre, Kaduna

الشكل

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

Whether this is a hard legal precondition to the export permit, or best-practice feeding it, was not confirmed from primary text

Register/renew as exporter with NEPC

من

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

يُصدر

Certificate of origin; Evidence of NEPC registration

Mines Inspectorate assesses the export-stage royalty (3% ad valorem on gold) on the lot; the exporter pays; the receipt is filed with the Form 22 application as the evidence of the payment of royalties on the minerals to be exported

من

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

يُصدر

Receipt for the royalty assessed on the lot to be exported: the evidence the export permit requires

[unconfirmed] whether the Nigeria Revenue Service collects it from 2026 (ng.gold.gap-export-royalty-2026).

• reg 131(3)(v)

  “Evidence of the payment of royalties on the minerals to be exported”

• reg 131(2)

  “An application for the issuance of permit to export minerals for commercial purpose shall be made to the Mines Inspectorate Department in the prescribed Form 22 in Schedule 3”

• Schedule 4 (gold)

  “4 Gold 3 5 Gypsum 5”

• Schedule 3, Form 22 item 7

  “7. Amount due as Royalty”

Apply to the Mines Inspectorate on Form 22 for a Permit to Export Minerals for Commercial Purpose; issued on Form 23 (fee: N10,000 in Regs Schedule 1 item 18(a); N100,000 in the MSMD fee notice of 4 July 2024)

من

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

يتطلب

Certificate of Incorporation; Three years' Tax Clearance Certificate; Evidence of NEPC registration; Evidence of source of supply (purchase records and receipts tracing each lot to licensed buying centres / titles); SPA between exporter and Dubai importer: price = LBMA reference +/- premium/discount, pricing-date mechanism; Receipt for the royalty assessed on the lot to be exported: the evidence the export permit requires

يُصدر

Form 22 application: applicant; CAC and NEPC registration numbers and dates; address for notices; source of supply (lease no., grant and expiry dates, or possess/purchase permit no.); mineral types and weights; amount due as royalty; buyer's contact details; signed declaration; Revenue Collector's Receipt for the export-permit fee, quoted on the permit's payment schedule (N10,000 under Regs Schedule 1 item 18(a); N100,000 under the MSMD fee notice of 4 July 2024); Permit to Export Minerals for Commercial Purpose (Form 23): permit number, exporter, minerals and quantities, destination, fee receipt (RCR) number; signed by the Director of Mines Inspectorate for the Minister and copied to the Area Controller of Customs

[ocr] reg 131 checked against gazette page images pp.106-107. [inferred] Neither version says whether a permit covers one shipment; the Form 23 layout (named minerals, quantities and destination) points to a per-consignment permit. [conflict] ng.div-regs-form-numbering: Forms 22/23 are captioned "Regulation 117" in the Cadastre Office copy. [conflict] ng.div-fees-2024: fee. NTAA s.72(4)(e) also requires a tax clearance certificate for an application for an export licence. NEITI 2021 found Customs does not reliably verify permit numbers (ng.div-neiti-permit-check).

• Minerals and Mining Regulations 2011, reg 131(1)-(3); Schedule 1 item 18(a)

Register Form NXP through an Authorised Dealer bank (free of charge); open an export domiciliary account at that bank; quote the NXP number in all dealings with the bank, CBN, inspection agent and Customs

من

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

يتطلب

Certificate of origin; Permit to Export Minerals for Commercial Purpose (Form 23): permit number, exporter, minerals and quantities, destination, fee receipt (RCR) number; signed by the Director of Mines Inspectorate for the Minister and copied to the Area Controller of Customs

يُصدر

e-NXP submission, bank-approved; Proforma / provisional invoice from the Nigerian exporter (against pre-shipment assay)

• CBN Foreign Exchange Manual, 4th Edition (May 2026), Memorandum 10.A (non-oil exports) i-v

Processing bank approves Form NXP; the inspection agent then sends the exporter a Request for Information (RFI) link on the Stakeholders Verification Portal

من

Authorised Dealer bank (Nigeria)

يتطلب

e-NXP submission, bank-approved

يُصدر

e-NXP submission, bank-approved; Request for Information (RFI) on the Stakeholders Verification Portal: NXP no., RFI no., exporter and importer, description of goods, quantity, units, unit price; inspector completes the inspection section

Inspect the consignment within 48 hours of the RFI, at the approved location with Nigeria Customs and other agencies present, checking quantity and quality to determine fair value

من

Pre-shipment inspecting agent (NESS)

يتطلب

e-NXP submission, bank-approved; Request for Information (RFI) on the Stakeholders Verification Portal: NXP no., RFI no., exporter and importer, description of goods, quantity, units, unit price; inspector completes the inspection section

• CBN Foreign Exchange Manual 4th Ed.; Pre-Shipment Inspection of Exports Act, Memorandum 10.A vi-vii, xi

After inspection, pay the assessed NESS levy (0.5% of FOB value) through a designated bank and deliver the receipt to the inspection agent

من

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

يتطلب

e-NXP submission, bank-approved

يُصدر

NESS fee payment receipt

[conflict] Timing of payment: FX Manual 10.A.viii (followed) - after inspection; Anglia International - at a designated bank when Form NXP is submitted, i.e. before inspection; the NPA guide - paid on the intended export value, with an additional charge if inspection finds a higher FOB value.

• CBN Foreign Exchange Manual 4th Ed.; Pre-Shipment Inspection of Exports Act, Memorandum 10.A viii; Act s.14(2)

Once it holds Form NXP and the NESS levy receipt, the inspection agent issues the Clean Certificate of Inspection (NEPC: within 72 hours of inspection; Anglia: within 3 working days); where a discrepancy cannot be corrected, it issues a Non-negotiable Certificate of Inspection instead

من

Pre-shipment inspecting agent (NESS)

يتطلب

Proforma / provisional invoice from the Nigerian exporter (against pre-shipment assay); NESS fee payment receipt; e-NXP submission, bank-approved

يُصدر

Clean Certificate of Inspection

No replacement or renewal of the Jan 2021 non-oil appointments was found for 2022-2026; the agents' sites are still active (Neroli 2026, Anglia 2025). Zones as published by NEPC (June 2022) and reported from the CBN circular of 26 Jan 2021: Anglia - North West and North Central; Neroli - South West and South-South; Gojopal - South East and North East. [inferred] Abuja/FCT falls in North Central. [conflict] Timing: FX Manual 10.A.xi and NEPC (2022) - within 72 hours of inspection; Anglia - within 3 working days; the Act sets no time. The later CBN appointments found (May 2024; 15 June 2026 per the CBN Reforms page) concern oil and gas terminals only.

• CBN Foreign Exchange Manual 4th Ed.; Pre-Shipment Inspection of Exports Act, Memorandum 10.A ix, xi-xiii; Act s.1(1), s.8(1)(b) (non-negotiable certificate), s.9(1)

  “no goods to which this Act applies shall be exported from Nigeria unless an inspecting agent … has issued in respect of the goods a Clean Certificate of Inspection”

File the export declaration (Single Goods Declaration) on the Customs system: NICIS II, being replaced by B'Odogwu

من

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

يتطلب

e-NXP submission, bank-approved; Permit to Export Minerals for Commercial Purpose (Form 23): permit number, exporter, minerals and quantities, destination, fee receipt (RCR) number; signed by the Director of Mines Inspectorate for the Minister and copied to the Area Controller of Customs; Certificate of origin; Fire-assay report, National Geosciences Research Laboratory Centre, Kaduna; Clean Certificate of Inspection

يُصدر

Single Goods Declaration (NICIS II)

[unconfirmed] B'Odogwu replaces NICIS II and handles the Single Goods Declaration; its published rollout (PTML, Apapa, Tin Can Island, Port Harcourt Area II, Kano/Jigawa, Industrial Area Command) names no airport, so which system serves the airport commands is not confirmed. [conflict] ng.div-tax-act-versions: VAT section number.

• Nigeria Customs Service Act; Nigerian Minerals and Mining Act; Nigeria Tax Act (sections in refs), Nigeria Customs Service Act 2023 (No. 35 of 2023) s.148(1): export declaration lodged before goods leave

  “Goods destined to leave the customs territory including oil and gas shall be covered by an export declaration lodged at the relevant customs office before the goods are taken out of the customs territory.”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Act; Nigeria Tax Act (sections in refs), s.76: export value uses the valuation methodology of ss.69-74 (in this record the text of s.76 is parsed into section s-74)

  “The valuation methodology contained in sections 69-74 of this Act shall be used to determine the value of goods for export”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Act; Nigeria Tax Act (sections in refs), s.67(1)(a)

  “determine and declare the classification, valuation and origin of the goods”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Act; Nigeria Tax Act (sections in refs), s.79(2)(a): minerals exploited from Nigerian soil are wholly obtained there

  “mineral products exploited from its soil, territory water or sea-bed”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Act; Nigeria Tax Act (sections in refs), Nigerian Minerals and Mining Act 2007 s.143(1)(a)

  “before the mineral is entered for export declared on the appropriate customs entry from the State from which the mineral was extracted”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Act; Nigeria Tax Act (sections in refs), Nigeria Tax Act 2025 s.186 (National Assembly text; s.187 in the gazetted text, see ng.div-tax-act-versions)

  “the following taxable supplies are charged to VAT at the rate of zero percent”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Act; Nigeria Tax Act (sections in refs), s.186(n)

  “exported goods excluding oil and gas”

Nigeria Customs: document check, physical/X-ray examination, verify NXP/export-permit numbers, release

من

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

يتطلب

Single Goods Declaration (NICIS II); e-NXP submission, bank-approved; Permit to Export Minerals for Commercial Purpose (Form 23): permit number, exporter, minerals and quantities, destination, fee receipt (RCR) number; signed by the Director of Mines Inspectorate for the Minister and copied to the Area Controller of Customs; Clean Certificate of Inspection

يُصدر

Customs release for export ("Export Release Note" in the NPA guide), granted as "release for exit" on the accepted declaration (NCS Act s.149(4))

The Act names no separate release document - "release for exit" is granted on the accepted declaration; the NPA guide calls it the Export Release Note. [not-read] The FMITI step pages for "Customs clearance at the airport in Abuja" are not held (index page only), so the airport sequence recorded earlier (NAHCO warehouse, joint inspection, NDLEA, NCS release, aviation security screening) is not confirmed and was removed from the notes. [ocr] The Regulations' seizure rule was checked against the gazette page image.

• Nigeria Customs Service Act; Nigerian Minerals and Mining Regulations (sections in refs), Nigeria Customs Service Act 2023 s.149(2): goods presented at the exit office; exit formalities

  “Goods leaving the customs territory shall be presented to the customs office at the place of exit or at any other place designated by the Service”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Regulations (sections in refs), s.149(2)(c)(vi): prohibitions incl. money laundering

  “money laundering and other cash transfers contrary to law”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Regulations (sections in refs), s.149(4): release for exit

  “Release for exit shall be granted to condition that the goods leave the customs territory in the same condition as when the export declaration was accepted.”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Regulations (sections in refs), s.150(2): loading before acceptance / goods not matching the declaration

  “commits an offence and is liable on conviction to imprisonment for a term of five years without an option of fine.”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Regulations (sections in refs), s.246(b): forfeiture of goods exported contrary to a prohibition (in this record the text of s.246 is parsed into section s-245)

  “the exportation of the goods is or would be contrary to any prohibition”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Regulations (sections in refs), Nigerian Minerals and Mining Regulations 2011 reg 132(3): seizure without export permit

  “shall seize any Mineral Commodity for export at the Port if the owner fails to present to the Custom Officer an export permit for sale or permit to export minerals for analysis”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Regulations (sections in refs), reg 132(4)

  “be conveyed to the Mines Inspectorate Department within 72 hours of the seizure.”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Regulations (sections in refs), CBN Foreign Exchange Manual, Memorandum 10.A.xiii (no CCI, no loading)

• Nigeria Customs Service Act; Nigerian Minerals and Mining Regulations (sections in refs), NPA export procedure guide (Export Release Note)

Secure road transport, exporter premises -> Lagos/Abuja airport cargo area

من

Secure logistics provider (Nigeria leg)

يتطلب

Single Goods Declaration (NICIS II); Customs release for export ("Export Release Note" in the NPA guide), granted as "release for exit" on the accepted declaration (NCS Act s.149(4)); Letter of identification as accredited agent (Form 30 in the Cadastre Office copy; Form 29 in the gazette): bearer, minerals, title/licence number, principal, mine site and destination of the movement

يُصدر

Packing list; Certificate of insurance

No gold-specific MMIA/airport procedure document was located; escort/desk arrangements are inferred from general secure-logistics practice, not a cited regulation

Airline acceptance of valuable cargo (IATA VAL special handling code) with a Consignment Security Declaration

من

Secure logistics provider (Nigeria leg)

يُصدر

Consignment Security Declaration; Air waybill, Lagos/Abuja -> Dubai

[unconfirmed] The IATA VAL special handling code for valuable cargo is not stated in the sources read. Nig.CARs Part 17 read in the 2015 edition (S.I. 36 of 2015), held in laws/; 17.74.2 quoted.

• IATA Resolution 651 (Consignment Security Declaration programme); Nigeria Civil Aviation Regulations (Nig.CARs) Part 17, Nig.CARs 17.74.2 (goods accepted only with a valid consignment security declaration)

Send the pre-shipment notice to the Dubai importer/refiner (weights, estimated fineness, value, flight, AWB)

من

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

يتطلب

Air waybill, Lagos/Abuja -> Dubai; Packing list

يُصدر

Pre-shipment notice: box count, weights, packing list, estimated fineness, value, carrier, flight, AWB

Screen the supplier and the gold: KYC, OFAC sanctions lists, and confirm the gold is not of Russian Federation origin (unless it was outside Russia before 28 June 2022); apply CAHRA red flags from the 2023 Africa Gold Advisory

من

Importer of record (bullion bank, trader, refiner or dealer)

يتطلب

Commercial invoice; Bar list (serials, weights, fineness)

يُصدر

Importer's supplier KYC and OFAC / Russian-origin screening file

• E.O. 14068; OFAC Determination (effective 28 Jun 2022, amended 22 Dec 2023), E.O. 14068 s.1(a)(i); determination under s.1(a)(i)(A), 1(b) and 5; delegation 31 CFR 587.802

File entry (CBP Form 3461 or electronic equivalent) with evidence of the right to make entry, commercial invoice and packing list, and the entry summary (CBP Form 7501) classifying the gold under HTSUS 7108 with country of origin; deposit any duty (heading 7108 free except 4.1% on 7108.12.50 and 7108.13.70 for non-preference origins) and the 0.3464% merchandise processing fee; shipments of $2,500 or less may use informal entry

من

Licensed customs broker

يتطلب

Importer's supplier KYC and OFAC / Russian-origin screening file; Commercial invoice; Packing list; Air waybill

يُصدر

CBP Form 3461 entry / immediate delivery (or ACE electronic equivalent); CBP Form 7501 entry summary (HTSUS classification, origin, duties and fees)

• 19 CFR 142.3; 19 CFR 143.21; 19 CFR 24.23; HTSUS 7108

Review, examine if selected, and release the goods; CBP enforces the Russian-origin gold ban and any withhold release order on gold made with forced labour

من

US Customs and Border Protection

يتطلب

CBP Form 3461 entry / immediate delivery (or ACE electronic equivalent)

يُصدر

CBP release of entered goods (ACE cargo release)

• 19 CFR 142.3; E.O. 14068 gold determination; 19 U.S.C. 1307 and 19 CFR 12.42

Deliver released gold directly to the refinery or to a COMEX-approved depository (for COMEX, bars must come directly from an approved producer or assayer with certificates, or from another depository)

من

Secure logistics carrier (armoured / valuables; COMEX-approved carrier where relevant)

يتطلب

CBP release of entered goods (ACE cargo release)

يُصدر

Delivery record airport to refinery or depository

Deliver bars into a COMEX-approved depository directly from the approved producer with refiner certificates, from an approved assayer with assay certificates, or from another approved depository

من

Secure logistics carrier (armoured / valuables; COMEX-approved carrier where relevant)

يتطلب

Refiner certificate for bars produced (brand, serial, weight, fineness)

يُصدر

Chain-of-integrity receipt at depository

Inspect and weigh the bars and record them as eligible stock

من

COMEX-approved depository / bullion vault

يتطلب

Chain-of-integrity receipt at depository; Bar list (serials, weights, fineness)

يُصدر

Depository inspection, weight record and eligible-stock entry

Issue an electronic warrant in the name of the clearing member, referencing bar serials and the approved producer; the metal becomes registered (deliverable) stock

من

COMEX-approved depository / bullion vault

يتطلب

Depository inspection, weight record and eligible-stock entry

يُصدر

COMEX gold warrant (electronic UCC Article 7 document of title)

• COMEX Rulebook; UCC Article 7, Rule 705.A; 113108

Report eligible, pledged and registered stocks to the exchange registrar daily by 2:00 p.m.

من

COMEX-approved depository / bullion vault

Optionally pledge the warrant to CME as collateral (title to CME, first-priority security interest, 15% haircut)

من

Futures clearing member / bullion bank

يتطلب

COMEX gold warrant (electronic UCC Article 7 document of title)

Release the bars from the depository (load-out after warrant cancellation if on COMEX warrant) to the carrier

من

COMEX-approved depository / bullion vault

يتطلب

Depository inspection, weight record and eligible-stock entry

File EEI in AES for the foreign-origin gold and give the ITN to the carrier (same rules as export; BIS licence for Russia/Belarus)

من

US principal party in interest (USPPI) / exporter

يُصدر

EEI/ITN for re-export of foreign-origin gold

• Foreign Trade Regulations, 15 CFR 30.2, 30.4

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

من

DMCC importer / trader

يتطلب

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

يُصدر

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

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

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

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

من

DMCC importer / trader

يتطلب

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

يُصدر

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

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

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

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

من

DMCC importer / trader

يُصدر

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

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

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

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

من

DMCC importer / trader

يُصدر

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

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

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

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

من

DMCC Vault (operated by Brink's)

يتطلب

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

يُصدر

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

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

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

من

DMCC importer / trader

يتطلب

Refiner outturn/assay report; Commercial invoice

يُصدر

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

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

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

Credit export proceeds to the exporter's export domiciliary account at the bank where the NXP was registered, within 180 days of the bill of lading / air waybill date; CBN monitors banks on repatriation

من

Authorised Dealer bank (Nigeria)

يُصدر

Credit of export proceeds to the exporter's export domiciliary account at the NXP bank

[inferred] The Manual speaks of the bill of lading; for air freight the air waybill is the equivalent transport document.

• CBN Foreign Exchange Manual 4th Ed., Memorandum 10.A iii, xiv(a) (180 days for non-oil; 90 days applies to oil and gas); Memorandum 20; Appendix II Contravention 6