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Gold

United Kingdom

Checked 2026-09-28 · Version r2 · Replaces version r1 · Reviewed

Public law and official guidance, published as research. Not legal, tax or financial advice.

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Trading hubVaulting hub

London is the main OTC trading and vaulting hub (9,632 t in London vaults, Aug 2026, LBMA). Imports are declared on CDS; the tariff shows 0.00% third-country duty on unwrought gold (7108 12) and import VAT 20% or exempt (additional code VATE) for investment gold (995+ bars). Investment gold between LBMA members is zero-rated under the Terminal Markets Order; between a member and a taxable non-member it is standard-rated under the gold special accounting scheme (buyer accounts). Only LBMA Good Delivery bars settle loco London via LPMCL clearing banks. Russian gold exported from Russia on or after 21 Jul 2022, and third-country gold processed from it, may not be imported (SI 2022/850, SI 2022/1110). The HVD cash threshold became GBP 10,000 and the general CDD occasional-transaction threshold GBP 12,000 on 30 Jun 2026 (SI 2026/621). Refining is minor (Royal Mint e-waste recovery).

How sure this page is

  • Primary law 22
  • Official guidance 38
  • Standard 24
  • Industry practice 2
  • Unverified 2
  • No confidence level recorded 10
  • Researcher's note 50
  • Not recorded 52
  • Text 32
  • OCR 2
  • Transcription 1
  • Not stated 17

Regulators

  • UK Assay Offices (London, Birmingham, Sheffield, Edinburgh)

    Statutory hallmarking of precious-metal articles under the Hallmarking Act 1973 (Birmingham: "one of four assay offices with legal duties under UK law"); dealers must display the compulsory Dealer's Notice. Bullion and current/former legal-tender coins are exempt from hallmarking (Sch 1 Part II paras 3, 7).

    No confidence level recordedNot recorded

  • Bank of England (as gold custodian)

    Allocated gold custody for HM Treasury (UK reserves), other central banks and certain commercial firms that support central-bank access to the London market; gold accounts at the Bank's sole discretion. Not the gold market's regulator: per the LBMA OTC Guide (2017) the Bank has not regulated the gold market since 2000 (FSA formed); certain aspects passed to the FCA after the 2012 legislation; the Bank (PRA) is prudential regulator of banks active in gold.

    Website
    https://www.bankofengland.co.uk/gold
    No confidence level recordedNot recorded

  • Financial Conduct Authority (FCA)

    Conduct supervision of authorised banks and investment firms active in bullion (most are dual-regulated with the PRA); the OTC bullion market itself "is not directly regulated as a market" (LBMA OTC Guide 2017).

    Website
    https://www.fca.org.uk
    No confidence level recordedNot recorded

  • HM Revenue & Customs (HMRC)

    Customs (CDS declarations, EORI), import VAT and VAT on gold (investment gold exemption, special accounting scheme, TMO), AML supervisor for high value dealers and art market participants, enforcement of import sanctions at the border

    Website
    https://www.gov.uk/government/organisations/hm-revenue-customs
    No confidence level recordedNot recorded

  • London Bullion Market Association (LBMA)

    Private standard-setter: Good Delivery List and Rules, Responsible Gold Guidance, Global Precious Metals Code adherence for members, Gold Bar Integrity database, vault data; not a statutory regulator

    Website
    https://www.lbma.org.uk
    No confidence level recordedNot recordedTranscription

  • London Precious Metals Clearing Limited (LPMCL)

    Private clearing company owned by clearing members; loco London clearing via unallocated accounts; standard account agreements

    Website
    https://www.lpmcl.com
    No confidence level recordedNot recorded

  • Office of Financial Sanctions Implementation (OFSI), HM Treasury

    Implements and enforces UK financial sanctions (asset freezes, including on gold held for designated persons); receives frozen-asset reports; issues financial sanctions licences.

    Website
    https://www.gov.uk/government/organisations/office-of-financial-sanctions-implementation
    No confidence level recordedNot recorded

  • Department for Business and Trade - trade sanctions licensing (Import Sanctions Team) and Office of Trade Sanctions Implementation (OTSI)

    DBT is responsible for trade sanctions licensing; import licence applications are handled by DBT's Import Sanctions Team (aims to decide within 30 days). OTSI (part of DBT) handles civil enforcement of certain trade sanctions (services, and goods movements by UK persons that do not cross the UK border). HMRC enforces trade sanctions at the border.

    No confidence level recordedNot recorded

  • Prudential Regulation Authority (PRA), Bank of England

    Prudential supervision of banks and investment firms active in bullion

    No confidence level recordedNot recorded

Laws

  • Customs and Excise Management Act 1979

    Forfeiture of smuggled gold, "even if the gold is found in the hands of an innocent buyer" (VAT Notice 701/21 s.14); some sanctions offences sit in CEMA (Russia statutory guidance s.2).

    Citation
    1979 c. 2
    Kind
    Act
    Official guidanceNot recorded

    Researcher's note: [not-read] Act not held; relevance as stated by HMRC and FCDO guidance.

  • Hallmarking Act 1973

    Hallmarking of precious-metal articles described as gold. Schedule 1 Part II exempts "Any coin which is, or was formerly at any time, current coin of the United Kingdom or any other territory" (para 3) and "Any raw material (including any bar, plate, sheet, foil, rod, wire, strip or tube) or bullion" (para 7).

    Citation
    1973 c. 43
    Kind
    Act
    Primary lawNot recorded

    Researcher's note: [summary] Schedule 1 paragraphs were quoted through a WebFetch read (asked verbatim) on 2026-09-28; the Act is not yet held in laws/ (gb-fetch.tsv) - to be checked against the held copy.

  • LBMA Good Delivery Rules (incl. Annexes A-I)

    Bar specification (2.1.5 marks, 2.1.7 350-430 fine oz, 995.0 minimum), vault refusal right (2.4), refiner throughput/TNW (4.1), GPMC (5.2), Responsible Sourcing (5.3), sanctions (5.4), Approved Weighers (Annex A) and weighing, packing and delivery (Annex B). 2026 edition held.

    Kind
    Rulebook
    StandardNot recordedTranscription

  • Russia (Sanctions) (EU Exit) Regulations 2019

    Parent regime (Part 5 trade). Gold: Chapter 4J (regs 46Z10-46Z16, inserted by SI 2022/850) and Chapter 4JA (regs 46Z16A-46Z16I, inserted by SI 2022/1110); Schedule 3G; exceptions reg 60A(1C)-(1D); licences under Part 7. Financial sanctions (asset freeze regs 11-15; reg 18A foreign-reserve services incl. gold of the Central Bank of Russia) as described in the statutory guidance.

    Citation
    SI 2019/855
    Kind
    Regulation
    Official guidanceNot recorded

    Researcher's note: [not-read] The consolidated SI 2019/855 is not held (gold chapters and Schedule 3G listed in gb-fetch.tsv); the gold provisions were read in the amending SIs as made, and regs 11-15 and 18A only as named in the statutory guidance.

  • Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022

    Chapter 4J (Gold): reg 46Z11 import of gold originating in Russia exported from Russia on or after 21 Jul 2022 (export defined in 46Z11(2)); 46Z12 acquiring gold that originated in and is located in Russia with the intention that it enter the UK; 46Z13 supplying or delivering gold that originated in Russia on or after 21 Jul 2022 from Russia or a third country to the UK; 46Z14-46Z16 technical assistance, financial services/funds and brokering; reg 60A(1C) diplomatic exception. Schedule 3G: 7108; the code printed "71129 10000" (waste and scrap of gold); ex 7118 9000 gold coin.

    Citation
    SI 2022/850
    Kind
    Regulation
    In force from
    2022-07-21
    Primary lawNot recorded

    Researcher's note: Reg 46Z11(1) "originating from" was corrected to "originating in" by SI 2022/1110 Sch 3 para 4.

  • Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022

    Chapter 4JA: 46Z16A relevant processed gold = gold processed in a third country incorporating gold that on or after 21 Jul 2022 originated in and was exported from Russia; 46Z16B gold jewellery (Sch 3G Part 3: ex 7113, ex 7114) originating in Russia exported on or after 29 Oct 2022; 46Z16C import of relevant processed gold; 46Z16D-46Z16I acquisition, technical assistance, financial services and brokering; reg 60A(1C)-(1D) exceptions. In force 29 Oct 2022.

    Citation
    SI 2022/1110
    Kind
    Regulation
    In force from
    2022-10-29
    Primary lawNot recorded

    Researcher's note: SI 2023/1367 reg 4 extended the reg 60A(1D) personal-jewellery exception to diamond jewellery; it made no new gold prohibition.

  • Value Added Tax (Terminal Markets) Order 1973

    Art. 2(2) lists "the London Bullion Market" among the terminal markets; art. 2(4): "a person is to be regarded as being a member of the London Bullion Market only if that person is a member of the London Bullion Market Association"; art. 2(5): investment gold has the VATA 1994 Sch 9 Group 15 meaning (both inserted by SI 1999/3117 from 1 Jan 2000). The zero-rating provisions for LBM investment gold are arts 4 to 7 per VGOLD1700 (not held).

    Citation
    SI 1973/173
    Kind
    Regulation
    Primary lawNot recorded

    Researcher's note: [not-read] Arts 3-7 not held (whole Order listed in gb-fetch.tsv); what they zero-rate is taken from HMRC guidance. [conflict] gb.div-tmo-member-category: art. 2(4) says any LBMA member; LBMA says the TMO is extended to Full and Market Making Members only, per the HMRC-LBMA MOU.

  • Value Added Tax (Investment Gold) Order 1999

    Right to opt to tax investment gold (VGOLD1700; art. 4 is named there as the provision the special accounting scheme also applies to). Procedure: notification, or HMRC written agreement for industrial-purpose suppliers (Notice 701/21 s.4, force of law).

    Citation
    SI 1999/3116
    Kind
    Regulation
    Official guidanceNot recorded

    Researcher's note: [not-read] Order text not held (gb-fetch.tsv).

  • Value Added Tax Regulations 1995

    reg 31A: invoicing, record keeping and notification for investment gold (published by HMRC as tertiary legislation with force of law); regs 103 and 103A: limited right to deduct input tax (per VGOLD1700).

    Citation
    SI 1995/2518
    Kind
    Regulation
    Official guidanceNot recorded

    Researcher's note: [not-read] Regulations text not held (reg 31A listed in gb-fetch.tsv).

  • Value Added Tax Act 1994

    s.50 (Terminal Markets Order power), s.55 (special accounting scheme for gold; also applies to opted investment gold), s.69A (penalties for breach of the VAT Regulations), Sch 8 Group 10 (zero rate: supplies by/to central banks), Sch 9 Group 15 (investment gold exemption, from 1 Jan 2000) - as listed in HMRC VGOLD1700.

    Citation
    1994 c. 23
    Kind
    Act
    Official guidanceNot recorded

    Researcher's note: [not-read] The Act itself is not held in laws/ (legislation.gov.uk data.pdf returned HTTP 202 on 2026-09-28; HTML pages listed in gb-fetch.tsv). Section and Schedule numbers are as printed in VGOLD1700 (held, read-full); the r1 note that s.55 was "from general knowledge, not read" is withdrawn - VGOLD1700 names s.55.

  • Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 (as amended, incl. SI 2022/748 and SI 2023/616)

    The tariff attaches to 7108 12 a Belarus import restriction (legal base SI 2023/616, from 30 Sep 2023) and export restriction (legal base SI 2022/748), footnotes SN129/SN030.

    Kind
    Regulation
    Official guidanceNot recorded

    Researcher's note: [not-read] Neither the Regulations nor SIs 2022/748 and 2023/616 are held (gb-fetch.tsv); scope of the gold measures (origin or consignment test) not read.

  • Customs Tariff (Establishment) (EU Exit) Regulations 2020

    Legal base the UK tariff gives for the 0.00% third-country duty on 7108 12 00 00.

    Citation
    SI 2020/1430
    Kind
    Regulation
    Official guidanceNot recorded

    Researcher's note: [not-read] SI not held; rate read on the tariff (28 Sep 2026).

  • LPMCL standard Allocated and Unallocated Account Agreements (2018)

    English-law custody/clearing contracts (templates): deposit notices and Rules-compliant bars (Allocated cl. 3; Unallocated cl. 3), verification and weighing before credit, right to refuse, withdrawal notices ([2pm] London time default, cl. 4.2), reports at least annually (cl. 2.3), sanctions representations (Allocated cl. 10; Unallocated cl. 8), English law (Allocated cl. 17; Unallocated cl. 15).

    Kind
    Other
    StandardNot recordedOCR

  • Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017

    reg 14(1)(a): high value dealer = trader in goods making or receiving cash of at least GBP 10,000 (single or linked); reg 27(1)-(3): CDD triggers (business relationship; transfer of funds > GBP 800; occasional transaction GBP 12,000+; HVD occasional cash transaction GBP 10,000+); reg 33: EDD incl. FATF call-for-action countries (as amended 30 Jun 2026).

    Citation
    SI 2017/692
    Kind
    Regulation
    Primary lawNot recorded

    Researcher's note: [not-read] The consolidated MLR 2017 is not held in laws/ (data.pdf HTTP 202 on 2026-09-28; HTML listed in gb-fetch.tsv). Regs 14(1)(a) and 27(1)-(3) were quoted verbatim through WebFetch; the amounts are confirmed by the held amending SI 2026/621 (regs 9, 14, 19).

  • Money Laundering and Terrorist Financing (Amendment) Regulations 2026

    reg 9: in MLR reg 14 "10,000 euros" -> "GBP 10,000"; reg 14: in MLR reg 27 thresholds (1)(b) GBP 800, (2) GBP 12,000, (3) GBP 10,000, (5) and (7) GBP 2,000, (7A)/(7C) GBP 10,000, (7E) GBP 800; reg 19: reg 33 "high-risk third country" -> "FATF call for action country"; reg 15: pooled-account CDD (reg 29(10)-(18)). In force 30 Jun 2026; regs 20 and 36(b) from 1 Feb 2027; reg 37 partly 25 Oct 2027. Also amends Terrorism Act 2000 Sch 3A and POCA 2002 Sch 9.

    Citation
    SI 2026/621 (made 9 Jun 2026)
    Kind
    Regulation
    In force from
    2026-06-30
    Primary lawNot recorded

  • Sanctions and Anti-Money Laundering Act 2018

    Enabling Act for the Russia sanctions Regulations (SIs 2022/850, 2022/1110, 2023/1367 made under ss.1, 5, 15, 17, 45, 54 and Sch 1) and for the MLR amendments (SI 2026/621 under ss.49, 54(2) and Sch 2); s.43 statutory guidance; s.21 UK nexus.

    Citation
    2018 c. 13
    Kind
    Act
    Primary lawNot recorded

    Researcher's note: [not-read] The Act itself is not held; the sections are those recited in the SIs' preambles and the guidance.

Laws concerning gold in United Kingdom

From the law library: the laws tagged with this commodity, with their sources. They are not research findings; the sections above are.

Gold (Bank of England web page, bankofengland.co.uk/gold)

Regulation · none - an information web page, not a numbered instrument · Bank of England

HMRC list of gold coins that are investment gold (from the file; to confirm against the document)

Other · to confirm · HM Revenue & Customs (to confirm)

Memorandum of Understanding (MoU) between LBMA, LPPM and HMRC (from the file; to confirm against the document)

Treaty · to confirm · to confirm

VGOLD1300 - Background to the exemption for investment gold (HMRC internal manual VAT Gold)

Guidance · VGOLD1300 · HM Revenue & Customs

VGOLD1500 - The special accounting scheme (HMRC internal manual VAT Gold)

Guidance · VGOLD1500 · HM Revenue & Customs

VGOLD1600 - The London Bullion Market and Central Banks (HMRC internal manual VAT Gold)

Guidance · VGOLD1600 · HM Revenue & Customs

VGOLD1700 - UK and EC Law (HMRC internal manual VAT Gold)

Regulation · VGOLD1700 · HM Revenue & Customs

Investment gold coins (VAT Notice 701/21A)

Notice · VAT Notice 701/21A · HM Revenue & Customs

The Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022

Regulation · S.I. 2022 No. 850 (Exiting the European Union; Sanctions); http://www.legislation.gov.uk/id/uksi/2022/850 · Secretary of State (FCDO; signed Rehman Chishti, Parliamentary Under Secretary of State) under the Sanctions and Anti-Money Laundering Act 2018; laid under s.55(3) for approval within 28 days

The Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022

Regulation · S.I. 2022 No. 1110 (Sanctions); http://www.legislation.gov.uk/id/uksi/2022/1110; issued free of charge in part to correct errors in S.I. 2022/792 and S.I. 2022/850 · Secretary of State (FCDO; signed Leo Docherty, Minister of State); approved by both Houses

The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023

Regulation · S.I. 2023 No. 1367 (Sanctions); http://www.legislation.gov.uk/id/uksi/2023/1367 · Secretary of State (FCDO; signed Anne-Marie Trevelyan, Minister of State)

UK Integrated Online Tariff - Commodity 7108120000 (Gold, non-monetary, other unwrought forms)

form · commodity code 7108 12 00 00; measures cite S.I. 2020/1430 (third-country duty), S.I. 2020/1457, 2023/561, 2023/195, 2024 c.6, S.I. 2023/616 and 2022/748 (Belarus), S.I. 2022/801, 2022/452 and 2019/855 (Russia), S.I. 2022/395 (Ukraine NGCA), S.I. 2019/411 (DPRK) · UK Integrated Online Tariff (GOV.UK trade tariff service; HMRC is named for classification advice)

UK overseas trade in goods statistics July 2025: methodology notes

Other · none - accredited official statistics release note · HM Revenue & Customs

vat investment gold order 1999 si 1999 3116 (from the file; to confirm against the document)

Order · to confirm · to confirm

Gold imports and exports (VAT Notice 701/21) [page title as retrieved; the URL slug is gold-acquisitions-imports-investments-and-vat-notice-70121]

Notice · VAT Notice 701/21 · HM Revenue & Customs

VAT Tertiary Legislation - Gold imports and exports

Notice · HMRC guidance manual "VAT Tertiary Legislation", page "Gold imports and exports" · HM Revenue & Customs

Procedures

Delivery into a London vault and credit to an allocated or unallocated account

Applies when: Bars are stored loco London

  1. Custody

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

    Who
    Bullion dealer / trader (importer of record, usually an LBMA member)
    With
    London commercial vault / custodian (typically a clearing or custodian bank)
    StandardNot recordedOCRTranscription

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

  2. Inspection

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

    Who
    LBMA Approved Weigher
    Issues
    Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)
    StandardNot recordedTranscription

    Legal basis: LBMA Good Delivery Rules, Annex B

  3. Inspection

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

    Who
    London commercial vault / custodian (typically a clearing or custodian bank)
    With
    Secure valuables carrier
    Needs
    Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)
    StandardNot recordedOCRTranscription

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

  4. Due diligence

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

    Who
    London commercial vault / custodian (typically a clearing or custodian bank)
    Needs
    Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)
    StandardNot recorded

    Legal basis: LBMA Good Delivery List suspension notice (7 Mar 2022)

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

  5. Custody

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

    Who
    London commercial vault / custodian (typically a clearing or custodian bank)
    Needs
    Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)
    Issues
    Allocated weight list (bar number, gross weight, fineness, fine weight, brand) or unallocated balance statement
    StandardNot recordedOCR

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

  6. Custody

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

    Who
    Bank of England (gold custodian)
    With
    Foreign central bank holding gold in London
    Official guidanceNot recorded

    Researcher's note: Monetary state applies when held as reserves by a monetary authority.

  7. Reporting

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

    Who
    London commercial vault / custodian (typically a clearing or custodian bank)
    Issues
    Custodian holdings return to LBMA (London vault data / GBI)
    StandardNot recorded

Buyer due diligence, sanctions origin check and CDS import

Applies when: UK receives bars (typically Good Delivery bars or kilobars from Switzerland, South Africa, the US etc.)

  1. Due diligence

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

    Who
    Bullion dealer / trader (importer of record, usually an LBMA member)
    With
    Foreign seller / consignor (refiner or trader abroad)
    Issues
    Supplier KYC pack received by the UK buyer; MLR customer due diligence file
    Primary lawNot recordedOCR

    Legal basis: Money Laundering Regulations 2017, reg 27

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

  2. Due diligence

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

    Who
    Bullion dealer / trader (importer of record, usually an LBMA member)
    Issues
    Importer's Russia-sanctions origin evidence file
    Primary lawNot recorded

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

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

  3. Transport

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

    Who
    Secure valuables carrier
    Issues
    Air waybill, inbound valuables consignment
    Unverified

    Researcher's note: UK valuables-cargo handling not researched in this pass.

    No source recorded
  4. Customs

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

    Who
    Customs agent / declarant using CDS software
    With
    HMRC (customs and VAT authority)
    Needs
    Importer's Russia-sanctions origin evidence file; Air waybill, inbound valuables consignment
    Issues
    CDS full import declaration
    Official guidanceNot recorded

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

  5. Tax

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

    Who
    Bullion dealer / trader (importer of record, usually an LBMA member)
    With
    HMRC (customs and VAT authority)
    Needs
    CDS full import declaration
    Official guidanceNot recorded

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

  6. Customs

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

    Who
    HMRC (customs and VAT authority)
    Needs
    CDS full import declaration
    Official guidanceNot recorded

Vault withdrawal and CDS export

Applies when: Bars leave London for another hub (Switzerland, US, Hong Kong, Gulf, India, China)

  1. Custody

    Instruct withdrawal in writing: for allocated metal, bar serials (or the bank selects), amount and Withdrawal Date, received by the time in the agreement ("[2pm]" London time in the LPMCL template); unallocated metal is first allocated or delivered from bars the bank selects

    Who
    Bullion dealer / trader (importer of record, usually an LBMA member)
    With
    London commercial vault / custodian (typically a clearing or custodian bank)
    Needs
    Allocated weight list (bar number, gross weight, fineness, fine weight, brand) or unallocated balance statement
    StandardNot recordedOCR

    Legal basis: LPMCL Account Agreements, Allocated cl. 4.1, 4.2, 4.4; Unallocated cl. 3.5, 4.1, 4.2

  2. Due diligence

    Screen the buyer, its owners and the destination against the UK Sanctions List (asset freeze: no funds or economic resources to designated persons); no financial services for the gold or reserves of the Central Bank of Russia, National Wealth Fund or Ministry of Finance; for Russia or Belarus destinations, the tariff attaches export restrictions to 7108 12 (declare 9011 licence or 9022; C052/Y999 for the Russia export-control measure)

    Who
    Bullion dealer / trader (importer of record, usually an LBMA member)
    Needs
    MLR customer due diligence file
    Official guidanceNot recorded

    Legal basis: Russia (Sanctions) (EU Exit) Regulations 2019; Republic of Belarus (Sanctions) (EU Exit) Regulations 2019

    Researcher's note: [not-read] The tariff's "Restriction on export for Russia" on 7108 12 cites SI 2022/452 (the No. 8 amending Regulations) - not held, so which prohibition it implements for unwrought gold is not confirmed. The guidance's export list names no gold-specific export prohibition. The r1 claim of a ban on "making gold available to or for use in Russia" is withdrawn (the guidance does not list gold among the making-available prohibitions).

  3. Custody

    Release the bars to the carrier against the withdrawal instruction with a bar list; client bears cost and risk from collection

    Who
    London commercial vault / custodian (typically a clearing or custodian bank)
    With
    Secure valuables carrier
    Issues
    Bar list for bars leaving the London vault
    StandardNot recordedOCR

    Legal basis: LPMCL Allocated Account Agreement, cl. 4.4

  4. Customs

    Submit a full export declaration on CDS before the goods leave (30 minutes before for air); no gold-specific export licence identified outside sanctions cases

    Who
    Customs agent / declarant using CDS software
    With
    HMRC (customs and VAT authority)
    Needs
    Bar list for bars leaving the London vault
    Issues
    CDS full export declaration
    Official guidanceNot recorded

    Researcher's note: The tariff (28 Sep 2026) shows UK export measures on 7108 12 only for Belarus, North Korea and Russia destinations and a supplementary unit (gram); no general export licence measure. 7108 13 page not held.

  5. Transport

    Fly the bars out under an air waybill; departure message confirms exit

    Who
    Secure valuables carrier
    Needs
    CDS full export declaration
    Issues
    Air waybill, outbound
    Official guidanceNot recorded

    Researcher's note: AWB practice not sourced.

  6. Tax

    Treat exported investment gold as outside the scope of UK VAT (input tax recoverable); hold export evidence (departure message or commercial evidence per VAT Notice 703)

    Who
    Bullion dealer / trader (importer of record, usually an LBMA member)
    Official guidanceNot recorded

    Legal basis: VAT Notice 701/21, s8.2

    Researcher's note: Without a departure message, commercial evidence under VAT Notice 703 s.7 may be used (export guidance); Notice 703 not held.

Minor UK refining / recovery

Applies when: Gold is recovered or refined in the UK

  1. Processing

    Take in UK e-waste (printed circuit boards) at the Royal Mint recovery plant, Llantrisant (up to 4,000 t PCBs a year, opened 2024)

    Who
    UK refiner / precious-metals recovery plant
    Industry practiceNot recorded
  2. Refining

    Recover gold chemically (Excir process) at 99.9%+ purity; hundreds of kg a year, used in the Royal Mint's 886 jewellery line

    Who
    UK refiner / precious-metals recovery plant
    Industry practiceNot recorded

    Researcher's note: No LBMA Good Delivery status found for this output; no ref.ms state fits recovered gold, so states left null.

  3. Tax

    A producer of investment gold may opt to tax its B2B supplies by notifying HMRC; standard-rated supplies then fall under the special accounting scheme

    Who
    UK refiner / precious-metals recovery plant
    With
    HMRC (customs and VAT authority)
    Official guidanceNot recorded

    Legal basis: VAT (Investment Gold) Order 1999

  4. Reporting

    If Good Delivery-listed: pass annual RGG independent assurance and upload country-of-origin data and assurance deliverables to the LBMA GBI database (monthly CoO mandatory from 2027)

    Who
    UK refiner / precious-metals recovery plant
    Issues
    RGG annual assurance report of a UK Good Delivery refiner
    StandardNot recordedTranscription

    Legal basis: LBMA Good Delivery Rules / Responsible Gold Guidance

Retail investment-gold sale by a dealer (HVD rules for cash)

Applies when: Domestic retail sale of bars/coins

Channel: Retail dealer

  1. Licensing

    Register with HMRC as a high value dealer before accepting or making any cash payment of GBP 10,000 or more (single or linked); pay annual fee

    Who
    Retail bullion dealer accepting cash (high value dealer)
    With
    HMRC (customs and VAT authority)
    Primary lawNot recorded

    Legal basis: MLR 2017 as amended by SI 2026/621, reg 14 (definition)

    Researcher's note: [conflict] gb.div-hvd-guidance-lag. Registration requirement ("must not accept or make a high value cash payment until you have registered") from the HMRC page; the MLR registration regulation not read.

  2. Due diligence

    Apply CDD to any occasional cash transaction of GBP 10,000 or more

    Who
    Retail bullion dealer accepting cash (high value dealer)
    Issues
    MLR customer due diligence file
    Primary lawNot recorded

    Legal basis: MLR 2017, reg 27(3)

    Researcher's note: [not-read] Reg 27(3) quoted via WebFetch; amount confirmed by SI 2026/621 reg 14(c) (held).

  3. Tax

    Sell investment gold VAT-exempt to the retail customer: identity evidence (one List 1 and one List 2 document), invoice and records where the thresholds are met

    Who
    Retail bullion dealer accepting cash (high value dealer)
    Needs
    MLR customer due diligence file
    Official guidanceNot recorded

    Legal basis: VAT Notice 701/21; VAT Regs 1995 reg 31A, Notice s7.1

Loco London OTC sale and settlement

Applies when: Bars or metal balances are sold in London

Channel: Wholesale OTC via LPMCL clearing members

  1. Due diligence

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

    Who
    LPMCL clearing member bank
    With
    Bullion dealer / trader (importer of record, usually an LBMA member)
    Issues
    MLR customer due diligence file
    Primary lawNot recordedOCR

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

    Researcher's note: [not-read] MLR reg 27 quoted via WebFetch; MLR not held.

  2. Pricing

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

    Who
    Bullion dealer / trader (importer of record, usually an LBMA member)
    With
    LPMCL clearing member bank
    Needs
    MLR customer due diligence file
    StandardNot recorded
  3. Tax

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

    Who
    Bullion dealer / trader (importer of record, usually an LBMA member)
    Official guidanceNot recorded

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

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

  4. Custody

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

    Who
    LPMCL clearing member bank
    Needs
    Allocated weight list (bar number, gross weight, fineness, fine weight, brand) or unallocated balance statement
    Issues
    Loco London settlement: transfer between unallocated accounts via LPMCL members, or allocated bar transfer
    StandardNot recorded

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

  5. Payment

    Pay the cash leg against metal settlement

    Who
    LPMCL clearing member bank
    With
    Bullion dealer / trader (importer of record, usually an LBMA member)
    Needs
    Loco London settlement: transfer between unallocated accounts via LPMCL members, or allocated bar transfer
    Issues
    Cash-leg payment for the metal
    Unverified

    Researcher's note: Cash-leg timing and DvP arrangements not documented in the sources read.

    No source recorded
  6. Reporting

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

    Who
    Bullion dealer / trader (importer of record, usually an LBMA member)
    Needs
    Loco London settlement: transfer between unallocated accounts via LPMCL members, or allocated bar transfer
    Primary lawNot recorded

    Legal basis: VAT Regulations 1995; VAT tertiary legislation (gold), reg 31A

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

  7. Reporting

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

    Who
    LPMCL clearing member bank
    Needs
    MLR customer due diligence file
    Official guidanceNot recorded

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

Licences and registrations

  • LBMA Approved Weigher status

    Weight lists stating approved-weigher status

    Held by
    LBMA Approved Weigher
    Issued by
    LBMA
    StandardNot recordedTranscription

    Legal basis: LBMA Good Delivery Rules Annex A/B

    Researcher's note: Annex A of the GD Rules 2026 lists the Approved Weighers (Bank of England (gold only), Brink's, Citi, HSBC, ICBC Standard, Malca-Amit, JP Morgan, Loomis) and notes that LBMA does not approve vaults.

  • Bank of England gold account

    Allocated gold account

    Held by
    Foreign central bank holding gold in London
    Issued by
    Bank of England
    Official guidanceNot recorded

  • LBMA Good Delivery List accreditation

    Current List entry

    Held by
    UK refiner / precious-metals recovery plant
    Issued by
    LBMA
    Valid for
    ongoing, annual checks and Proactive Monitoring
    StandardNot recordedTranscription

    Legal basis: LBMA Good Delivery Rules

  • Adherence to the Global Precious Metals Code

    Signed Statement of Commitment to the Global Precious Metals Code (Rules for Members Sch 1)

    Held by
    Bullion dealer / trader (importer of record, usually an LBMA member)
    Issued by
    LBMA (membership condition)
    Valid for
    ongoing
    StandardNot recordedTranscription

  • LBMA Full or Market Making Membership (the category that benefits from the Terminal Markets Order zero rate)

    Listing as LBMA member

    Held by
    Bullion dealer / trader (importer of record, usually an LBMA member)
    Issued by
    LBMA
    Valid for
    membership year 1 January to 31 December; annual fee (Rules for Members s.6.2)
    Official guidanceNot recorded

    Legal basis: VAT (Terminal Markets) Order 1973 art. 2(4); LBMA Rules for Members Sch 3

    Researcher's note: [conflict] gb.div-tmo-member-category - TMO art. 2(4) counts any LBMA member; LBMA Rules Sch 3 and the 2017 OTC Guide say HMRC treats Full Members (incl. Market Making) as the market members, per the HMRC-LBMA MOU (MOU not held).

  • Option to tax supplies of investment gold (notified to HMRC)

    Held by
    UK refiner / precious-metals recovery plant
    Issued by
    HMRC (Written Enquiries Section)
    Official guidanceNot recorded

    Legal basis: VAT (Investment Gold) Order 1999

  • Trade sanctions import licence for otherwise prohibited Russian gold (DBT Import Sanctions Team)

    Licence reference, declared on CDS under document code 9011 as "GBSAN" + reference

    Held by
    Bullion dealer / trader (importer of record, usually an LBMA member)
    Issued by
    Department for Business and Trade (Import Sanctions Team) on behalf of the Secretary of State
    Official guidanceNot recorded

    Legal basis: Russia (Sanctions) (EU Exit) Regulations 2019, Part 7 (each gold prohibition is "subject to Part 7 (Exceptions and licences)")

  • LBMA Responsible Gold Guidance compliance with annual independent audit

    Annual audit report by an approved service provider, submitted within three months of financial year-end and published with the List entry (GD Rules 5.3); uploaded through the GBI database

    Held by
    UK refiner / precious-metals recovery plant
    Issued by
    LBMA / approved assurance provider
    Valid for
    annual
    StandardNot recordedTranscription

  • EORI number (GB)

    EORI number quoted on declarations

    Held by
    Bullion dealer / trader (importer of record, usually an LBMA member)
    Issued by
    HMRC
    Valid for
    ongoing
    Official guidanceNot recorded

    Researcher's note: [not-read] Parts 2-6 of the EORI guide not held (only part 1).

  • PRA/FCA authorisation as a bank or investment firm

    Financial Services Register entry

    Held by
    LPMCL clearing member bank
    Issued by
    PRA and FCA
    Valid for
    ongoing
    StandardNot recorded

    Researcher's note: [not-read] Stated by the LBMA OTC Guide (2017 edition held: "authorised banks and investment firms, which are dual-regulated"); FSMA text not read.

  • HMRC high value dealer registration under the MLR

    HMRC MLR registration

    Held by
    Retail bullion dealer accepting cash (high value dealer)
    Issued by
    HMRC
    Valid for
    annual renewal and fee
    Fee
    Registration and annual supervision fees (amounts not read)
    Primary lawNot recorded

    Legal basis: Money Laundering Regulations 2017, reg 14 (definition); registration article not read

    Researcher's note: [conflict] gb.div-hvd-guidance-lag - the HMRC page still says 10,000 euros; the model follows SI 2026/621 (GBP 10,000 from 30 Jun 2026). [not-read] The MLR registration regulation and fee amounts not read.

  • LPMCL clearing membership

    Member listing (Citi, HSBC, ICBC Standard, JP Morgan, UBS as of Sep 2026)

    Held by
    LPMCL clearing member bank
    Issued by
    LPMCL
    StandardNot recorded

Taxes and fees

  • Customs duty on gold (UK Global Tariff)

    HS 7108 12 00 00 non-monetary gold, other unwrought forms (read); 7108 13 and 7112 91 not held

    Rate
    0.00% (third-country duty on 7108 12 00 00; preferential rates also 0.00%)
    Paid by
    Importer
    Collected by
    HMRC
    Official guidanceNot recorded

    Legal basis: Customs Tariff (Establishment) (EU Exit) Regulations 2020 (S.I. 2020/1430), as shown on the tariff

    Researcher's note: [not-read] Rate read on the UK Integrated Online Tariff for 7108 12 only (7108 13 page and S.I. 2020/1430 not held).

  • Import VAT on investment gold

    Bars/wafers 995+ of a weight accepted by the bullion markets; qualifying coins

    Rate
    Exempt
    Base
    Customs value
    Official guidanceNot recorded

    Legal basis: VAT Act 1994 Sch 9 Group 15; VAT Notice 701/21 s.8.1; UK tariff additional code VATE

    Researcher's note: [conflict] gb.div-cpc-chief (CHIEF CPC 40 00 073 in the Notice vs additional code VATE on the tariff).

  • Import VAT on non-investment gold

    Doré, grain, scrap, bars below 995, non-qualifying coins

    Rate
    20% (standard rate; tariff code 03020)
    Base
    Customs value
    Paid by
    Importer
    Collected by
    HMRC
    Official guidanceNot recorded

    Legal basis: VAT Notice 701/21, s10.7

  • VAT exemption for supplies of investment gold (with option to tax)

    Supplies of investment gold (incl. rights to it, unallocated gold, loans, swaps, forwards and futures; not options) and agents' services for them; not between an LBMA member and a taxable non-member (standard-rated, SAS)

    Rate
    Exempt
    Official guidanceNot recorded

    Legal basis: VAT Act 1994 Sch 9 Group 15; VAT (Investment Gold) Order 1999

  • Special accounting scheme (reverse charge) for gold

    Standard-rated B2B supplies between VAT-registered (or liable) persons: fine gold, gold grain, gold coins (not margin-scheme), gold-containing goods priced at no more than a negligible amount above the gold value, investment gold on which the option to tax is exercised or supplied between an LBMA member and a non-member, and treatment/processing services producing such gold (Notice 701/21 s.11.2)

    Rate
    20%, accounted for by the buyer
    Paid by
    VAT-registered buyer
    Collected by
    HMRC
    Official guidanceNot recorded

    Legal basis: VAT Act 1994 s.55 (named in VGOLD1700; statute not held)

    Researcher's note: [unconfirmed] Introduced "in 1993" per VGOLD1500 (no day given; 1 Jan used as a placeholder date). The scheme is compulsory (Notice 701/21 s.11).

  • Zero rate for London Bullion Market and central-bank gold transactions

    Investment gold (incl. futures and options) between taxable LBMA members (TMO; Notice 701/9 s.3.2.4); gold, rights to or part interests in gold held in the UK between central banks or between a central bank and an LBM member (VATA Sch 8 Group 10; Notice 701/21 s.10.4). Not zero-rated: investment gold between an LBMA member and a taxable non-member (standard-rated, special accounting scheme); a futures contract between a member and a non-member that leads to physical delivery (Notice 701/9 s.3.3.2).

    Rate
    0%
    Official guidanceNot recorded

    Legal basis: VAT (Terminal Markets) Order 1973 art. 2(2), (4) and arts 4-7; VATA 1994 s.50, Sch 8 Group 10

    Researcher's note: [conflict] gb.div-tmo-member-category. [not-read] TMO arts 4-7 and VATA s.50/Sch 8 not held.

  • HMRC MLR registration and annual supervision fee

    Rate
    Not read
    Paid by
    High value dealer
    Collected by
    HMRC
    Official guidanceNot recorded

    Researcher's note: [not-read] Fee amounts are on the HMRC registration-fees page, not held (gb-fetch.tsv). HMRC may terminate a registration if the correct fee is not paid.

Controls

  • No Great Britain statute imposing CAHRA/OECD due diligence on gold importers was found. Responsible-sourcing duties in London come from the LBMA (RGG mandatory for Good Delivery refiners since 2012; annual audit; Incident Review Process) and the GBI country-of-origin reporting (monthly, mandatory from 2027).

    Kind
    Conflict-area due diligence
    StandardNot recordedTranscription

    Legal basis: LBMA Responsible Gold Guidance / Good Delivery Rules

    Researcher's note: Negative finding for Great Britain. Northern Ireland: the Conflict Minerals (Compliance) (Northern Ireland) (EU Exit) Regulations 2020 (SI 2020/1664) and a 2021 amendment exist (found by search 2026-09-28); [not-read] not yet held (gb-fetch.tsv), so their gold thresholds are not recorded.

  • UK persons may not provide financial services for foreign exchange reserve and asset management to the Central Bank of Russia, the National Wealth Fund or the Russian Ministry of Finance (or persons owned, controlled or acting for them); the reserves include bullion such as gold - "it is prohibited to provide financial services to carry out transactions with the Central Bank of the Russian Federation involving its gold". Relevant firms must report funds or economic resources held for these bodies.

    Kind
    Sanctions
    Official guidanceNot recorded

    Legal basis: Russia (Sanctions) (EU Exit) Regulations 2019, reg 18A (as named in the statutory guidance)

    Researcher's note: [not-read] Regulation text not held; reg 18A as named in guidance s.3.2.

  • Only Good Delivery bars settle loco London: 350-430 fine troy oz, minimum 995.0 fineness, marks = refiner stamp, assay mark, fineness, serial number (max 11 digits or characters), month and year of manufacture (MMYY, since Jan 2019); no laser engraving. Vault managers have complete discretion and an absolute right to refuse bars (GD Rules 2.4); custodians may refuse metal (LPMCL cl. 3.5 / 3.4).

    Kind
    Bar standard
    StandardNot recordedOCRTranscription

    Legal basis: LBMA Good Delivery Rules 2026; LPMCL account agreements, GD Rules 2.1.5, 2.1.7, 2.4

  • The Hallmarking Act 1973 regulates describing articles as gold; Schedule 1 Part II exempts "Any raw material (including any bar, plate, sheet, foil, rod, wire, strip or tube) or bullion" (para 7) and coins that are or were current coin of the UK or any other territory (para 3). Bullion bars and legal-tender coins therefore need no hallmark; gold articles such as jewellery do.

    Kind
    Other
    Primary lawNot recorded

    Legal basis: Hallmarking Act 1973

    Researcher's note: [summary] Sch 1 read through WebFetch (asked verbatim) on 2026-09-28; Act not yet held (gb-fetch.tsv). [not-read] Weight de minimis exemptions for gold articles not recorded.

  • Dealers in exempt investment gold must identify customers (one List 1 and one List 2 document), issue invoices with prescribed details, keep records at least 6 years and notify HMRC within 28 days when an exempt supply first exceeds GBP 5,000 or supplies to one customer exceed GBP 10,000 in 12 months - whether or not VAT-registered; penalty normally 17.5% of the value of the transactions (Finance Act 2000 penalty, Notice 701/21 s.9).

    Kind
    Anti-money laundering
    Threshold
    GBP 5,000 per supply / GBP 10,000 per customer per 12 months
    Primary lawNot recorded

    Legal basis: VAT Regulations 1995; VAT tertiary legislation, reg 31A

    Researcher's note: Force of law as HMRC tertiary legislation (held); the penalty rate is in the non-statutory part of Notice 701/21.

  • LBMA suspended six Russian refiners (Krastsvetmet, Novosibirsk, Uralelectromed, Moscow Special Alloys, Prioksky, Shyolkovsky) from the Good Delivery List on 7 Mar 2022; their bars made from that date are not Good Delivery; stocks already in loco London/Swiss before then remain Good Delivery.

    Kind
    Bar standard
    Valid from
    2022-03-07
    StandardNot recorded

    Legal basis: LBMA Good Delivery List

  • Import of gold originating in Russia that was exported from Russia on or after 21 Jul 2022 is prohibited (reg 46Z11); so are acquiring gold that originated in and is located in Russia with the intention that it enter the UK (46Z12), supplying or delivering gold that originated in Russia on or after 21 Jul 2022 from Russia or a third country to the UK (46Z13), and related technical assistance, financial services or funds and brokering (46Z14-46Z16). Gold exported from Russia before 21 Jul 2022 is outside the import ban. "Gold" = Schedule 3G (7108; gold waste and scrap; ex 7118 90 gold coin). Licences under Part 7; diplomatic exception reg 60A(1C).

    Kind
    Sanctions
    Threshold
    none
    Valid from
    2022-07-21
    Primary lawNot recorded

    Legal basis: Russia (Sanctions) (EU Exit) Regulations 2019 as amended by SI 2022/850, regs 46Z11-46Z16; Sch 3G

  • Import of relevant processed gold - gold processed (altered, transformed or otherwise operated on) in a third country that incorporates gold which on or after 21 Jul 2022 originated in and was exported from Russia - is prohibited (46Z16C), as is import of gold jewellery (Sch 3G Part 3) originating in Russia exported on or after 29 Oct 2022 (46Z16B); with prohibitions on acquisition of Russian gold jewellery, technical assistance, financial services and brokering (46Z16D-46Z16I). Personal-luggage jewellery exception reg 60A(1D).

    Kind
    Sanctions
    Valid from
    2022-10-29
    Primary lawNot recorded

    Legal basis: SI 2022/1110 (Chapter 4JA), regs 46Z16B, 46Z16C, 46Z16D-46Z16I

  • All smuggled gold may be liable to forfeiture under the Customs and Excise Management Act 1979, even in the hands of an innocent buyer; HMRC advises buyers to check where the gold came from, whether it was declared at import with import VAT paid, and warning signs (below-market price, quick settlement or cash, new seller without fixed premises).

    Kind
    Other
    Official guidanceNot recorded

    Legal basis: Customs and Excise Management Act 1979; VAT Notice 701/21 s.14

  • The UK tariff attaches to 7108 12 00 00 a "Restriction on entry into free circulation for Belarus" (from 30 Sep 2023; legal base SI 2023/616) and a "Restriction on export for Belarus" (legal base SI 2022/748): allowed with document code 9011 (DBT licence, GBSAN reference) or 9022 (not subject to / exempt from sanctions, evidence to be produced on demand).

    Kind
    Sanctions
    Valid from
    2023-09-30
    Official guidanceNot recorded

    Legal basis: Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 as amended

    Researcher's note: [not-read] SIs 2023/616 and 2022/748 not held; the regulation numbers and the origin/consignment test of the Belarus gold measure are not recorded.

  • A trader accepting or making a cash payment of GBP 10,000 or more for goods (single or linked) is a high value dealer: must register with HMRC first and apply CDD. Threshold changed from EUR 10,000 to GBP 10,000 with effect from 30 Jun 2026.

    Kind
    Cash limit
    Threshold
    GBP 10,000 cash (EUR 10,000 before 30 Jun 2026)
    Valid from
    2026-06-30
    Primary lawNot recorded

    Legal basis: MLR 2017 as amended by SI 2026/621, regs 14, 27(3); SI 2026/621 reg 9

    Researcher's note: [conflict] gb.div-hvd-guidance-lag - HMRC guidance still says 10,000 euros.

  • Regulated firms apply CDD on a business relationship, a transfer of funds over GBP 800, an occasional transaction of GBP 12,000+ (HVDs: cash GBP 10,000+), suspicion or doubt; EDD for PEPs, non-face-to-face and FATF call-for-action countries (reg 33 as amended 30 Jun 2026); keep records 5 years; nominated officer reports suspicion to the NCA.

    Kind
    Anti-money laundering
    Threshold
    Occasional transactions GBP 12,000 (general); GBP 10,000 cash (HVD); transfer of funds GBP 800 (from 30 Jun 2026; previously 15,000 / 10,000 / 1,000 euros)
    Primary lawNot recorded

    Legal basis: MLR 2017, reg 27

    Researcher's note: [conflict] gb.div-hvd-guidance-lag - HMRC's responsibilities page still gives 15,000/10,000 euros and the EU high-risk list. [not-read] Consolidated MLR not held.

  • The import into the United Kingdom of gold originating from Russia is prohibited where it was exported from Russia on or after the relevant day. The ban goes by origin, so it applies whichever country the gold is shipped from.

    Kind
    Sanctions
    No confidence level recorded

    Legal basis: The Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022, inserting reg 46Z11 into SI 2019/855, reg 46Z11(1)

    No source recorded

Trade flows

  • LPMCL net daily average gold clearing was USD 64.5bn in July 2026.

    Figures: USD 64.5bn/day

    StandardNot recorded

  • January 2025: precious metals were 42% of UK goods exports (GBP 18.167bn), with GBP 7.605bn to the United States (up 342% m/m) and GBP 7.612bn to Switzerland.

    Figures: GBP 18.2bn exports; US 7.6bn; CH 7.6bn

    Official guidanceNot recorded

  • September 2025: precious metals imports GBP 8.95bn (Switzerland 2.232bn, South Africa 0.99bn, Uzbekistan 0.881bn, US 0.755bn); exports GBP 6.553bn (Qatar 1.582bn, China 1.268bn, Hong Kong 1.029bn, Oman 0.633bn, Switzerland 0.166bn).

    Figures: Imports 8.95bn; exports 6.55bn GBP

    Official guidanceNot recorded

    Researcher's note: Figures confirmed in the held commentary (Tables 6-7), filed under laws/za-south-africa/.

  • HMRC trade statistics include non-monetary gold (gold not held as a reserve asset by a monetary authority, incl. scrap and jewellery) and exclude monetary gold, which ONS records in the National Accounts; per LBMA (Alchemist 97), ONS balance of payments records ownership changes between residents and non-residents even when bars stay in a London vault.

    Official guidanceNot recorded

  • London vaults (commercial plus Bank of England) held 9,632 t of gold at end-August 2026, about 770,571 bars worth about USD 1.4 trillion.

    Figures: 9,632 t; +1.03% m/m (Aug 2026)

    StandardNot recorded

Where practice departs from the law

What credible sources show happening that the law does not provide for.

  • [conflict] VAT Notice 701/21 s.8.1 (last updated 31 Dec 2020) tells importers to use CHIEF CPC 40 00 073 to gain the investment-gold exemption; CHIEF is no longer used for imports (import guidance, update of 1 Oct 2022) and the UK tariff for 7108 12 (28 Sep 2026) shows the exemption as VAT additional code VATE (footnote 03006). The model follows the tariff. Affected: gb.st-04, gb.tax-import-vat-ig.

    Official guidanceNot recorded

  • [conflict] HMRC's high value dealer page (last updated 10 Aug 2022) and "Your responsibilities" page (23 May 2025) still give 10,000 euros (HVD registration and CDD), 15,000 euros (other occasional transactions) and the EU list of high-risk third countries, whereas SI 2026/621 substituted GBP 10,000 (MLR reg 14 and reg 27(3)), GBP 12,000 (reg 27(2)) and the FATF call-for-action list (reg 33) from 30 Jun 2026. The model follows the SI (the law). Affected: gb.cr-hvd-registration, gb.ctl-hvd-cash, gb.ctl-mlr-cdd, gb.st-30.

    Primary lawNot recorded

  • [conflict] Who counts as a London Bullion Market member for the TMO zero rate. The Order (art. 2(4), revised text held) says a person is a member of the London Bullion Market "only if that person is a member of the London Bullion Market Association" - any category. LBMA's Rules for Members (Schedule 3, note 2) and its 2017 OTC Guide say the TMO provisions are extended to Full Members (including Market Making Members) - HMRC "considers Full Members of the LBMA to be official members of the market" - and point to the HMRC-LBMA-LPPM MOU for the interpretation; Affiliate Members do not get the benefit. The model follows the LBMA/MOU reading (Full and Market Making Members) because it is the agreed HMRC practice; the MOU itself is not held (gb.gap-hmrc-lbma-mou). Affected: gb.cr-lbma-membership, gb.tax-vat-zero-lbm, gb.st-22, gb.law-tmo-1973.

    Primary lawNot recorded

What we could not obtain

Documents the research needed and could not get, where they might be, and why.

  • Text of the Belarus sanctions measures the tariff attaches to 7108 12 (import restriction from 30 Sep 2023, export restriction).

    Missing document
    SI 2023/616 and SI 2022/748 (Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations)
    Where it might be
    https://www.legislation.gov.uk/uksi/2023/616/pdfs/uksi_20230616_en.pdf
    Why not obtained
    Measures found on the held tariff page on 2026-09-28; SIs not yet downloaded (gb-fetch.tsv).
    Affects
    gb.ctl-belarus-goldgb.law-belarus-2019

  • Bank of England gold account terms and deposit requirements.

    Missing document
    Bank of England gold custody terms
    Where it might be
    Bank of England (terms not published on https://www.bankofengland.co.uk/gold)
    Why not obtained
    Not public on the page read in full on 2026-09-28; request row in gb-requests.md.
    Affects
    gb.st-15

  • CDS procedure / additional procedure code (DE 1/10, 1/11) for importing investment gold; the VAT exemption itself is shown on the tariff as additional code VATE.

    Missing document
    UK Trade Tariff Volume 3: CDS import declaration completion guide
    Where it might be
    https://www.gov.uk/government/publications/cds-uk-trade-tariff-volume-3-import-declaration-completion-guide
    Why not obtained
    Found as a link in the held import guidance on 2026-09-28; not yet downloaded (gb-fetch.tsv).
    Affects
    gb.st-04

  • HMRC list of coins recognised as investment gold coins (attachment to VAT Notice 701/21A).

    Missing document
    Coins-update-20260615.ods
    Where it might be
    https://assets.publishing.service.gov.uk/media/6a467a541c8bd7ce25a5ea00/Coins-update-20260615.ods
    Why not obtained
    Attachment not in the download list; listed in gb-fetch.tsv.
    Affects
    gb.tax-vat-ig-supply

  • Parts 2-6 of the GOV.UK EORI guide.

    Missing document
    Get an EORI number - printable guide
    Where it might be
    https://www.gov.uk/eori/print
    Why not obtained
    The download captured only part 1; listed in gb-fetch.tsv.
    Affects
    gb.cr-eori

  • Held copy of the Hallmarking Act 1973 (Schedule 1 was read only through WebFetch).

    Missing document
    Hallmarking Act 1973 Schedule 1
    Where it might be
    https://www.legislation.gov.uk/ukpga/1973/43
    Why not obtained
    data.pdf returned HTTP 202 to the Mac host on 2026-09-28; HTML page listed in gb-fetch.tsv.
    Affects
    gb.ctl-hallmarkinggb.law-hallmarking-1973

  • The HMRC-LBMA/LPPM memorandum of understanding on VAT treatment of market transactions.

    Missing document
    HMRC/LBMA VAT MOU
    Where it might be
    https://www.lbma.org.uk/memorandum-of-understanding-mou-between-hmrc-lbma-and-lppm-2013 (PDF lead: http://www.lbma.org.uk/assets/downloads/LBMA%20LPPM%20MOU%20April%202013.pdf)
    Why not obtained
    URL found by search on 2026-09-28; not yet downloaded (gb-fetch.tsv).
    Affects
    gb.tax-vat-zero-lbmgb.div-tmo-member-categorygb.cr-lbma-membership

  • HMRC MLR registration and annual fee amounts for high value dealers.

    Missing document
    Money Laundering Regulations: registration fees (GOV.UK)
    Where it might be
    https://www.gov.uk/guidance/money-laundering-regulations-registration-fees
    Why not obtained
    Linked from the held HVD page; not yet downloaded (gb-fetch.tsv).
    Affects
    gb.tax-hvd-fee

  • Consolidated MLR 2017 (regs 14, 27, 33 and the registration provisions) held in laws/.

    Missing document
    SI 2017/692 as amended
    Where it might be
    https://www.legislation.gov.uk/uksi/2017/692
    Why not obtained
    data.pdf for regs 14 and 27 returned HTTP 202 (empty) on 2026-09-28; HTML page form listed in gb-fetch.tsv.
    Affects
    gb.law-mlr-2017gb.cr-hvd-registrationgb.ctl-mlr-cddgb.st-01gb.st-20gb.st-31

  • Text of the Conflict Minerals (Compliance) (Northern Ireland) (EU Exit) Regulations 2020 (SI 2020/1664) and its 2021 amendment, and the EU Regulation thresholds for gold as they apply in Northern Ireland.

    Missing document
    SI 2020/1664; SI 2021/145
    Where it might be
    https://www.legislation.gov.uk/uksi/2020/1664/pdfs/uksi_20201664_en.pdf
    Why not obtained
    Identified by search on 2026-09-28 (the r1 guessed gov.uk URL was 404); not yet downloaded (gb-fetch.tsv).
    Affects
    gb.ctl-cahra

  • Consolidated Russia (Sanctions) (EU Exit) Regulations 2019 gold chapters (4J, 4JA), Schedule 3G, reg 18A, and the provisions behind the tariff's Russia export restriction on 7108 (SI 2022/452); Notice to Importers 2953.

    Missing document
    SI 2019/855 (revised) Part 5 Chapters 4J/4JA, Sch 3G; SI 2022/452; NTI 2953
    Where it might be
    https://www.legislation.gov.uk/uksi/2019/855/part/5/chapter/4J
    Why not obtained
    Not in the download list; listed in gb-fetch.tsv on 2026-09-28.
    Affects
    gb.law-russia-2019gb.st-51gb.ctl-cbr-reserve-services

  • Tariff measures for 7108 13 (semi-manufactured gold, e.g. many kilobars), 7108 11 (powder) and 7112 91 (scrap); only 7108 12 is held.

    Missing document
    UK Integrated Online Tariff pages for 7108 13 00 00, 7108 11 00 00, 7112 91 00 00
    Where it might be
    https://www.trade-tariff.service.gov.uk/commodities/7108130000
    Why not obtained
    Not in the 2026-09-28 download list; added to laws/_work/gb-fetch.tsv.
    Affects
    gb.tax-import-dutygb.st-04gb.st-53

  • Articles 1 and 3-7 of the Terminal Markets Order (the zero-rating provisions); the revised article 2 is held.

    Missing document
    SI 1973/173 as amended (whole instrument)
    Where it might be
    https://www.legislation.gov.uk/uksi/1973/173/contents
    Why not obtained
    Only article 2 was in the download list; whole instrument listed in gb-fetch.tsv.
    Affects
    gb.law-tmo-1973gb.tax-vat-zero-lbmgb.st-22

  • Whether any UK-located refiner is on the current gold Good Delivery List.

    Missing document
    LBMA Current List data table
    Where it might be
    https://www.lbma.org.uk/good-delivery/gold-current-list
    Why not obtained
    The refiner table is script-rendered: the curl copy (laws/_international) and a WebFetch on 2026-09-28 show only "67 Gold refiners". Request row in laws/_work/gb-requests.md (save from a browser).
    Affects
    gb.proc-refining

  • Text of VATA 1994 s.50, s.55, Sch 8 Group 10 and Sch 9 Group 15.

    Missing document
    VAT Act 1994 provisions
    Where it might be
    https://www.legislation.gov.uk/ukpga/1994/23/schedule/9/group/15
    Why not obtained
    Not in the download list; legislation.gov.uk data.pdf URLs returned HTTP 202 (empty) to the Mac host on 2026-09-28, but its HTML pages download (TMO art. 2 did). HTML URLs listed in laws/_work/gb-fetch.tsv.
    Affects
    gb.law-vata-1994gb.tax-vat-reverse-chargegb.tax-vat-zero-lbmgb.tax-import-vat-iggb.tax-vat-ig-supply

  • Whether a non-bank wholesale bullion dealer paid by wire (no cash) falls within any MLR category.

    Missing document
    Money Laundering Regulations 2017 (SI 2017/692), consolidated, regs 8-14
    Where it might be
    https://www.legislation.gov.uk/uksi/2017/692
    Why not obtained
    Reg 14 (read via WebFetch 2026-09-28) makes HVD status depend on cash of GBP 10,000+, so a wire-paid dealer is not an HVD; whether it is a "financial institution" under reg 10 needs the full text - data.pdf returned HTTP 202; HTML listed in gb-fetch.tsv.
    Affects
    gb.st-01

Routes through United Kingdom

Country pairs

Sources

Every source this country's research cites, with how much of it was read and how.