Zimbabwe [state buyer/exporter (FGR) or gold dealing licensee] → Canada (refine) → United Arab Emirates · Reconcile assays and pay the balance

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

Ask the research

Ask in your own words. The answer is the research itself: its records, word for word, with every source and how sure each one is.

The route, leg by leg

Each step, tax and control as the research records it, with its legal basis and how sure the research is.

Zimbabwe (Doré bar - unstamped → Pre-refined 995 bar (e.g. 'Dubai 995')) ⟶ Canada (Pre-refined 995 bar (e.g. 'Dubai 995') → LBMA Good Delivery 400oz bar) ⟶ United Arab Emirates (LBMA Good Delivery 400oz bar)

Not researched: Zimbabwe → Canada, Canada → United Arab Emirates

Leg 1: Zimbabwe

Where the goods start

Doré bar - unstamped → Pre-refined 995 bar (e.g. 'Dubai 995')

1
Register as an exporter in CEPECS through the authorised dealer
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Issues
CEPECS exporter registration
Official guidance
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.1
2
Obtain the Gold Export Certificate for the lot
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Issues
Gold Export Certificate
Official guidance
[unconfirmed] Issuer and form of the 'Gold Export Certificate' are stated in no text held (FX Guidelines, Gold Trade Act and Regulations, Exchange Control Regulations and General Order all read); requested (zw.gap-gec).
3
Prepare assays and a pro-forma invoice showing the quantity, price and total value of the gold
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Needs
FGR bar list for the export lot
Issues
Assays supporting the RBZ export application; Pro-forma invoice: quantity, price and total value of gold to be exported (FXG 3.2.30)
Official guidance
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.30
4
Submit the export application on the RBZ Document Management System with the Gold Export Certificate, Gold Dealership Licence, assays and pro-forma invoice
Who
Authorised dealer bank
Needs
Gold Export Certificate; Gold dealing licence ('Gold Dealership Licence'); Assays supporting the RBZ export application; Pro-forma invoice: quantity, price and total value of gold to be exported (FXG 3.2.30); CEPECS exporter registration
Primary law
- Exchange Control Regulations SI 109/1996; RBZ Foreign Exchange Guidelines FXD5/2026, Regulations s.20(1)(e) (no export of gold unless authorised by an exchange control authority); Guidelines para 3.2.30 ('All exports of Gold require prior Reserve Bank approval')
5
Approve the gold export within 24 working hours and issue an approval reference number
Who
Reserve Bank of Zimbabwe
Issues
RBZ gold export approval (approval reference number on the Document Management System)
Official guidance
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.30
6
Raise the CEPECS Form CD1 quoting the RBZ approval reference
Who
Authorised dealer bank
Needs
RBZ gold export approval (approval reference number on the Document Management System)
Issues
CEPECS Form CD1 (exchange control export form)
Official guidance
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), paras 3.2.5, 3.2.30
7
Issue the commercial invoice to the foreign buyer/refiner (attached to the export entry)
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Issues
Commercial invoice
Official guidance
ZIMRA lists 'Suppliers' invoices' for the export entry; the pro-forma invoice goes to the RBZ (3.2.30). [blocked] ZIMRA page via WebFetch only.
8
Lodge the export bill of entry (Form 21) through a registered clearing agent in ASYCUDA World before the gold leaves, with the CEPECS Form CD1, the invoice and the RBZ approval; pay the clearance fee - 'No duties are payable on export'
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Needs
CEPECS Form CD1 (exchange control export form); RBZ gold export approval (approval reference number on the Document Management System); Commercial invoice
Issues
Customs export bill of entry (Form 21, lodged in ASYCUDA World)
Primary law
[blocked] The ZIMRA clearance page was read only through WebFetch. [unconfirmed] Any gold-specific customs examination is not described.
- Customs and Excise Act [Chapter 23:02]; Customs and Excise (General) Regulations 2001, Act s.54(1), s.61; Regulations s.62(1)(a); Exchange Control Regulations s.21
9
Where the buyer or the importing country's customs requires one (e.g. the UAE import declaration, ae.st-18), obtain a certificate of origin from the Zimbabwe National Chamber of Commerce on its form: the exporter declares 'that all the goods are of ZIMBABWE ORIGIN' and the chamber certifies it; the form carries the invoice, consignee and destination, transport, tariff number, description, net weight and the bill of entry number
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Needs
Commercial invoice; Customs export bill of entry (Form 21, lodged in ASYCUDA World)
Issues
ZNCC certificate of origin for the gold consignment
Secondary
ZNCC's own form read in full (a chamber, not a regulator). [unconfirmed] Whether FGR or other gold exporters obtain one in practice, its fee and turnaround were not found (requested from ZNCC). [inferred] Treated as optional: no Zimbabwean export rule requires it. [blocked] ZIMRA origin page via WebFetch only.
- Customs and Excise Act [Chapter 23:02]; Customs and Excise (General) Regulations 2001, Act s.89(1)(a) ('wholly grown or produced' test for unmanufactured goods); Regulations s.25 (certificates of origin for lower duty - imports)
10
An officer authorises loading by stamping the consignment note or air waybill; the airline accepts the sealed consignment as valuable cargo under the air waybill and the gold must leave Zimbabwe within ten days of the authority
Who
Secure logistics provider / airline
Needs
Customs export bill of entry (Form 21, lodged in ASYCUDA World)
Issues
Air waybill
Primary law
[inferred] Air freight from Harare is assumed; no Zimbabwe source names the route or carriers.
- Customs and Excise (General) Regulations 2001; Customs and Excise Act, Regulations s.63(1), (3); Act s.55(1)

Taxes and fees

Export duty and customs clearance fee
none on export ('No duties are payable on export'); clearance fee per Form 21
Official guidanceAmount not confirmed
- Customs and Excise (General) Regulations 2001, s.62(1)(a)(ii); s.175 (clearance fee)
Gold dealing licence fee
US$200,000 per year
Primary lawAmount not confirmed
- Gold Trade (Licence Fees) Notice 1978, Schedule 2, as replaced by SI 32 of 2023
Presumptive tax on small-scale miners
0% of the purchase price of precious metals Precious metals bought from small-scale miners
Primary lawAmount not confirmed
- Finance Act [Chapter 23:04] s.22C(1)(b) as substituted by Finance Act 2024 s.6, s.22C(1)(b)
Gold royalty, artisanal and small-scale miners
2% (reported, 2025-2026); previously 1% Gold sold by artisanal and small-scale miners
SecondaryAmount not confirmed
- Mines and Minerals Act s.244-245; Finance Act [Chapter 23:04] Schedule to Chapter VII; Income Tax Act 37th Schedule, MMA ss.244-245; 37th Schedule paras 2-3, 7
Gold royalty, 'gold produced by other miners' (price-banded, from 1 January 2026)
3% (sold 'at a time when its price is US$1 200 per ounce'); 5% (above US$1,200 but below US$5,000 per ounce); 10% (above US$5,000 per ounce) 'Gold produced by other miners' (the Schedule item replaced by the Finance Act 2025; the item for small-scale miners is separate and not held)
Primary lawAmount not confirmed
- Finance Act 2025 s.61 (Schedule to Chapter VII of the Finance Act [Chapter 23:04]); Income Tax Act 37th Schedule, s.61; 37th Schedule paras 2, 3, 7
Gold royalty, large-scale producers (before Finance Act 2025)
3% below US$1,200/oz; 5% above US$1,200/oz
SecondaryAmount not confirmed
Implicit cost: 10% ZiG payment to small-scale miners and FGR discount to spot
~5% below spot (best FGR tier) plus 10% of value paid in ZiG (ASM) / 30% (LSM)
SecondaryAmount not confirmed

Controls

Exporters surrender 30% of gross proceeds to the RBZ at the interbank rate and retain 70% indefinitely (retention cut from 75% to 70% in the February 2025 MPS); 50% surrender on overdue proceeds; proceeds due within 90 days.
30% of gross export receipts
Official guidanceAmount not confirmed
- Exchange Control Regulations SI 109/1996; RBZ FX Guidelines FXD5/2026, Regulations ss.5, 35(1)(c); Guidelines paras 3.2.2, 3.2.3; Directive FXD5/2026 para 2
Gold Trade Act licensees and permit holders are 'precious metals dealers' (MLPC Act s.13): identify and verify customers who pay 'in currency equal to or exceeding fifteen thousand United States dollars' (s.15(2)(d)) and whenever ML/TF is suspected, and the beneficial owner (s.15(3)); EDD for PEPs (…
US$15,000 CDD threshold for occasional transactions
Primary lawAmount not confirmed
- MLPC Act [9:24]; FIU DPMS Guidance (2026), MLPC Act ss.13, 15(2)(d), 15(3), 20, 24, 30, 31; Guidance paras 155, 172
Authorised gold bars are FGR-produced 99.5% bars of gazetted weights and dimensions bearing the FGR hallmark; defacing, altering, counterfeiting or smelting them is an offence (level 14 fine or up to 15 years).
Primary law
- Gold Trade Act [Chapter 21:03] as amended by Finance Act 2025, ss.2, 3, 12A
A traveller may take out at most 'US$2,000 or its equivalent in any other currency, combination of currencies or gold coins' in foreign cash, and ZiG cash equivalent to US$2,000 (FX Guidelines 3.2.33-3.2.34). Personal-use gold articles in baggage are exempt from the export prohibition (Exchange Cont…
US$2,000
Official guidanceAmount not confirmed
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), paras 3.2.33-3.2.34
All gold won must be delivered 'not later than the 10th of every month' to the holder of a gold dealing licence (GTA s.6(1)), who 'shall deal with such gold in accordance with directions issued to him by the Minister responsible for finance' (s.6(3)). Only licence or permit holders, location holders…
All gold, any quantity
Primary law
- Gold Trade Act [Chapter 21:03], ss.3(1), 4, 5, 6(1), 6(3)
Gold Trade Enforcement Unit (FGR staff plus police) may inspect mining locations and premises, examine documents and devices, and seize gold; obstruction is an offence.
Primary law
- Gold Trade Act [Chapter 21:03] Part IIIA, ss.22B-22E
Payment for gold delivered to refineries: ASGM not more than 90% foreign currency / not less than 10% ZiG; LSGM 70% / 30% (from 1 March 2026).
Official guidance
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.29
'No person shall dispatch by post any postal article containing gold unless he is authorized to do so by any regulation' (GTA s.10(1)); authorised: licence holders, permit holders, location holders or tributors and their employees or agents (GT Regulations reg 8); suspect articles may be detained an…
Primary law
- Gold Trade Act [Chapter 21:03]; Gold Trade Regulations 1978, s.10; reg 8
No person may export gold unless authorised by an exchange control authority (Exchange Control Regulations s.20(1)(e)); 'All exports of Gold require prior Reserve Bank approval', applied for by the authorised dealer on the Document Management System with 'The Gold Export Certificate', 'Gold Dealersh…
Primary law
- Exchange Control Regulations SI 109/1996; Exchange Control Act; RBZ FX Guidelines FXD5/2026, Regulations s.20(1)(e); Act s.5(4c); Guidelines para 3.2.30
  “a fine of three times the value of the item”
'No person shall smelt or change the form of any manufactured article containing gold unless he has received the permission of the Minister' (GTA s.12(1)); fine up to level nine or two years (s.12(2)).
Primary law
- Gold Trade Act [Chapter 21:03], s.12
Contravening s.3(1): without special circumstances 'imprisonment for a period of not less than five years or more than ten years', not suspendable (s.3(3)(a), (4)); with special circumstances up to five years or a fine up to level nine or twice the value of the gold (s.3(3)(b)); the same for ss.4, 5…
Primary law
- Gold Trade Act [Chapter 21:03], ss.3(3)-(4), 24, 30
On 4 March 2024 the US ended the Zimbabwe sanctions programme and designated President Mnangagwa and 10 other individuals plus Sakunda Holdings, Fossil Agro and Fossil Contracting under Global Magnitsky, citing involvement in gold and diamond smuggling networks. FGR is not named. US persons must scr…
Official guidance

Leg 2: Canada

On the way

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

11
Hold a Business Number with RM import-export program account, registered in the CARM Client Portal (and optional RPP financial security)
Who
Importer of record (doré, scrap or bars for refining)
Official guidance
12
Present the shipment for release: classify doré as 7108.12.00.22 (bars 7108.12.00.11/.21, scrap 7112.91) - all Free under MFN and every preferential tariff; no import permit; gold goods from Russia or a person in Russia (Schedule 9) and precious-metal scrap from Russia (Schedule 13) are prohibited; goods produced wholly or in part by forced labour are prohibited
Who
Licensed customs broker
Needs
Export customs declaration accepted by the dispatching country's customs; Commercial invoice; Air waybill
Issues
Commercial invoice from the foreign shipper
Primary law
Forced-labour prohibition: Customs Tariff item 9897.00.00 (ca.src-tariff-ch98). MFN is not available for goods of Belarus, North Korea or Russia (guide-3).
- Customs Tariff; SEMA (Russia) Regulations, Tariff item 7108.12.00; SEMA (Russia) ss.3.11, 3.16
13
Account for the goods on a Commercial Accounting Declaration (Type C at release, or Type AB within five business days of release under RPP) and pay duties and taxes on the statement of account; imported precious-metal bars are non-taxable for GST, and doré, unwrought gold, scrap and concentrates imported to be refined are non-taxable
Who
Importer of record (doré, scrap or bars for refining)
Needs
Commercial invoice from the foreign shipper
Issues
Commercial Accounting Declaration
Primary law
- Customs Act; Accounting for Imported Goods and Payment of Duties Regulations; Excise Tax Act; Non-Taxable Imported Goods (GST/HST) Regulations, Customs Act s.32; SOR/86-1062 s.10; ETA Sched VII s.8; SOR/91-31 s.3(a), (b)
14
Keep import records for 6 years; self-correct within 90 days; CBSA may verify origin, value and classification for 4 years
Who
Importer of record (doré, scrap or bars for refining)
Needs
Commercial Accounting Declaration
Official guidance
90-day correction duty read in Customs Act s.32.2(2); six-year retention and four-year verification from CBSA guide-7 and D17-1-21 (the regulation fixing the period was not read).
15
Onboard the supplier: KYC, OECD five-step risk assessment, sanctions/PEP/adverse-media screening, confirm gold is not imported, purchased or acquired from Russia or a person in Russia
Who
Private LBMA Good Delivery refiner in Canada
Needs
Refining (toll) agreement, mine - Canadian refiner; Origin country's export authorisation for the gold (permit, licence or clearance issued by the mining or trade authority)
Issues
Supplier KYC pack and acknowledgement of the refiner's procurement policy; Onboarding and daily screening record; non-Russian origin confirmation
Primary law
[inferred] SEMA element is law; KYC and OECD process are LBMA/refiner practice, not a Canadian statute for refiners.
- SEMA (Russia) Regulations s.3.11; LBMA RGG; OECD DDG, s.3.11
16
Receive, weigh, melt and sample the lot; assay in the refinery lab and issue the outturn
Who
Private LBMA Good Delivery refiner in Canada
Needs
Supplier KYC pack and acknowledgement of the refiner's procurement policy; Onboarding and daily screening record; non-Russian origin confirmation
Issues
Refiner outturn assay and settlement statement
Official guidance
17
Refine to 999.9 (or 999.99) and cast LBMA Good Delivery 400 oz bars, 100 oz or 1 kg bars bearing the refiner's mark
Who
Private LBMA Good Delivery refiner in Canada
Issues
Bar list of refined bars (GD 400 oz, 100 oz, kilobars)
Form
Doré bar - stamped/exporter-sealed → LBMA Good Delivery 400oz bar
Official guidance
18
Settle outturn with the supplier: credit fine metal to its metal account or buy the metal, with final invoice
Who
Private LBMA Good Delivery refiner in Canada
Needs
Refiner outturn assay and settlement statement
Issues
Refiner's final invoice / metal-account credit against outturn
Industry practice
19
First supply of the refined bars by the refiner (or the owner on whose behalf they were refined) is zero-rated for GST/HST; refining fees charged to the metal owner are generally taxable
Who
Private LBMA Good Delivery refiner in Canada
Issues
Invoice for sale of refined bars (zero-rated first supply by the refiner / exempt resale)
Primary law
Refining-fee taxability is CRA guidance (17-1 para 35), not a specific statutory provision.
- Excise Tax Act, s.123(1) 'precious metal'; Sched VI Part IX s.3
20
For any purchase or sale of $10,000 or more as a dealer in precious metals: verify identity, keep records, report cash of $10,000+ (LCTR), virtual currency (LVCTR) and suspicious transactions
Who
Private LBMA Good Delivery refiner in Canada
Issues
Record of $10,000+ purchase or sale and client identification; Large cash transaction report; Suspicious transaction report; Large virtual currency transaction report
Primary law
s.65(2) excludes purchases/sales in connection with extracting precious metals from a mine or manufacturing a product; its application to refiners buying doré is not settled in the texts read.
- PCMLTF Regulations, ss.65, 66, 126, 148
21
Optionally hold refined bars in allocated (segregated, identified bars) or unallocated storage at the Royal Canadian Mint vaults in Ottawa or Winnipeg (institutional clients only), with semi-annual counts
Who
Royal Canadian Mint (federal Crown corporation: refinery and vault)
Needs
Bar list of refined bars (GD 400 oz, 100 oz, kilobars)
Issues
Allocated weight list / unallocated account statement
Official guidance
22
Re-export imported or toll-refined bars: file CERS export declaration (non-US destinations, CAD 2,000+) and hand the proof of report number to the carrier
Who
Exporter of record (mine, refiner or bullion trader)
Needs
Commercial Accounting Declaration
Issues
CERS export declaration and proof of report number
Primary law
23
Carry the re-exported bars under air waybill
Who
Secure precious-metals carrier / airline
Needs
CERS export declaration and proof of report number
Issues
Air waybill
Industry practice

Taxes and fees

GST on imported precious metal
Non-taxable Imported precious metals under any circumstances (SOR/91-31 s.3(a)); unwrought gold, waste and scrap and gold concentrates imported to be refined into precious metals (s.3(b))
Primary law
- Excise Tax Act; Non-Taxable Imported Goods (GST/HST) Regulations, ETA Sched VII s.8; SOR/91-31 s.3(a), (b)
GST/HST on 'precious metal' (gold bars, ingots, coins, wafers of 99.5%+)
Zero-rated when supplied by the refiner or the person on whose behalf it was refined (Sched VI Part IX s.3); otherwise exempt as a financial service (Sched V Part VII s.1); supplies by a financial institution to a non-resident zero-rated (Sched VI Part IX s.1) ref.ms-gd400, ref.ms-9999 bars; not doré, granules or jewellery
Primary lawAmount not confirmed
- Excise Tax Act, s.123(1); Sched V Part VII s.1; Sched VI Part IX ss.1, 3
GST/HST on doré and other non-qualifying gold
5% GST (s.165(1)), or HST in participating provinces; exports zero-rated where Sched VI Part V s.1 applies Doré, granules, scrap sold domestically; refining fees charged to metal owners
Primary lawAmount not confirmed
- Excise Tax Act, s.165(1), (2); Sched VI Part V s.1
Customs duty on gold (7108) and gold scrap (7112.91)
Free (MFN and every applicable preferential tariff, incl. UST, CPTPT, UKT) Doré, bullion, powder, semi-manufactures, monetary gold, gold scrap
Primary lawAmount not confirmed
- Customs Tariff, 7108.11-7108.20, 7112.91

Controls

S.C. 2026, c. 4 (Bill C-12, royal assent 26 Mar 2026) amended the PCMLTFA and the AMP Regulations: penalty ranges per violation $1 to $40,000 (minor), $1 to $4,000,000 (serious) and $1 to $20,000,000 (very serious) (AMP Regulations s.5, as amended by s.118), subject to the Act's maxima of $4,000,000…
Primary law
- PCMLTFA and PCMLTF AMP Regulations as amended by S.C. 2026, c. 4, Act ss.9.6(1.1), 73.1; SOR/2007-292 s.5
CBSA officers may enter premises where goods destined for export are reported, loaded or stored and examine them (Customs Act ss.97.01-97.02, added by S.C. 2026, c. 4, Part 1).
Primary law
- Customs Act, ss.97.01, 97.02
Extractive entities (listed in Canada, or meeting two of $20m assets, $40m revenue, 250 employees) must report and publish payments of $100,000 or more per category per payee to governments in Canada and abroad within 150 days after year end; keep records 7 years; fine up to $250,000 (ESTMA ss.8, 9,…
Primary law
- Extractive Sector Transparency Measures Act, ss.8, 9, 13, 24
A DPMS receiving $10,000 or more in cash in a single transaction must file a large cash transaction report (unless from a financial entity or public body); amounts received within 24 consecutive hours from or for the same person are aggregated.
$10,000 cash
Primary lawAmount not confirmed
- PCMLTF Regulations, ss.66, 126
No exchange control or export-proceeds repatriation requirement identified.
Unverified
Since 2025 the Ontario Minister may suspend MLAS access, prohibit or terminate prospector's licences, deny leases and (with Lieutenant Governor in Council approval) cancel claims or terminate leases for the protection of the strategic national mineral supply chain.
Primary law
- Ontario Mining Act, ss.4.1(8)-(14), 26.1, 81(1.1), 176.1
No legal cap on cash payments for gold is in force. Bill C-2 (Strong Borders Act, first reading 3 Jun 2025) Part 11 would add PCMLTFA s.77.5 making it an offence for a person or entity engaged in a business to accept a cash payment, donation or deposit of $10,000 or more (single or prescribed relate…
$10,000 (proposed)
Primary lawAmount not confirmed
- Bill C-2 (not enacted), proposed PCMLTFA s.77.5
Travellers must declare currency or monetary instruments of CAN$10,000 or more; gold bullion is not a monetary instrument and moves as goods through customs.
CAN$10,000
Primary lawAmount not confirmed
- Cross-border Currency and Monetary Instruments Reporting Regulations, ss.1, 2
Dealers in precious metals and precious stones are PCMLTFA reporting entities for purchases or sales of $10,000 or more (compliance program, KYC, beneficial ownership, PEPs, records kept at least five years, STR, LCTR, LVCTR, listed-person property and sanctions-evasion reports). Excluded: purchases…
$10,000 per purchase or sale
Primary lawAmount not confirmed
- PCMLTF Regulations, ss.1(2), 65, 148
Export reporting (not licensing): non-monetary gold must be declared through CERS/G7 EDI when worth CAD 2,000+ and going anywhere but the US; exports to the US of non-restricted goods are exempt.
CAD 2,000; US destinations exempt
Primary lawAmount not confirmed
- Customs Act s.95; Reporting of Exported Goods Regulations, REGR ss.3, 6(b), 7
Tariff item 9897.00.00 prohibits importation of "Goods manufactured or produced wholly or in part by prison labour" and "Goods mined, manufactured or produced wholly or in part by forced labour or child labour as those terms are defined in section 2 of the Fighting Against Forced Labour and Child La…
Primary law
- Customs Tariff, Schedule, tariff item 9897.00.00
Canada hosts three LBMA Good Delivery gold refiners: Royal Canadian Mint (Ottawa, listed ~1919), CCR Refinery - Glencore Canada Corporation (Montreal East, ~1956) and Asahi Refining Canada Limited (Brampton, 15/06/1961). Output is accepted in London; Asahi and the Mint also state COMEX acceptance.
Standard
Gold is not on the Export Control List: no export permit, licence or state approval is required to export gold, and no state buyer or export monopoly exists.
Primary law
- Export and Import Permits Act; Export Control List, EIPA s.13; SOR/89-202
Every Ontario patent, lease or other disposition of lands, claims or mining rights is subject to the condition that "all ores or minerals raised or removed therefrom shall be treated and refined in Canada so as to yield refined metal or other product suitable for direct use in the arts without furth…
Primary law
- Ontario Mining Act, s.91
No person in Canada or Canadian abroad may export, sell, supply or ship unwrought (710812) or semi-manufactured (710813) gold, wherever situated, to Russia or to any person in Russia (Schedule 6 Part 1 items 176-177; also jewellery and other listed articles). Exception: personal effects.
Primary law
- Special Economic Measures (Russia) Regulations, s.3.08, Schedule 6 Part 1 items 176-177
Persons in Canada and Canadians abroad may not import, purchase or acquire any Schedule 9 good from Russia or from any person in Russia: gold powder (710811), other unwrought (710812), semi-manufactured (710813), monetary gold (710820), jewellery (711319) and goldsmiths' wares (711419) of precious m…
Primary law
- Special Economic Measures (Russia) Regulations, s.3.11, Schedule 9
No person in Canada or Canadian abroad may import, purchase or acquire Schedule 13 goods, wherever situated, from Russia or a person in Russia; Schedule 13 item 137 is heading 7112 (waste and scrap of precious metal). Added by SOR/2025-143.
Primary law
- Special Economic Measures (Russia) Regulations, s.3.16, Schedule 13 item 137
Entities producing, selling or distributing goods, or importing goods, that are listed in Canada or meet two of $20m assets, $40m revenue, 250 employees must report to the Minister by May 31 each year on steps taken to prevent forced and child labour in their supply chains (S.C. 2023, c. 9, ss.2, 9,…
Primary law
- Fighting Against Forced Labour and Child Labour in Supply Chains Act, ss.9, 11

Leg 3: United Arab Emirates

Where the goods arrive

24
Pre-contract KYC on the Nigerian exporter: corporate docs, UBO, MBC/export-permit evidence, mine-of-origin declaration
Who
DMCC importer / trader
Needs
Bank-to-bank reference confirmation (not a public letter) on the Nigerian exporter
Issues
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
Official guidance
[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)
25
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
Who
DMCC importer / trader
Needs
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
Issues
Dubai Customs declaration filed online (for goods entering a free zone: "FZ Transit In"); Disclosure of precious metals crossing the UAE border (cargo included)
Official guidance
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)
26
Import VAT: registered importer accounts for VAT on its own return (reverse charge); investment-grade gold is zero-rated, doré is not
Who
DMCC importer / trader
Issues
Import VAT accounted on the importer's own VAT return (registered importer)
Primary law
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)
27
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)
Who
DMCC importer / trader
Issues
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
Primary law
[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)
28
Deposit refined bars into DMCC Vault (operated by Brink's)
Who
DMCC Vault (operated by Brink's)
Needs
Manufacturer certificate accompanying UAEGD bars (states year of manufacture if not stamped)
Issues
DMCC Vault deposit/withdrawal receipt; DMCC Tradeflow warrant (optional; used for pledging and title transfer)
Official guidance
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.
29
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
Who
DMCC importer / trader
Needs
Refiner outturn/assay report; Commercial invoice
Issues
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
Secondary
[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

Taxes and fees

Customs duty on gold imports
0% for goods entering a free zone (FZ Transit In); mainland imports of gold: 0% under the GCC exempted-commodities list (read via WebFetch only) Unwrought and semi-manufactured gold
Official guidanceAmount not confirmed
- Dubai Customs Customer Guide v3.03; GCC common customs law; UAE list of exempted commodities, Customer Guide s.9 (duty suspended for goods admitted into free zones), s.15.12.2
Domestic reverse charge on precious metals and precious stones between registered businesses
Recipient accounts for VAT Supplies of gold, silver, platinum, palladium, precious stones and jewellery made of them, for resale or production, between VAT-registered persons, with the buyer's written declaration (CD 127/2024, replacing CD 25/2018)
Primary law
- Cabinet Decision 127/2024; FTA VATP043, Art. 1 (Goods: precious metals - gold, silver, palladium, platinum - precious stones and jewellery mostly of them), Art. 2(1)-(4), Art. 4 (repeals CD 25/2018)
  “Precious Metals, Precious Stones and jewelry made of any Precious Metals or Precious Stones”
Special reverse charge on gold and diamonds between registrants (Cabinet Decision 25/2018)
Registered recipient accounts for VAT Gold and products mostly of gold not qualifying for zero-rating, and diamonds, supplied between registrants; exports of gold items and investment precious metals outside its scope (VATP029)
Official guidance
- Cabinet Decision No. 25 of 2018
Import VAT
5% standard; 0% for investment precious metals (99%+ purity, tradeable form) Doré is not investment gold, so it is standard-rated; refined bars of 99%+ are zero-rated
Primary lawAmount not confirmed
- Federal Decree-Law 8/2017 on VAT; Executive Regulation, Art. 3 (5%), 45(8), 48(1), 49; Exec. Reg. Art. 36(2), 48, 50(1)
  “a standard rate of 5% Tax shall be imposed on any supply or Import”

Controls

Precious metals crossing the UAE border must be disclosed; declarations are also required for precious metals over AED 60,000 crossing through cargo, mail or shipments, cargo being declared through the official customs systems.
AED 60,000
Primary lawAmount not confirmed
- Federal Decree-Law 10/2025; CBUAE Regulation on the Declaration of Currencies, BNIs, and Precious Metals and Stones (OG 703, 31 May 2021), FDL 10/2025 Art. 10 (duty to disclose, per the disclosure system issued by the ICP with the Central Bank), Art. 41(3) (regulations under FDL 20/2018 remain effective insofar as not conflicting), Art. 34 (penalty)
  “Any person entering into or departing from the State shall be under the obligation to make a disclosure whenever they carry currencies, bearer negotiable instruments, precious metals, or valuable stones, in accordance with the disclosure system issued by the Federal Authority for Identity, Citizenship, Customs and Port Security, in coordination with the Central Bank”
Dealers in precious metals and stones are DNFBPs for any single cash transaction, or linked transactions, of AED 55,000 or more (CR 134/2025 Art. 3 item 3), and keep records for at least 5 years (Art. 25). The DPMSR report, including for dealings with companies of AED 55,000 or more paid in cash or …
AED 55,000
Primary law
- Cabinet Resolution 134/2025; MoET Supplemental Guidance for DPMS 2026, CR 134 Art. 3(3), Art. 25(1); Guidance s.1.4.1
  “when carrying out any single cash transaction or several transactions that appear to be linked and whose value equals or exceeds fifty-five thousand dirhams (AED 55,000)”
Supply-chain entities and precious-metals dealers must have due-diligence management systems, identify and assess supply-chain risks and adopt a risk-management strategy (Decree Art. 1(A)); refiners must also appoint an independent third-party auditor and submit a due-diligence report (Art. 1(B)), u…
Primary law
- Ministerial Decree 68/2024; MoE Due Diligence Regulations v1 (2022), Decree Art. 1(A), 1(B), Art. 3 (penalties under the AML law)

Leg 4: Zimbabwe

Back in the origin country: the proceeds of the export

30
Receive payment within three months (90 days) from export or when contractually due
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Issues
Receipt of export proceeds
Primary law
- Exchange Control Regulations SI 109/1996; Exchange Control (General) Order SI 110/1996; RBZ FX Guidelines FXD5/2026, Regulations ss.5, 21; General Order s.13(2) ('within three months from the date of export'); Guidelines para 3.2.2
31
Pre-acquit the Form CD1 within 48 hours of receiving the proceeds
Who
Authorised dealer bank
Issues
CD1 acquittal (proceeds received)
Official guidance
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.7
32
Sell 30% of gross proceeds to the RBZ at the weighted-average willing-buyer willing-seller interbank rate; the exporter keeps 70% indefinitely (50% surrender where proceeds were overdue)
Who
Authorised dealer bank
Issues
Sale of 30% surrender portion to RBZ at the WBWS interbank rate
Official guidance
[unconfirmed] Whether the general 30% surrender applies to FGR's own gold export proceeds is not stated. The February 2026 MPS (para 233) keeps 70% retention for all sectors 'with the exception of small-scale gold producers, whose retention shall be 90%'.
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026); FXD5/2026, FXG para 3.2.3; FXD5 para 2.2

Crossings between countries

Zimbabwe → Canada Not researched
Papers that cross: CEPECS exporter registration; Gold Export Certificate; Assays supporting the RBZ export application; Pro-forma invoice: quantity, price and total value of gold to be exported (FXG 3.2.30); RBZ gold export approval (approval reference number on the Document Management System); CEPECS Form CD1 (exchange control export form); Customs export bill of entry (Form 21, lodged in ASYCUDA World); ZNCC certificate of origin for the gold consignment; Air waybill
Canada → United Arab Emirates Not researched
Papers that cross: Commercial invoice from the foreign shipper; Commercial Accounting Declaration; Refiner outturn assay and settlement statement; Bar list of refined bars (GD 400 oz, 100 oz, kilobars); CERS export declaration and proof of report number; Air waybill

Paperwork gaps

ae.st-18 expects Packing list; the earlier legs don't model this paper