Burkina Faso [SONASP single export window (ASM gold)] → Russian Federation (refine) → United Arab Emirates · Reconcile assays and pay the balance

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

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Burkina Faso (Doré bar - unstamped → Doré bar - stamped/exporter-sealed) ⟶ Russia (Doré bar - stamped/exporter-sealed → 999.9 kilobar) ⟶ United Arab Emirates (999.9 kilobar)

Not researched: Burkina Faso → Russia

Leg 1: Burkina Faso

Where the goods start

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

1
SONASP exports ASM gold itself: comptoirs may only sell to it; special export authorisations (ASE) for gold are issued by the Secrétariat permanent du guichet unique du commerce et de l'investissement
Who
SONASP (state gold buyer and single ASM export window)
Needs
SONASP purchase record / receipt at a buying window
Issues
Special export authorisation (ASE)
Official guidance
[inferred] no text read names SONASP as sole exporter; it follows from sales being restricted to comptoirs or the public buyer and comptoirs having no export right; [not-read] legal basis of the ASE (273 issued in 2023 per the BNAF report) not found.
- Loi 016-2024/ALT; Décret 2025-0348, Code Arts 241, 251, 254; Décret Arts 29, 31
2
Obtain the Minister of Finance's prior authorisation to export gold
Who
SONASP (state gold buyer and single ASM export window)
Issues
Minister of Finance prior authorisation to export gold (UEMOA)
Primary law
[inferred] SONASP is not in the Art. 20 exemptions (Treasury, BCEAO, low-gold articles, travellers' objects up to 500 g).
- Règlement 06/2024/CM/UEMOA, Art. 20; Annex X
3
Domicile the export with an authorised intermediary (exports above FCFA 20 million) and sign the engagement de change
Who
SONASP (state gold buyer and single ASM export window)
Needs
Commercial invoice
Issues
Export domiciliation file at an authorised intermediary bank; Engagement de change (exports)
Primary law
- Instruction 03/07/2025/RFE, Arts 3-5
4
Have BUMIGEB control the weight and composition of the ingots; each ingot is referenced and marked with the official Burkina Faso hallmark and a control certificate issued on the spot; samples of products for export are lodged with the national laboratory
Who
SONASP (state gold buyer and single ASM export window)
Issues
BUMIGEB control certificate for ASM or semi-mechanised gold ingots (with official hallmark)
Primary law
[inferred] Art. 19 names ANEEMAS, SONASP's predecessor, as requester; the BNAF report records 391 ASM ingots (50,571 g fine) controlled by BUMIGEB in 2023.
- Décret 2018-0970; Loi 016-2024/ALT, Décret Arts 15, 19-22; Code Art. 45
5
Prepare commercial invoice and packing list; have the bank stamp the attestation d'exportation; seal the consignment
Who
SONASP (state gold buyer and single ASM export window)
Issues
Commercial invoice; Packing list; Attestation d'exportation de biens
Form
Doré bar - unstamped → Doré bar - stamped/exporter-sealed
Primary law
Attestation from Instruction 03/07/2025 Art. 6; [unconfirmed] invoice and packing-list content for SONASP exports is practice.
- Instruction 03/07/2025/RFE, Art. 6
6
Lodge the detailed customs export declaration at the export office on arrival of the goods and present the gold with the attestation d'exportation; customs completes the attestation and sends copies to the bank, BCEAO and the external-finance department within 8 days
Who
SONASP (state gold buyer and single ASM export window)
Needs
Minister of Finance prior authorisation to export gold (UEMOA); Export domiciliation file at an authorised intermediary bank; Engagement de change (exports); Attestation d'exportation de biens; BUMIGEB control certificate for ASM or semi-mechanised gold ingots (with official hallmark); Commercial invoice; Packing list
Issues
Customs export declaration (Burkina Faso)
Primary law
[unconfirmed] gold-specific customs annexes and the declaration form were not found.
- Code des douanes 2025; Règlement 06/2024/CM/UEMOA, Code Arts 101, 122-125; Règlement Annex II Arts 21-23
7
Obtain a certificate of origin if the buyer requires it
Who
SONASP (state gold buyer and single ASM export window)
Issues
Certificate of origin (Burkina Faso)
Unverified
Issuer and requirement not found.
8
Accept the consignment as valuable cargo and issue the air waybill
Who
Valuables carrier / airline
Needs
Customs export declaration (Burkina Faso); Packing list
Issues
Air waybill
Primary law
[unconfirmed] carrier practice (valuable cargo, air waybill) is generic.
- Code des douanes 2025, Arts 103-104

Taxes and fees

Fixed fees and annual flat royalty for artisanal exploitation authorisations (gold)
Grant FCFA 1,000,000; renewal FCFA 1,500,000; annual flat royalty FCFA 2,000,000
Primary lawAmount not confirmed
- Décret 2025-0331, Art. 12
Royalty on artisanal gold sold to comptoirs
FCFA 100 per gram Gold of artisanal production
Primary lawAmount not confirmed
- Décret 2025-0331, Art. 19
Proportional royalty on gold, 2017 scale
3% below USD 1,000/oz; 4% USD 1,000-1,300; 5% above USD 1,300 ("London Metal Exchange (LME)" price); export through the State structure taxed at FCFA 200/g Gold
Primary lawAmount not confirmed
- Décret 2017-0023, Art. 14
Proportional royalty on gold, 2023 bands
3% below USD 1,000/oz; 4% 1,000-1,300; 5% 1,300-1,500; 6% 1,500-1,700; 6.5% 1,700-2,000; 7% above 2,000 Industrial gold
SecondaryAmount not confirmed
- Décret n°2023-1454 of 27 Oct 2023 (amending Décret 2017-0023)
Proportional royalty on gold (redevance proportionnelle), 2025 bands
3% below USD 1,000/oz; 4% 1,000-<1,300; 5% 1,300-<1,500; 6% 1,500-<1,700; 6.5% 1,700-<2,000; 7% 2,000-<3,000; from USD 3,000/oz add 1% for each USD 500 Gold from industrial and semi-mechanised mines and residue treatment
Primary lawAmount not confirmed
- Décret 2025-0331; Loi 016-2024/ALT, Décret Arts 4, 18-21; Code Arts 156, 159
Contribution to the Fonds minier de développement
1% of monthly turnover excluding tax
Primary lawAmount not confirmed
- Loi 016-2024/ALT, Arts 28-29
Taxe superficiaire
Large mine FCFA 10,000,000/km²/yr (years 1-5), 15,000,000 (6-10), 20,000,000 (11+); small mine 4,000,000/7,000,000/10,000,000; semi-mechanised 1,500,000 (year 1), 3,000,000 after; AEA 1,500,000
Primary lawAmount not confirmed
- Décret 2025-0331; Loi 016-2024/ALT, Décret Arts 7, 8, 16, 21; Code Art. 158

Controls

UMOA AML thresholds (Décision n°021/CM/UMOA of 21 Dec 2023): traders in goods become designated non-financial businesses when they make or receive cash payments of FCFA 5,000,000 or more (Art. 2); they identify occasional customers and beneficial owners above FCFA 9,000,000 (Art. 5(a)); cash or be…
FCFA 5m (cash, DNFBP status); 9m (identification); 15m (cash reporting)
Primary lawAmount not confirmed
- Décision n°021/CM/UMOA du 21 décembre 2023, Arts 2, 4, 5, 8
Resident travellers to non-UEMOA states declare foreign-currency cash above FCFA 3 million equivalent (Art. 4) and may take FCFA notes up to FCFA 500,000 (Art. 6); non-residents declare in writing, on entry and exit, foreign-currency cash above FCFA 500,000 (Art. 7) and may take out more only agains…
FCFA 3,000,000 (residents, foreign cash out of UEMOA); FCFA 500,000 (non-residents)
Primary lawAmount not confirmed
- BCEAO Instruction 06/07/2025/RFE, Arts 4-8, Annex
[time-limited] Repealed version (Règlement 09/2010 and Instruction 05-07-2011/RFE, replaced 1 Aug 2025): travellers declared foreign currency above FCFA 1 million equivalent.
FCFA 1,000,000
Primary lawAmount not confirmed
- Règlement 09/2010/CM/UEMOA, Annex II
Mining title holders must use the national site-security structure (ONASSIM) for securing their activities and sites, including transfers of mining products (Décret 2025-0378 Arts 2-4).
Primary law
- Décret 2025-0378, Arts 2-4
[time-limited] Repealed version (Règlement 09/2010/CM/UEMOA and Instruction 03-07-2011/RFE; replaced 20 Dec 2024 / 1 Aug 2025): domiciliation of exports above FCFA 10 million; repatriation within one month of the due date.
FCFA 10 million
Primary lawAmount not confirmed
- Règlement 09/2010/CM/UEMOA, Annex II
State takes 15% free shares in industrial mining companies with priority dividend and may subscribe at least 30% more; 20% free shares in semi-mechanised companies; State and Burkinabè holdings cannot be diluted. Five Endeavour/Lilium assets (Boungou, Wahgnion, three exploration companies) were nat…
Primary law
- Loi 016-2024/ALT; Décret 2025-0302, Code Arts 66-67; Décret Arts 9, 12-22
Burkina Faso was removed from FATF increased monitoring on 24 Oct 2025. The AML/CFT law is Loi n°046-2024/ALT of 30 Dec 2024, which replaced Loi 016-2016/AN (neither text held); BNAF supervises dealers in precious metals (Décret 2023-1308, as cited); an agrément can be withdrawn for AML failures …
Standard
[time-limited] Repealed regime (Loi 028-2017/AN, repealed by the 2024 Code on 31 Jul 2024): comptoir agréments covered buying, selling and exporting ASM gold (Art. 22); semi-mechanised permits allowed sale abroad (Art. 27); the ASM agency ANEEMAS ran a single window that bought and exported gold, i…
Primary law
- Loi 028-2017/AN, Arts 14, 22, 27
Gold refined in Burkina Faso is 24 carats (99.99%) (Décret 2025-0379 Art. 2); refineries stamp each bar with seal, weight, fineness and serial number and have bars controlled by the national geological service before export (Décret 2025-0348 Art. 59).
Primary law
- Décret 2025-0379; Décret 2025-0348, 0379 Art. 2; 0348 Art. 59
Armed groups control or tax mining sites in the Sahel and East regions (ATI/SWISSAID; the MEMC/BNAF 2023 report also records armed groups' presence on sites and smuggling towards Lomé and Bamako); buyers should treat Burkinabè ASM gold as from a conflict-affected and high-risk area under the OECD …
Secondary
Comptoirs buy gold only in the legal tender of Burkina Faso (FCFA) (Décret 2025-0348 Art. 28).
Primary law
- Décret 2025-0348, Art. 28
Industrial permit holders transform or add value to all or part of their output in Burkina Faso; the proportion is fixed by arrêté of the Minister of Mines; refined gold is 24 carats (99.99%); derogation when transformation is not possible; six months to comply.
Primary law
- Loi 016-2024/ALT; Décret 2025-0379, Code Art. 70; Décret Arts 2-3, 5, 7
Import and export of gold need the prior authorisation of the Minister of Finance, requested by letter (Annex X). Exempt: Treasury and BCEAO; articles with little gold; travellers' gold objects up to 500 g (Art. 20). Annex X also exempts mining companies holding an exploitation and export licence fr…
Primary law
- Règlement 06/2024/CM/UEMOA, Art. 20; Annex X
Possessing, transporting, buying, selling or exporting gold without a valid title, selling ASM gold to anyone but comptoirs or the public buyer, importing or exporting gold without declaration, and pouring, weighing or packing industrial or refined gold without the administration's representative: s…
Primary law
- Loi 016-2024/ALT; Loi 003-2025/ALT (Code des douanes), Code minier Arts 265-266, 273; Code des douanes Arts 23, 436, 438, 450
Each ASM or semi-mechanised gold ingot controlled by BUMIGEB is referenced and marked with the official Burkina Faso hallmark; a control certificate is issued (Décret 2018-0970 Arts 20-21). Gold traded must be in coins, ingots or assayed bars (Code Art. 235).
Primary law
- Décret 2018-0970; Loi 016-2024/ALT, Décret Arts 20-21; Code Art. 235
A natural person (other than agrément, permit or authorisation holders and established jewellers) may hold up to 500 g of raw gold without declaration, must declare above 500 g, and may not hold more than 2,000 g; savings purchases up to 2,000 g only from ANEEMAS (now SONASP), deposited in a bank a…
500 g without declaration; 2,000 g maximum
Primary lawAmount not confirmed
- Décret 2018-0969; Loi 016-2024/ALT, Décret Arts 2-4; Code Art. 242
The State has a pre-emption right over gold commercialisation from industrial, semi-mechanised and artisanal production, exercised by the Treasury or the public buyer (Code Art. 237); to build the national gold reserve the State notifies the producer, and producers must sell the requested quantities…
Primary law
- Loi 016-2024/ALT; Décret 2025-0414, Code Art. 237; Décret Art. 5
Exports above FCFA 20 million are domiciled with an authorised intermediary; proceeds are repatriated within one month of the due date, itself within 120 days of shipment; the bank repatriates at least 80% via BCEAO correspondent accounts and surrenders the currency; temporary gold exports above 500…
FCFA 20 million (domiciliation); 500 g (temporary gold exports)
Primary lawAmount not confirmed
- Instruction 03/07/2025/RFE; Règlement 06/2024/CM/UEMOA, Instruction Arts 2, 3, 7; Règlement Arts 5, 11, 21
Persons subject to targeted financial sanctions linked to money laundering or terrorist financing cannot obtain mining titles (Code Art. 41) or agréments for buying, selling, transforming, importing or exporting gold (Arts 239-240).
Primary law
- Loi 016-2024/ALT, Arts 41, 239-240
Artisanal and semi-mechanised gold may be sold only to comptoirs or the public buyer (SONASP) (Code Arts 241, 249, 251); comptoirs may only sell to the public buyer and have no export right (Décret 2025-0348 Arts 29, 31); industrial and refined gold sold in Burkina Faso goes to the State or the pub…
Primary law
- Loi 016-2024/ALT; Décret 2025-0348, Code Arts 241, 246, 249, 251, 261; Décret Arts 29, 31

Leg 2: Russia

On the way

Doré bar - stamped/exporter-sealed → 999.9 kilobar

9
File the FPP import-control application in GIIS DMDK with the foreign-trade contract, specification, document on precious-metal content and special-registration record
Who
Importer of gold-bearing material for refining (refiner or special-registered company)
Needs
Special-registration register entry (FPP); Assay certificate (fineness and fine weight); Commercial invoice
Issues
FPP application for import control
Primary law
- EEC Board Decision 30, Annex 14, Annex 2 (Rules) para 4(a), Rules para 4(a)
10
State control at a specialised customs post (all goods except ores and concentrates), within 5 working days; act of state control
Who
Federal Assay Chamber
Needs
FPP application for import control
Issues
Act of state control on import
Primary law
- Presidential Decree 1137 para 19¹; EEC Board Decision 30, Annex 14, Annex 2 para 10, para 19¹
11
Declare the goods at a specialised customs post for release or processing, presenting the act of state control, and take delivery to the refinery
Who
Importer of gold-bearing material for refining (refiner or special-registered company)
Needs
Act of state control on import
Issues
EAEU goods declaration for import / customs processing
Primary law
[not-read] Import duty and import VAT treatment of gold-bearing material not read.
- EEC Board Decision 30, Annex 14 paras 4, 8, Regulation para 8
12
Receive the lot, weigh, sample and assay; record receipt in GIIS DMDK
Who
Refining organisation on the Government list
Needs
ESD for dispatch of dore/placer gold to the refiner; Refining (tolling) agreement miner-refiner
Issues
Refiner receipt: weighing and sampling record; Refiner assay of the incoming lot (metallurgical balance)
Primary law
- Government Decree 972, Procedure paras 3, 7, paras 3, 7
13
Refine to standard bars (gold at least 995 fine; usually 999.9)
Who
Refining organisation on the Government list
Form
Doré bar - unstamped → 999.9 kilobar
Primary law
[unconfirmed] 999.9 as the usual fineness is market practice; the legal minimum for refined gold is 995 parts per 1,000 (41-FZ art. 1).
- 41-FZ art. 1 (definition of refining), art. 20(1), art. 1
14
Issue the quality document for each bar - a passport for a standard bar or a certificate for a measured bar (FPP Order 154n, to 28 Feb 2027); from 1 Mar 2027 a single certificate generated in GIIS DMDK (FPP Order 144n); prepare the bar list
Who
Refining organisation on the Government list
Issues
Passport for standard bar / certificate for measured bar of refined precious metal (FPP Order 154n; replaced by a single certificate under Order 144n from 1 Mar 2027); Bar list (serials, weights, fineness)
Primary law
- Government Decree 972, Procedure para 7¹; FPP Orders 154n and 144n, para 7¹
15
Deliver bars to the owner (or to the buyer on the owner's instruction) with a GIIS DMDK ESD; metal is booked on the owner's balance and enters civil circulation
Who
Refining organisation on the Government list
Needs
Passport for standard bar / certificate for measured bar of refined precious metal (FPP Order 154n; replaced by a single certificate under Order 144n from 1 Mar 2027)
Issues
ESD for shipment of refined bars to the owner or buyer
Primary law
- Federal Law 41-FZ, art. 20(3)
16
Screen buyer and destination: Russian-origin gold exported after the sanctions dates cannot be imported into the EU, UK, US, Switzerland or Japan, and Russian bars made from 7 Mar 2022 are not LBMA Good Delivery; sales go to non-sanctioning markets
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Primary law
17
Sign the export contract and issue the commercial invoice
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Issues
Export contract with foreign buyer; Commercial invoice
Primary law
18
Apply to Minpromtorg for an export licence (one-off for a contract, or a general licence under Decree 1126 or 867); Minfin approves the application in GIIS DMDK within 10 working days (Order 10n from 1 Sep 2026), except credit organisations' applications for refined gold, silver, platinum and palladium bars since 8 May 2026
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Needs
Export contract with foreign buyer; Special-registration register entry (FPP)
Issues
Minfin conclusion (permissive document) approving an export-licence application (Order 10n from 1 Sep 2026); EAEU export licence issued by Minpromtorg (one-off or general)
Primary law
Licence validity and issue time from EEC Council Decision 125 Rules paras 9 and 13: a one-off licence is valid up to 1 year from its start (may be limited to the contract term); a general licence up to 1 year; the licensing authority decides within 15 working days of receiving the documents unless the Commission decision introducing the measure sets another term. [unconfirmed] Decision 125's own in-force date depends on the Protocol of 25.05.2023 (see ru.law-eec-125).
- Presidential Decree 1137, Regulation paras 4 and 22; Minfin Order 10n, paras 4, 22
19
File the application letter for FPP state control through GIIS DMDK with: the export licence copy (table-1 goods), the contract, the specification, the invoice, the calculation of the value of the precious metals (within 5% of world prices), special-registration record or bank licence, proof of lawful ownership, the precious-metal content document, technical documentation, the subsoil licence (mining subjects) and the document on the State Fund's refusal to buy (mining and producing subjects)
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Needs
EAEU export licence issued by Minpromtorg (one-off or general); Export contract with foreign buyer; Commercial invoice; Document on the authorised bodies' refusal (non-exercise) to purchase; Passport for standard bar / certificate for measured bar of refined precious metal (FPP Order 154n; replaced by a single certificate under Order 144n from 1 Mar 2027)
Issues
Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK; Calculation of the value of precious metals in the consignment
Primary law
[transcription] EEC Board Decision 30 read in the ConsultantPlus copy published by the FPP; the FPP list reproduces the same paragraph.
- EEC Board Decision 30, Annex 14, Annex 2 (Rules) para 4(b); Minfin Order 11n (valuation), Rules para 4(b)
20
State control of the whole consignment within 5 working days: check against documents, origin, compliance with transaction rules, valuation, optional sampling; issue the act of state control (3 copies; the first for customs) or a refusal
Who
Federal Assay Chamber
Needs
Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK
Issues
Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber
Primary law
- EEC Board Decision 30, Annex 14, Annex 2 (Rules) paras 3, 8, 10; 41-FZ art. 26², Rules para 10
21
Lodge the export declaration at a specialised customs post, presenting the export licence and the act of state control
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Needs
EAEU export licence issued by Minpromtorg (one-off or general); Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber; Commercial invoice
Issues
Export goods declaration (accepted and released by customs); Certificate of origin (general form) for non-EAEU destinations
Primary law
[not-read] The customs rules on the declaration itself were not read.
- EEC Board Decision 30, Annex 14 paras 4-5; Presidential Decree 1137 para 19¹, Regulation paras 4-5
22
Carry the sealed consignment to the airport and hand to the airline (valuable cargo)
Who
Secure carrier of valuables
Needs
Export goods declaration (accepted and released by customs)
Issues
Packing list; Air waybill
Unverified
The armed-escort rule (41-FZ art. 29(3)) covers transport to the airport; no rule on the hand-over to the airline was read.
- Federal Law 41-FZ, art. 29(3)

Taxes and fees

VAT on precious metals
0% on sales of precious metals by mining or producing taxpayers to the State Fund, regional funds, the Bank of Russia and banks (art. 164(1)(6)); 0% on goods exported under the export customs procedure (art. 164(1)(1)); 0% on ores and concentrates sold by miners to listed refiners for refining (art. 164(1)(6³)); exempt: sales of precious metals to the State Fund, CBR and banks by others, bank and CBR sales of bars to banks, sales of refined bars (except silver) by banks, refiners and Goznak to individuals, and bank sales of bars kept in the vault (art. 149(3)(9)); exempt: legal-tender precious-metal coins (art. 149(2)(11))
Primary lawAmount not confirmed
- Tax Code Part Two, ch. 21, arts. 149(2)(11), 149(3)(9), 164(1)(1), (6), (6³)

Controls

FPP state control of every import from and export to non-EAEU states of goods in tables 1 and 3 of section 2.10 (41-FZ art. 26²; Decree 1137 para 19(b)): the whole batch is presented (for ores and concentrates, HS 2616, the documents only) and controlled within 5 working days; checks of the batch a…
Primary law
- EEC Board Decision 30, Annex 14, Annex 2 (Rules) paras 3, 4, 7, 8, 10; Presidential Decree 1137 paras 19, 19¹, Rules paras 3, 10
From 1 May 2026 export from Russia of refined gold in bars with a total weight over 100 g by individuals, legal entities and entrepreneurs is prohibited, except (a) to EAEU member states through the international airports Moscow (Vnukovo), Moscow (Domodedovo), Moscow (Sheremetyevo) and Vladivostok (…
Total weight over 100 g
Primary lawAmount not confirmed
- Presidential Decree 193 of 25.03.2026; Government Decree 450 of 23.04.2026, para 2, para 4
Purchase and sale of precious metals (and jewellery and scrap) of RUB 1,000,000 or more is subject to mandatory control and reported to Rosfinmonitoring by the seller within 3 working days; individuals buying jewellery up to RUB 60,000 (RUB 400,000 with a personalised e-payment means) are not identi…
RUB 1,000,000
Primary lawAmount not confirmed
- Law 115-FZ, art. 6(1)(4) sixth paragraph; art. 7(1.4-2)
Only listed refiners, Goznak and credit organisations may sell refined (investment) bars to individuals, and retailers only bars received on commission or agency from them; buy-back dealers and pawnshops may pass bars bought from individuals only to refiners. Deals between individuals in precious me…
Primary law
- Government Decree 604 of 15.05.2024 (Rules paras 3-4, 8); 41-FZ art. 22(6), Rules para 4
No gold-specific cash-payment limit was found. The RUB 1,000,000 mandatory-control threshold applies whatever the means of payment.
Unverified
Export to non-EAEU states of goods in tables 1 and 2 of section 2.10 of the EAEU Single List (table 1 includes refined gold in bars, plates, powder and granules, unique and non-refinable nuggets, other unwrought gold incl. dore, scrap, ores and concentrates) requires a licence issued by Minpromtorg …
Primary law
- Presidential Decree 1137 (Regulation paras 4, 22, 23); EEC Board Decision 30, Annex 14 para 5; Minfin Order 10n, paras 4, 22, 23
Residents must receive export proceeds on their accounts in authorised banks (173-FZ art. 19(1)(1)). Under art. 19(8) this does not apply to contracts priced or payable in foreign currency, except for goods listed there; the list includes HS 7101-7103 and 7112 but not 7108 (gold). Where art. 19 appl…
Primary law
- Federal Law 173-FZ art. 19; Presidential Decrees 79 (para 2) and 430, art. 19(1), (8)
Traceability: participants must record precious-metal operations in GIIS DMDK, with UINs and electronic accompanying documents between participants; refiners report receipt and shipment of metal in any form.
Primary law
- 41-FZ art. 12², art. 20(2); Government Decree 270 of 26.02.2021, art. 12²
Refined metal in standard form must, before it enters circulation, be offered by a purchase proposal to the State Fund institution under Minfin and to the authority of the mining region (where a regional fund exists) - for the next year by 31 December, with an additional proposal within 10 working d…
Primary law
- Federal Law 41-FZ, art. 2(5), art. 20(4)-(5)
LBMA suspended six Russian refiners on 7 Mar 2022; their bars produced from that date are not Good Delivery; Russian bars already in loco London/Swiss before then remain Good Delivery, with clearing banks attesting conformity.
Standard
Mined and produced precious metals (except nuggets) must, after the necessary processing, go for refining to organisations on the Government list (41-FZ art. 20(1)); only listed organisations may refine (art. 4(4)); the refining agreement's mandatory terms and the refiner's reporting duties are set …
Primary law
- Federal Law 41-FZ, art. 20(1)
Switzerland: purchase, import, transit and transport into and through Switzerland of gold under Annex 26 (includes HS 7108) originating in Russia and exported from Russia after 4 August 2022 are prohibited (Art. 14d(1)); the same applies to such gold processed in a third country (Art. 14d(2)) and, s…
Primary law
- Swiss Ukraine Ordinance SR 946.231.176.72 (Stand 21.09.2026), Art. 14d
EU: it is prohibited to purchase, import or transfer, directly or indirectly, gold listed in Annex XXVI (HS 7108; 7112 91 gold waste and scrap; ex 7118 90 gold coins) that originates in Russia and was exported from Russia into the Union or to any third country after 22 July 2022 (art. 3o(1)); the sa…
Primary law
- Regulation (EU) 833/2014 as amended by 2022/1269, art. 3o
Japan: import of precious metals originating in Russia and shipped from Russia on or after 1 August 2022 requires the Minister of Finance's permission under FEFTA art. 19(2) (MOF Notice No 443 of 2006 as amended 25 July 2022, item 4); the government announced it on 5 July 2022 as an import ban.
Primary law
- MOF Notice No 443 of 2006 as amended 25 Jul 2022, item 4
UK: import of gold originating in Russia and exported from Russia on or after 21 July 2022 is prohibited (reg 46Z11, Chapter 4J inserted by SI 2022/850, in force 21 Jul 2022), with prohibitions on acquisition with intent to import, supply and delivery, technical assistance, financial services and br…
Primary law
- Russia (Sanctions) (EU Exit) Regulations 2019, regs 46Z11-46Z16, 46Z16A-46Z16C
US: import of gold of Russian Federation origin is prohibited from 28 Jun 2022, except gold located outside Russia before that date (OFAC determination under E.O. 14068 s. 1(a)(i)(A), amended version of 22 Dec 2023). U.S. persons may not deal with the Central Bank, the National Wealth Fund or the Mi…
Primary law
- E.O. 14068 and the OFAC determination; E.O. 14024 as amended by E.O. 14114, E.O. 14068 s. 1(a)(i)(A); E.O. 14024 s. 11
  “the importation into the United States of … products of Russian Federation origin”
Temporary ban from 1 June to 30 November 2026 on export from Russia of precious-metal waste and scrap (HS 7112) and electrical and electronic waste used mainly to recover precious metals (8549 21 000 0, 8549 29 000 0), with exceptions for samples of up to 500 g per batch exported by listed refiners …
Primary law
- Government Decree 558 of 16.05.2026, para 1
Legal entities, entrepreneurs and artist-jewellers operating with precious metals must be on the FPP special register kept in GIIS DMDK; those that should be registered and are not may not carry out operations (41-FZ art. 13¹(2)). Registration within 30 calendar days of state registration (Rules pa…
Primary law
- 41-FZ art. 13¹; Government Decree 1052 (Rules paras 2, 5), art. 13¹
Precious metals and products from them are transported by air, sea, inland water, rail or specialised equipped road vehicles under armed escort; raw materials with less than 1% gold (or 5% silver), jewellery, investment metals (within a weight limit set by the Government) and some other items may mo…
Primary law
- Federal Law 41-FZ, art. 29(3)

Leg 3: United Arab Emirates

Where the goods arrive

23
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)
24
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)
25
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)
26
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)
27
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.
28
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: Burkina Faso

Back in the origin country: the proceeds of the export

29
Collect and repatriate the export proceeds through the authorised intermediary within one month of the payment due date; the due date must fall within 120 days of shipment
Who
Authorised intermediary bank
Issues
Credit of export proceeds to the Burkinabè bank
Primary law
- Instruction 03/07/2025/RFE; Règlement 06/2024/CM/UEMOA, Instruction Art. 7; Règlement Art. 11
30
The domiciling bank repatriates at least 80% of the proceeds through BCEAO correspondent accounts and surrenders the currency to the BCEAO
Who
Authorised intermediary bank
Primary law
[unconfirmed] mining conventions may allow offshore accounts; not checked.
- Instruction 03/07/2025/RFE; Règlement 06/2024/CM/UEMOA, Instruction Art. 7; Règlement Art. 5, Annex II Art. 15
31
Clear (apurer) the export domiciliation file against the customs declaration and the proceeds; report files not cleared
Who
Authorised intermediary bank
Primary law
- Instruction 03/07/2025/RFE, Art. 8

Crossings between countries

Burkina Faso → Russia Not researched
Papers that cross: Special export authorisation (ASE); Minister of Finance prior authorisation to export gold (UEMOA); BUMIGEB control certificate for ASM or semi-mechanised gold ingots (with official hallmark); Commercial invoice; Packing list; Attestation d'exportation de biens; Customs export declaration (Burkina Faso); Certificate of origin (Burkina Faso); Air waybill
Russia → United Arab Emirates Researched
Papers that cross: FPP application for import control; Act of state control on import; EAEU goods declaration for import / customs processing; Refiner receipt: weighing and sampling record; Refiner assay of the incoming lot (metallurgical balance); Passport for standard bar / certificate for measured bar of refined precious metal (FPP Order 154n; replaced by a single certificate under Order 144n from 1 Mar 2027); Bar list (serials, weights, fineness); Minfin conclusion (permissive document) approving an export-licence application (Order 10n from 1 Sep 2026); EAEU export licence issued by Minpromtorg (one-off or general); Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK; Calculation of the value of precious metals in the consignment; Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber; Export goods declaration (accepted and released by customs); Certificate of origin (general form) for non-EAEU destinations; Packing list; Air waybill

Paperwork gaps

ru.st-31 expects Assay certificate (fineness and fine weight); the earlier legs don't model this paper