Sudan [private exporter (legal person), since 5 Nov 2025] → Kazakhstan → United Arab Emirates · Reconcile assays and pay the balance

Where the goods start

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

• Royalty (al-'awa'id al-jalila) on traditional (artisanal) gold mining

  10% of the product (in gold or cash); alternatively 20% of the ore produced Traditional (artisanal) gold mining under a traditional mining contract

  Primary lawAmount not confirmed

  • Traditional Gold Mining Regulation 2016, art.8; Schedule (art.20)

• Corporation tax on gold companies

  18% (reduced from 28%, 2024); USGS 2019 reported 15%

  SecondaryAmount not confirmed

• Royalty on gold (concession companies)

  5-7% of mineral value (2019 policy)

  SecondaryAmount not confirmed

  • Regulation on the Exploitation of Minerals 2016, arts.13(6), 15

• Community (social) responsibility contribution on gold producers

  4% in kind of tailings companies' gold output; 1% in cash of concession companies' gold production value (based on the previous year's output)

  Primary lawAmount not confirmed

  • MoF Decision No. 90 of 2021, ثالثاً

• Fee for transferring artisanal gold from mining areas to city markets

  Waived (2024)

  Secondary

• Licence and contract fees

  MMDA Schedule (SDG): mining contract application 3,000, issue 15,000, transfer/assignment 50,000; small mining contract 3,000 / 10,000 / 50,000; traditional mining contract application 3,000, issue 7,000, regularisation 40,000, new contract 15,000; certificates 100 (samples up to 20 kg), 500 (ore export), 200 (other). Traditional Gold Mining Regulation Schedule (SDG): traditional mining licence 3,000; contract fee 7,000 (well), 50,000 / 150,000 / 250,000 (small / medium / large pit); sieve licences 10,000 / 50,000 / 100,000; miner card 100. Exploitation Regulation 2016 (EUR): ore export certificate 500; sample export 100 per 20 kg; tailings-processing contract signing bonus and renewal SDG 5,000,000 each.

  Primary lawAmount not confirmed

  • MMDA 2015, s.20(1); Schedule

• Implicit levy: CBOS indicative price set USD 10/oz below the international price

  USD 10 per troy ounce

  Official guidanceAmount not confirmed

  • CBOS Circular 13/2026, items 1-3

• State share in concessions

  30% of concessions (reported); plus a reported '40% tax on any gold sold' (unexplained)

  SecondaryAmount not confirmed

  • MMDA 2015 s.27أ (2023); Circular 2/2025 ثالثاً

• Dealers in metals or precious stones are "non-financial institutions" under the AML/CFT Act 2014 when they conclude cash transactions above a threshold the Minister sets by decision (s.3): customer due diligence (s.5), record keeping and suspicious-transaction reports to the Financial Information Un…

  Cash transactions above the Minister's threshold (not found)

  Primary law

  • Anti-Money Laundering and Counter-Terrorist Financing Act 2014, s.3, s.5, s.6

• EU ban on selling, supplying, transferring or exporting mercury (CN 2805 40) and sodium cyanides (CN 2837 11) to Sudan, with related services; humanitarian exceptions; sodium cyanide contracts concluded before 15 Jul 2026 may be executed until 16 Jan 2027.

  Primary law

  • Council Regulation (EU) 2026/1724, art.1b

• Banks may not finance the purchase of gold and its tailings (CBOS 2026 policies, list of prohibited financing, item vii "شراء الذهب ومخلفاته"). Gold buyers and exporters must use own funds or foreign advance payments.

  Official guidance

  • CBOS monetary and financial policies for 2026

• Sudan is an active conflict zone with both SAF and RSF financing themselves from gold; downstream refiners following OECD/LBMA due diligence must treat all Sudanese gold as high-risk, including gold from state-owned producers now under UK sanctions. Sudan itself has no conflict-minerals law found.

  Secondary

• 2014 version: banks may not complete gold export banking procedures for any company exporting gold, including mining and tailings companies, without CBOS prior written approval (Circular 11/2014). Superseded in substance by the 2025-2026 approval rules (sd.ctl-export-approvals-2025).

  Official guidance

  • CBOS Circular 11/2014

• 14 Sep - 5 Nov 2025 (Circular 14/2025): purchase of free (artisanal) and tailings gold inside Sudan reserved to CBOS or its delegate; export reserved to CBOS alone and banned for any natural or legal person; purchases executed by Sudan Gold Refinery. Concession and small-mining companies stayed unde…

  Official guidance

  • CBOS Circular 14/2025, ثانياً 1-4

• Concession companies may export 70% of the output remaining after in-kind deduction of the government's zakat, royalty and profit shares, and must sell the other 30% to CBOS or its delegate whether or not they export; small-mining companies likewise (Circular 2/2025 ثالثاً). Earlier versions: …

  30% of net output (after in-kind government shares)

  Official guidanceAmount not confirmed

  • CBOS Circular 2/2025, ثالثاً-1(ب), ثالثاً-2(د)

• Every person entering or leaving Sudan must declare to customs the currency and bearer negotiable instruments carried, at amounts set by regulations (AML/CFT Act 2014 s.31(1)); customs may seize them on suspicion or false declaration (s.32); breach of s.31 is punished by a fine equal to twice the am…

  Primary law

  • Anti-Money Laundering and Counter-Terrorist Financing Act 2014, s.31, s.32, s.38(4)

• EU ban on purchasing, importing or transferring, directly or indirectly, gold (CN 7108, 7112 91, ex 7118 90) that originates in Sudan and was exported from Sudan into the EU or any third country after 15 July 2026, and on related technical assistance, brokering, financing and financial assistance. E…

  Primary law

  • Council Regulation (EU) 2026/1724, art.1a

• Approvals banks must see before completing a gold export: concession and small-mining gold - CBOS written approval, an SSMO certificate and a Ministry of Minerals export-approval certificate (Circular 2/2025 ثانياً); tailings gold - CBOS written approval (17/2025 ثالثاً-5; restated by 18…

  Official guidance

  • CBOS Circulars 2/2025 and 17/2025

• Free and tailings gold may be exported by any legal person (شخص اعتباري) after all export procedures (Circular 17/2025 ثالثاً-1); exports by government bodies and by foreigners, individuals or companies, are banned except concession companies in gold mining (خامساً-4). Individu…

  Official guidance

  • CBOS Circular 17/2025, ثالثاً-1; خامساً-4

• No export, including export for manufacture and return, of precious metals or gemstones as bars or jewellery without hallmarking by SSMO's Hallmarking and Precious Metals Control Department as regulations provide; imports need the Department's approval, assay and hallmark unless a mutual-recognition…

  Primary law

  • Precious Metals and Gemstones Act 2008, s.20; s.7

• 2014 directions: raw gold exports prohibited and company exports refined at the Khartoum refinery (historical). Current texts: CBOS purchases are executed by Sudan Gold Refinery with fineness set by SSMO (Circular 2/2025 رابعاً; 14/2025 ثانياً-4); exporters must comply with Sudan Gold Re…

  Official guidance

  • CBOS Circular 17/2025, خامساً-1

• Minimum gold export contract 10 kg "or as MoIT decides" (Circular 17/2025 خامساً-2, from 5 Nov 2025); replaced on 13 May 2026 by a 1 kg minimum for free-gold export contracts (Circular 11/2026 item 3).

  1 kg per free-gold contract since 13 May 2026 (10 kg, 5 Nov 2025 - 12 May 2026)

  Official guidanceAmount not confirmed

  • CBOS Circular 11/2026, item 3

• Payment by advance payment or by confirmed sight documentary credit whose terms contain no condition on the goods such as overseas assay ("calibration"); L/C proceeds on acceptance of documents and at most 30 days from shipment (Circular 17/2025 ثالثاً-2; same for small-mining companies under …

  Official guidance

  • CBOS Circular 17/2025, ثالثاً-2

• CBOS prices gold for export daily at the international 24-carat price less USD 10 per ounce, in USD per gram, announced on the XAR system to MoIT and the unified gold export window; exporters are settled at this price and no shipment passes if the proceeds fall below the value at the announced price…

  Official guidance

  • CBOS Circular 13/2026, items 1-3

• L/C proceeds within 30 days of shipment (17/2025 ثالثاً-2). Proceeds are credited to a "gold export account" in the exporter's name and may stay there at most 21 working days, after which the bank buys them for CBOS at its announced rate (ثالثاً-3). Free-gold proceeds may be used for the…

  30 days from shipment; 21 working days in the gold export account; 21 working days in the import account

  Official guidanceAmount not confirmed

  • CBOS Circulars 17/2025, 11/2026 and 12/2026, 17/2025 ثالثاً-2, ثالثاً-3

• Offences (MMDA s.32(1)): exploring without a licence - up to 2 years (أ); extracting without a mining contract - up to 3 years (ب); withholding production data - up to 5 years (ج); false information - fine of at least SDG 100,000 (د); transporting, exporting, storing, possessing or dealing in mi…

  Primary law

  • MMDA 2015, s.32(1), s.32(2), s.33

• 13 May - 21 Sep 2026: CBOS bought 100% of tailings (mining-waste) companies' gold at its announced price after in-kind deduction of profits and royalties from total production (Circular 11/2026 item 2). Cancelled and replaced on 21 Sep 2026 by Circular 18/2026 (see sd.ctl-tailings-sale-2026-09).

  Official guidance

  • CBOS Circular 11/2026, item 2

• Since 21 Sep 2026 (replacing sd.ctl-tailings-100pct): tailings companies may sell all their gold to CBOS, its delegate or exporters; tailings gold may be exported by advance payment (priced daily by CBOS) or confirmed sight L/C with proceeds within 30 days of shipment; proceeds held in a gold export…

  Official guidance

  • CBOS Circular 18/2026, items 1-6

• The UAE, which took about 88-95% of Sudan's official gold exports, suspended trade with Sudan in August 2025, forcing a search for other buyers (Qatar refinery agreement, Egypt, Turkey, India, Hong Kong).

  Secondary

• UK asset freezes (16 Jul 2026) on three Sudanese state-owned mining companies - Omdurman Mining and Ariab Mining Company (suspected of generating gold revenue for the SAF) and Sudamin Company Ltd (suspected of channelling conflict-gold revenue to both SAF and RSF, incl. past links to Al Junaid) - pl…

  Official guidance

  • The Sudan (Sanctions) (EU Exit) Regulations 2020

• Transporting, exporting, storing, possessing or dealing in minerals or tailings whose source of production one does not own, without a licence or Ministry permission, is an offence (MMDA s.32(1)(هـ), added 2019; up to five years). Press reported that the Aug 2025 measures made holding undocumented…

  Primary law

  • MMDA 2015, s.32(1)(هـ)

• US designations under EO 14098: Al Junaid Multi Activities Co (RSF-controlled; gold mining and export since the 2017 takeover of Jebel Amer) on 1 Jun 2023; on 7 Jan 2025 RSF leader Hemedti and UAE companies incl. Al Zumoroud and Al Yaqoot Gold & Jewellers (bought Sudanese gold for the RSF and moved …

  Official guidance

  • Executive Order 14098

On the way

• VAT zero rate on export of goods

  0% Exported gold and raw materials

  SecondaryUnder reviewAmount not confirmed

  • Tax Code 214-VIII (18.07.2025)

• VAT zero rate on sale of refined gold to the NBK

  0% Refined gold from own or purchased raw material sold to the NBK to replenish its precious-metal assets

  Primary lawUnder reviewAmount not confirmed

  • Tax Code 214-VIII (18.07.2025), art. 472

• VAT, standard rate

  16% (from 1 Jan 2026) Domestic sales of gold not otherwise zero-rated or exempt

  SecondaryUnder reviewAmount not confirmed

  • Tax Code 214-VIII (18.07.2025)

• Cross-border carriage of cash and goods by individuals follows the EAEU Customs Code (written declaration above USD 10,000 cash equivalent).

  USD 10,000 (cash)

  UnverifiedAmount not confirmed

• On import from or export to non-EAEU countries, if documents on precious-metal content do not match the contract, samples are control-tested by the NBK.

  Primary lawUnder review

  • Law 444-V 'On precious metals and precious stones', art. 7(1); art. 5(3)

• Resident exporters must repatriate proceeds under export currency contracts within the contract term; contracts meeting NBK criteria receive registration numbers. No mandatory sale of FX proceeds found in the law.

  Primary lawUnder review

  • Law 167-VI, arts 9, 13-14

• Dealers in precious metals and stones are subjects of financial monitoring; purchase/sale of precious metals and stones of 50,000,000 KZT or more is reportable; jewellery 5,000,000 KZT; pawnshop operations 3,000,000 KZT. Retail jewellery purchases by individuals up to 500,000 KZT have simplified CDD…

  50,000,000 KZT (precious metals)

  Primary lawUnder reviewAmount not confirmed

  • Law 191-IV, arts 3, 4, 5

• Export of precious metals and raw materials to non-EAEU countries needs an export licence and a per-shipment act of state control from the authorised body; refined gold also needs proof of NBK refusal.

  Primary lawUnder review

  • Order of the Minister of Industry and Construction No. 375 of 29.10.2024, paras 10, 17-19

• Mined gold and raw materials (doré, cathode metal, zinc precipitate, scrap, ores and concentrates) must go to Kazakh precious-metal producers for processing/refining. Export of raw materials requires refusals from all listed producers and a conclusion that domestic extraction is not feasible.

  Primary lawUnder review

  • Law 444-V 'On precious metals and precious stones'; Order of the Minister of Industry and Construction No. 375 of 29.10.2024, art. 8(1)-(2); Order 375 para. 20

• The state has a priority right to buy refined gold for NBK assets. Producers and owners of refined gold after processing must sell refined gold, produced in Kazakhstan or abroad, to the NBK first, within half-yearly limits set from their forecasts; only gold the NBK refuses may go to third parties. …

  Primary lawUnder review

  • Law 444-V 'On precious metals and precious stones', art. 9

• Individual entrepreneurs and companies must notify the authorised body before starting import/export of refined and other precious metals and raw materials (the NBK is exempt).

  Primary lawUnder review

  • Law 444-V 'On precious metals and precious stones', art. 7(4)

Where the goods arrive

• 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”

• 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)

Back in the origin country: the proceeds of the export