Guinea [Industrial / semi-industrial title holder] → Australia (refine) → United Arab Emirates · Reconcile assays and pay the balance

File the prior declaration of export with the BNE on the BNE form (exporter, date of exit, quantity and quality, value, carriers, consignee); the BNE forwards it within 24 hours to the BCRG, Customs and the LNG. Guinee7 describes this as the 'demande de réception et d'exportation', filed at least 72 hours before the gold arrives in Conakry, naming the flight, destination, MMG-approved receiving institution and NIF

Who

Industrial or semi-industrial mining-title holder

Needs

Tax Identification Number certificate

Issues

Demande de réception et d'exportation (export request to the BNE)

[summary] The 72-hour lead time and the flight/receiving-institution fields are from Guinee7 only. [conflict] gn.div-declaration-body.

• Décret D/2014/013/PRG/SGG, art. 6

Give prior declaration of the gold export to the BCRG; the export takes place in the presence of a Customs representative

Who

Industrial or semi-industrial mining-title holder

Issues

Prior declaration of gold export (to the BCRG under Code art. 186; on the BNE form under Décret D/2014/013 art. 6)

[conflict] gn.div-declaration-body: D/2014/013 art. 6 routes the declaration through the BNE.

• Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT, art. 186

Attend the expertise and weighing of the ingots (with the LNG, BCRG, Customs and Sécurité Minière) and take part in packing them in sealed cases stored at the BCRG

Who

BNE (national expertise bureau for gold and precious materials)

Needs

Demande de réception et d'exportation (export request to the BNE)

Issues

LNG identification sheet (fiche d'identification) of the ingot or lot

Form

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

[conflict] gn.div-export-fee: Guinee7 reports a USD 750 BNE fee per export; not found in any text held.

• Décret D/2014/013/PRG/SGG, art. 7(3)-(7)

Take samples of the ingots, carry out the expertise and issue the identification sheet (fiche d'identification); the LNG's grade is the reference

Who

Laboratoire National de Géologie

Issues

Certificate of analysis (Laboratoire National de Géologie)

• Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT; Décret D/2014/013/PRG/SGG, Code art. 198; Décret art. 7(3), 7(32)

Weigh and value the ingots with the BCRG (purity; London fixing on the day of weighing) and record weight, purity, price and value on the evaluation sheet signed by the BCRG, Customs, Sécurité Minière, BNE and LNG; the sealed ingots are stored at the BCRG

Who

Laboratoire National de Géologie

Needs

Prior declaration of gold export (to the BCRG under Code art. 186; on the BNE form under Décret D/2014/013 art. 6)

Issues

Fiche d'évaluation (weighing and valuation sheet) of the ingot or lot

[conflict] gn.div-fixing: afternoon fixing (Code) vs morning fixing (decree).

• Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT; Décret D/2014/013/PRG/SGG, Code art. 161-I; Décret art. 7(2)-(7)

Pay the 5% tax on industrial or semi-industrial precious metals (base: ingot value at the weighing) to the Receveur Spécial des Douanes at the exit customs office, and the BCRG export fee

Who

Industrial or semi-industrial mining-title holder

Needs

Fiche d'évaluation (weighing and valuation sheet) of the ingot or lot

Issues

Quittance libératoire / customs visa proving payment of the precious-metals or artisanal export tax

[conflict] gn.div-export-fee: fee amounts; the tax is primary law.

• Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT; Décret D/2014/013/PRG/SGG, Code art. 161-I; Décret art. 7(13)-(19)

Lodge the detailed export declaration (title holder, title references, quantity and quality, HS code, copy of the evaluation sheet, carrier, destination, tax rate) at the exit customs office; after payment Customs grants mainlevée and visas the declaration; the export takes place in the presence of Customs. Guinee7 reports the shipping documents are co-signed by the company, BNE, LNG, DGD and BCRG

Who

Industrial or semi-industrial mining-title holder

Needs

LNG identification sheet (fiche d'identification) of the ingot or lot; Certificate of analysis (Laboratoire National de Géologie); Fiche d'évaluation (weighing and valuation sheet) of the ingot or lot; Quittance libératoire / customs visa proving payment of the precious-metals or artisanal export tax

Issues

Export documents jointly signed by the exporter, BNE, LNG, Customs (DGD) and BCRG; Export customs declaration (DGD)

[summary] Joint co-signature of the shipping documents from Guinee7 only.

• Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT; Décret D/2014/013/PRG/SGG; Customs Code, Code art. 186; Décret art. 7(13)-(21); Customs Code art. 132

Alert Customs and the anti-fraud brigade, which jointly monitor the export operation at the airport

Who

BCRG (central bank)

Needs

Export documents jointly signed by the exporter, BNE, LNG, Customs (DGD) and BCRG

[summary] The airport alert is from Guinee7; D/2014/013 art. 7(3) only allows the brigade to attend the weighing.

Fly the gold from Conakry to the receiving institution abroad

Who

Airline carrying the gold from Conakry

Needs

Export documents jointly signed by the exporter, BNE, LNG, Customs (DGD) and BCRG; Export customs declaration (DGD)

Issues

Air waybill

The request names the airline and destination; the AWB is assumed for industrial exports.

Onboard the foreign supplier: KYC, origin and chain-of-custody documents, export authorisation of the origin country, under LBMA RGG

Who

Australian gold refiner (LBMA Good Delivery-listed)

Issues

Supplier KYC pack for imported doré/scrap

RGG duties inferred from GD status; no Australian statute imposes refiner origin checks.

Screen for Russian-origin gold: import, purchase or transport of Russian gold exported after 30 Sep 2022 is prohibited without a sanctions permit

Who

Importer of doré or bullion (usually the refiner or a dealer)

Issues

Screen for Russian-origin gold

• Autonomous Sanctions Regulations 2011 regs 4A, 12A, 18(1)(b); Import Sanctioned Goods-Russia Designation 2022 Sch 1 item 16

Lodge the import declaration (entry for home consumption) in the Integrated Cargo System for consignments above the entry thresholds; customs duty Free for 7108 and 7112.91; importation of precious metal (99.5%+, investment form) is a non-taxable importation for GST; dore is a taxable importation (GST 10% of the value of the taxable importation)

Who

Licensed customs broker

Needs

Screen for Russian-origin gold; Export customs declaration accepted by the dispatching country's customs; Air waybill; Commercial invoice

Issues

Import declaration, HS 7108 / 7112.91

[inferred] GST on imported dore follows from ss.13-5/13-10 with the precious-metal definition; [not-read] duty rate from the ABF tariff page, not the Act.

• Customs Act 1901 ss.68, 71A; Customs Tariff Act 1995 Sch 3; GST Act 1999 ss.13-5, 13-10, 13-20

Refine doré to 999.9 kilobars/minted bars or 995+ Good Delivery bars; cast, mark (refiner mark, serial, fineness) and record

Who

Australian gold refiner (LBMA Good Delivery-listed)

Needs

Outturn / assay statement

Issues

Bar list for refined bars

Form

Doré bar - unstamped → 999.9 kilobar

Maintain LBMA Good Delivery and RGG compliance; publish the annual RGG compliance report with independent assurance

Who

Australian gold refiner (LBMA Good Delivery-listed)

Issues

Refiner RGG report and assurance

Report suspicious matters to AUSTRAC (refiner bullion business is a reporting entity)

Who

Australian gold refiner (LBMA Good Delivery-listed)

Issues

Suspicious matter report

[inferred] The refiner is a reporting entity because it buys and sells bullion in a bullion-dealing business (s.6 table 2 item 1); the Perth Mint enforceable undertaking confirms it for that refiner.

• AML/CTF Act 2006, s.6(3) table 2 item 1; s.41

Hold bars in allocated or unallocated metal accounts; for the Perth Mint, metal liabilities carry the WA Treasurer's guarantee

Who

Depository / vault operator (metal accounts)

Needs

Bar list for refined bars

Issues

Metal account statement

Metal-account practice from the Perth Mint pages; the guarantee itself read in s.22 (cash equivalent of gold due, payable and deliverable under the Act and currency-dealing moneys).

• Gold Corporation Act 1987 (WA), s.22

Keep origin records for imported material: under LBMA RGG the mine remains the origin of gold refined in Australia

Who

Australian gold refiner (LBMA Good Delivery-listed)

Needs

Supplier KYC pack for imported doré/scrap

RGG origin rule not re-read here.

Prepare commercial invoice and bar list; no export permit or licence is required for gold

Who

Exporter of bars (refiner, dealer or miner selling offshore)

Needs

Bar list for refined bars

Issues

Commercial invoice (GST-free / input-taxed treatment stated)

[inferred] Absence of a gold export permit read from the Regulations as a whole; commercial invoice and bar list are commercial practice.

• Customs (Prohibited Exports) Regulations 1958 (no gold item)

Lodge the export declaration in the Integrated Cargo System (required for consignments above $2,000 FOB) and obtain the export entry advice (authority to deal) with its number before loading; a declaration may be refused if the intended export day is more than 6 months ahead; if not exported within 30 days of the intended day, withdraw or amend within 7 days; keep commercial documents 5 years

Who

Licensed customs broker

Needs

Commercial invoice (GST-free / input-taxed treatment stated)

Issues

Export declaration and export entry advice (authority to deal, with export entry advice number)

• Customs Act 1901, ss.113, 114, 114C, 116, 240(1A); Customs Regulation 2015 r. 82

  “an FOB value not exceeding $2,000 or such other amount as is prescribed”

Obtain a certificate of origin only if the buyer or the destination requires one (e.g. to claim an FTA preference); an exporter claiming Australian origin for a preferential tariff in China, Hong Kong or the UK may be required by the ABF to produce origin records and answer questions for verification by the importing customs

Who

Exporter of bars (refiner, dealer or miner selling offshore)

Issues

Certificate of origin (on request)

[not-read] Issuing bodies and forms for certificates of origin not researched (au.gap-cert-origin); no Australian export rule requires one for gold.

• Customs Act 1901, Divisions 4J, 4K, 4M (ss.126AOA-126AOD, 126APA-126APD, 126ARA-126ARD)

Ship by secure air freight under air waybill

Who

Secure precious-metals carrier / airline

Needs

Export declaration and export entry advice (authority to deal, with export entry advice number)

Issues

Air waybill

Carrier practice not documented in the sources read.

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

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

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

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

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)

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

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

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

Who

DMCC importer / trader

Issues

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

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

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

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

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

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

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

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

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)

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

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

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

[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

Pay the export proceeds to the exporter's account

Who

Receiving institution abroad (refiner or buyer on the MMG-approved list)

Issues

Bank transfer record

Repatriate foreign-currency export receipts into BCRG accounts held with a first-rank foreign bank (Code art. 184); the government's reported shares are 50% (enforced from 2023) and 60-70% through local banks from March 2026, with DDI-DDE filings

Who

Industrial or semi-industrial mining-title holder

Issues

DDI-DDE export intention / export declaration filings (2026 FX measures)

[unconfirmed] The shares and the DDI-DDE requirement are from press; the obligation itself is primary law (art. 184).

• Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT, art. 184, 185

Repatriate the export proceeds through the banking circuit within 45 days, the SWIFT message quoting the shipment file number; the BCRG releases the funds after checking the SWIFT copy, the shipment file and earlier repatriations, and the comptoir may sell the currency only to BCRG-listed compliant exchange bureaux

Who

Purchaser in an accredited gold buying agency (comptoir d'achat et d'exportation d'or)

• BCRG Règlements N°098/2022 and N°103/2022, Règl. 098 art. 8; Règl. 103 arts. 4, 7-13