Kazakhstan [private export after NBK refusal] → Australia → United Kingdom · Retail investment-gold sale by a dealer (HVD rules for cash)

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

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Kazakhstan (Doré bar - unstamped → 999.9 kilobar) ⟶ Australia (999.9 kilobar) ⟶ United Kingdom (999.9 kilobar)

Not researched: Kazakhstan → Australia

Leg 1: Kazakhstan

Where the goods start

Doré bar - unstamped → 999.9 kilobar

1
Identify the customer and report purchases/sales of precious metals of 50,000,000 KZT or more (cash or non-cash) to the AFM; jewellery threshold 5,000,000 KZT; pawnshops 3,000,000 KZT
Who
Individual entrepreneur or company trading precious metals domestically
Issues
Report to the AFM on an operation subject to financial monitoring
Primary lawUnder review
- Law 191-IV, art. 4
2
Extract gold ore within the licensed plot under a mining licence
Who
Holder of a mining licence for solid minerals (industrial gold miner)
Needs
Mining licence for solid minerals
Form
Ore (in situ / run-of-mine) → Concentrate / black sand
Primary law
[unconfirmed] The held Subsoil Code text is the FAOLEX consolidation (Russian), older than the text in force; amendments made since then are not checked, because the official Adilet text is a wall.
- Code of the Republic of Kazakhstan on subsoil and subsoil use (articles in refs), Subsoil Code art. 202
  “По лицензии на добычу твердых полезных ископаемых ее обладатель имеет исключительное право пользоваться участком недр в целях проведения следующих операций”
- Code of the Republic of Kazakhstan on subsoil and subsoil use (articles in refs), art. 202(1)
  “добыча твердых полезных ископаемых (извлечение)”
3
Process on site (gravity, leaching, smelting) into doré, cathode metal or zinc precipitate; the mining licence covers use of the subsoil space for mining and mine-processing production, and mining includes leaching and the collection, storage, crushing and sorting of the extracted minerals on the mining plot
Who
Holder of a mining licence for solid minerals (industrial gold miner)
Form
Concentrate / black sand → Doré bar - unstamped
Primary law
Technology is industry practice. [unconfirmed] The held Subsoil Code text is the FAOLEX consolidation (Russian), older than the text in force; amendments made since then are not checked, because the official Adilet text is a wall.
- Code of the Republic of Kazakhstan on subsoil and subsoil use (articles in refs), Subsoil Code art. 202
  “По лицензии на добычу твердых полезных ископаемых ее обладатель имеет исключительное право пользоваться участком недр в целях проведения следующих операций”
- Code of the Republic of Kazakhstan on subsoil and subsoil use (articles in refs), art. 202(2)
  “использование пространства недр в целях проведения горных работ, размещения горнодобывающего и (или) горно-перерабатывающего производств”
- Code of the Republic of Kazakhstan on subsoil and subsoil use (articles in refs), art. 202, definition of mining
  “химическому и бактериальному выщелачиванию”
4
Contract with a producer on the authorised body's list for refining (tolling) or sale; mined gold and raw materials must go to Kazakh producers for processing/refining (nuggets not subject to refining excepted)
Who
Holder of a mining licence for solid minerals (industrial gold miner)
Issues
Refining (tolling) or purchase agreement with a listed Kazakh refiner
Primary lawUnder review
- Law 444-V 'On precious metals and precious stones', art. 8(1)
5
Record the transfer of ownership (or pledge) of raw materials before refining under the authorised body's rules on recording such transactions
Who
Holder of a mining licence for solid minerals (industrial gold miner)
Issues
Record of a transaction transferring ownership of (or pledging) mineral raw materials before refining
Primary lawUnder review
Only art. 4(10-1) delegating the rules was read; how and by whom the record is made is not confirmed.
- Law 444-V 'On precious metals and precious stones', art. 4(10-1)
6
Move doré under secure escort from the mine to the refinery
Who
Secure carrier (cash-in-transit / valuables logistics)
Industry practice
7
Weigh, sample and assay the incoming doré; agree the outturn
Who
Subject of production of precious metals on the authorised body's list (refinery)
Industry practice
8
Refine to 99.99% gold (standard 12 kg bars, 100 g-1 kg bars or granules); LBMA Good Delivery-listed refiners stamp bars of international standard
Who
Subject of production of precious metals on the authorised body's list (refinery)
Issues
Refiner's quality certificate / bar list for refined gold (999.9)
Form
Doré bar - unstamped → 999.9 kilobar
Industry practiceUnder review
- Law 444-V 'On precious metals and precious stones', art. 8(1)
9
Sign the foreign-trade contract with a specification (full assortment, quantity, mass) and issue the invoice or value-confirmation document with the precious-metal content calculation
Who
Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)
Issues
Foreign-trade contract with specification (submitted for licence and state control act); Invoice or value-confirmation document
Primary lawUnder review
- Order of the Minister of Industry and Construction No. 375 of 29.10.2024, para. 18
10
Obtain the document confirming the NBK's refusal to exercise the priority right on the refined gold
Who
Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)
Needs
Document confirming NBK refusal to exercise the priority right on refined gold
Issues
Document confirming NBK refusal to exercise the priority right on refined gold
Primary lawUnder review
- Order of the Minister of Industry and Construction No. 375 of 29.10.2024, para. 19
11
Obtain a laboratory document on precious-metal content from an accredited testing laboratory
Who
Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)
Issues
Accredited testing laboratory document on precious-metal content
Primary lawUnder review
- Order of the Minister of Industry and Construction No. 375 of 29.10.2024, para. 18
12
Obtain an export licence for the foreign-trade contract from the authorised body
Who
Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)
Needs
Notification of start/cessation of activity with precious metals (import/export); Foreign-trade contract with specification (submitted for licence and state control act)
Issues
Export licence for precious metals / raw materials (per foreign-trade contract)
Primary lawUnder review
Issuing procedure and EAEU basis (EEC Decision 30) not read.
- Order of the Minister of Industry and Construction No. 375 of 29.10.2024, paras 17-18
13
Assign a registration number to the currency contract where it meets the NBK monitoring criteria
Who
Kazakh commercial bank servicing the currency contract
Issues
Registration (accounting) number of a currency contract
Primary lawUnder review
Threshold is set in NBK rules, not read.
- Law 167-VI, arts 13-14
14
Apply through the e-government portal for the act of state control, presenting the whole batch and the licence, contract, specification, invoice, content calculation, notification, ownership documents and laboratory document
Who
Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)
Needs
Export licence for precious metals / raw materials (per foreign-trade contract); Foreign-trade contract with specification (submitted for licence and state control act); Invoice or value-confirmation document; Accredited testing laboratory document on precious-metal content; Notification of start/cessation of activity with precious metals (import/export); Document confirming NBK refusal to exercise the priority right on refined gold
Primary lawUnder review
- Order of the Minister of Industry and Construction No. 375 of 29.10.2024, paras 9, 18, 19, 21
15
Carry out control testing of samples when the content documents do not match the contract or technical documentation
Who
National Bank of Kazakhstan (state buyer, priority right)
Issues
NBK control test result on samples (Cash Operations and Valuables Storage Centre)
Primary lawUnder review
- Law 444-V 'On precious metals and precious stones', art. 7(1)
16
Issue the act of state control for the shipment (content, source, market valuation, compliance with contract); refuse if documents incomplete or price below metal value
Who
Authorised body for precious metals (Ministry of Industry and Construction)
Issues
Act of state control of precious metals, issued per shipment
Primary lawUnder review
- Order of the Minister of Industry and Construction No. 375 of 29.10.2024, para. 10
17
Obtain a certificate of origin if the buyer or destination requires it
Who
Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)
Issues
Certificate of origin (general form) for exported goods
Unverified
Not researched; included because hand-off checks may ask for it.
18
Lodge the export goods declaration with the state control act and export licence; customs releases the goods
Who
Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)
Needs
Act of state control of precious metals, issued per shipment; Export licence for precious metals / raw materials (per foreign-trade contract)
Issues
EAEU goods declaration for export (ДТ)
Primary lawUnder review
- Order of the Minister of Industry and Construction No. 375 of 29.10.2024, para. 17
19
Ship the bars to the foreign buyer
Who
Secure carrier (cash-in-transit / valuables logistics)
Needs
EAEU goods declaration for export (ДТ)
Issues
Air waybill for export shipment
Industry practiceUnder review
Order 375 governs release; carriage arrangements are industry practice.

Taxes and fees

Export customs duty on gold
None identified
UnverifiedAmount not confirmed
Mineral extraction tax on gold (Tax Code 2017)
7.5%
SecondaryAmount not confirmed
- Tax Code 120-VI (2017)
Mineral extraction tax (НДПИ) on gold, price-banded
7.5% at average price up to USD 2,800/oz; 8% to 3,000; 8.5% to 3,200; 9% to 3,400; 9.5% to 3,600; 10% to 3,800; 11% above 3,800 Gold extracted (all forms)
Primary lawUnder reviewAmount not confirmed
- Tax Code 214-VIII (18.07.2025), arts 780-781

Controls

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)

Leg 2: Australia

On the way

20
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
Standard
RGG duties inferred from GD status; no Australian statute imposes refiner origin checks.
21
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
Primary law
- Autonomous Sanctions Regulations 2011 regs 4A, 12A, 18(1)(b); Import Sanctioned Goods-Russia Designation 2022 Sch 1 item 16
22
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
Primary law
[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
23
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
Industry practice
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
24
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
Standard
RGG origin rule not re-read here.
25
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)
Primary law
[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)
26
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)
Primary law
- 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”
27
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)
Primary law
[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)
28
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
Industry practice
Carrier practice not documented in the sources read.

Taxes and fees

GST - first supply of precious metal after refining
GST-free (0%, input credits allowed) First supply of precious metal after its refining by, or on behalf of, the supplier, where the refiner is a "refiner of precious metal" and the recipient a "dealer in precious metal" (each: an entity that satisfies the Commissioner of the activity - s.195-1)
Primary lawAmount not confirmed
- A New Tax System (Goods and Services Tax) Act 1999, s.38-385; s.195-1
GST on importation of precious metal
Non-taxable importation (precious metal); otherwise GST 10% of the value of the taxable importation (customs value plus international transport and insurance, s.13-20) Imported gold that meets the precious-metal definition is a non-taxable importation because its supply would be input taxed or GST-free (s.13-10(b)); dore and other gold outside the definition is a taxable importation
Primary lawAmount not confirmed
- A New Tax System (Goods and Services Tax) Act 1999, ss.13-5, 13-10(b), 13-20
GST - other supplies of precious metal
Input taxed (no GST charged; no input tax credits) Gold (in an investment form) of at least 99.5% fineness (s.195-1 precious metal); "investment form" is not defined in the Act - the ATO describes it as a coin, wafer, bar or other tradeable form with an internationally accepted hallmark (LBMA-approved for gold)
Primary law
- A New Tax System (Goods and Services Tax) Act 1999, s.40-100; s.195-1
GST reverse charge on supplies of goods containing valuable metal
10% of the price, payable by the recipient A taxable supply of goods consisting wholly or partly of valuable metal (gold, silver, platinum) to a recipient registered or required to be registered, where the market value of the goods does not exceed the valuable metal threshold (i.e. is not at least 10% above the value of the metal in them) or the parties agree in writing - e.g. scrap, dore and other non-investment gold
Primary lawAmount not confirmed
- A New Tax System (Goods and Services Tax) Act 1999, Division 86 (ss.86-5, 86-10, 86-25); s.195-1 valuable metal
Customs duty on gold
Free HS 7108.11.00, 7108.12.00, 7108.13.00, 7108.20.00 and 7112.91.00 (general rate Free; the rate footnote: FTA originating goods Free unless otherwise shown)
Official guidanceAmount not confirmed
- Customs Tariff Act 1995, Schedule 3

Controls

Buying or selling bullion (gold, silver, platinum or palladium as a bar, coin, ingot, plate, wafer or like form, bearing a mark guaranteeing fineness and traded by reference to the spot price) in the course of carrying on a bullion-dealing business is a designated service: enrolment, AML/CTF program…
Primary law
- AML/CTF Act 2006, s.5 (bullion); s.6(3) table 2 item 1; ss.39E, 41, 43, 51B
Buying or selling precious metal (gold, silver, platinum-group metals, or an alloy with at least 2% of them, manufactured or not), precious stones or precious products in the course of carrying on a business, where the purchase involves physical currency and/or virtual assets totalling $10,000 or mo…
$10,000 in physical currency and/or virtual assets
Primary law
- AML/CTF Act 2006 as amended by the AML/CTF Amendment Act 2024, s.5A; s.6(3) table 2 item 2; Amendment Act s.2 and Sch 3 Pt 4 items 11-12
  “buying or selling one or more of the following items in the course of carrying on a business, where the purchase involves the transfer of physical currency or virtual assets (or a combination of physical currency and virtual assets) with a total value of not less than $10,000, whether the purchase is made in a single transaction or in several transactions that are linked or appear to be linked: (a) precious metal; (b) precious stones; (c) precious products”
Export markets accept Australian bars through the refiner's LBMA Good Delivery listing and exchange accreditations (CME, SGE, OSE, DGCX for the Perth Mint).
Industry practice
No economy-wide cap on cash payments was found. Reporting entities must report threshold transactions (transfers of $10,000 or more in physical currency) to AUSTRAC within 10 business days (s.43; s.5). Moving monetary instruments worth $10,000 or more into or out of Australia must be reported (s.53)…
$10,000 (reporting, not a limit)
Primary law
- AML/CTF Act 2006, ss.5, 43, 53
  “monetary instrument means any of the following: (a) physical currency; (b) a bearer negotiable instrument; (c) a thing prescribed by the AML/CTF Rules.”
No foreign-exchange control or repatriation requirement on gold export proceeds was identified.
Unverified
No export permit or licence for gold (it is not a prohibited export). The owner must enter goods for export by an export declaration and may not load them without an authority to deal (export entry advice); consignments with an FOB value of $2,000 or less are exempt unless a permission is required. …
FOB value above $2,000
Primary law
- Customs Act 1901, ss.113(1)-(2A), 113AA, 114, 114C, 116
  “an FOB value not exceeding $2,000 or such other amount as is prescribed”
Origin and CAHRA due diligence on supplies is imposed on Australian refiners by the LBMA RGG as a Good Delivery condition, not by Australian statute.
Secondary
Importing, purchasing or transporting gold (HS 7108) that was exported from Russia after 30 Sep 2022 is a sanctioned import (Designation Sch 1 item 16; AS Regulations reg 4A(1)-(3)) and an offence unless authorised by a permit of the Minister for Foreign Affairs under reg 18(1)(b) (reg 12A); it exte…
Primary law
- Autonomous Sanctions (Import Sanctioned Goods-Russia) Designation 2022 Sch 1 item 16; Autonomous Sanctions Regulations 2011 regs 4A, 12A, 18; Autonomous Sanctions Act 2011 s.16
Supplying, selling or transferring an item of gold, precious metals and diamonds so that it is transferred to the Government of Syria (or its public bodies, agents or controlled entities) is a sanctioned supply, and importing or purchasing such an item from them is a sanctioned import; both are offe…
Primary law
- Autonomous Sanctions Regulations 2011, regs 4(4), 4A(4), 12, 12A, 18

Leg 3: United Kingdom

Where the goods arrive

29
Apply customer due diligence to the foreign seller before buying (identity, beneficial owner, purpose, risk assessment, sanctions/PEP screening)
Who
Bullion dealer / trader (importer of record, usually an LBMA member)
Issues
Supplier KYC pack received by the UK buyer; MLR customer due diligence file
Primary law
[unconfirmed] Whether a non-bank wholesale bullion trader paid by wire is within the MLR at all (e.g. as a financial institution under reg 10) - consolidated MLR not held. [not-read] Reg 27 quoted via WebFetch; MLR not held.
- Money Laundering Regulations 2017, reg 27
30
Establish that the gold is not Russian-origin gold exported from Russia on or after 21 Jul 2022, not relevant processed gold incorporating such gold, and not Russian gold jewellery exported on or after 29 Oct 2022; check where the goods were originally consigned or exported from; if Russian origin is possible, apply to DBT's Import Sanctions Team for a licence or contact it; declare document code 9022 (not subject to / exempt from sanctions) or 9011 (licence) on CDS and keep the evidence to produce on demand
Who
Bullion dealer / trader (importer of record, usually an LBMA member)
Needs
Export customs declaration accepted by the dispatching country's customs
Issues
Importer's Russia-sanctions origin evidence file
Primary law
[inferred] The guidance and tariff do not list specific evidence documents; the required kinds are this module's inference.
- Russia (Sanctions) (EU Exit) Regulations 2019 as amended by SI 2022/850 and SI 2022/1110, regs 46Z11, 46Z16B, 46Z16C
31
Fly the bars into the UK as valuable cargo (typically Heathrow) under an air waybill
Who
Secure valuables carrier
Issues
Air waybill, inbound valuables consignment
Unverified
UK valuables-cargo handling not researched in this pass.
32
Submit a full import declaration on CDS (procedure code, commodity code 7108 12 00 00 for unwrought gold, DUCR, consignor/consignee, value, licences; EORI); declare sanctions document code 9022 or 9011; claim the investment-gold VAT exemption with additional code VATE where the bars are 995+ of a weight accepted by the bullion markets
Who
Customs agent / declarant using CDS software
Needs
EORI number of importer/exporter; Importer's Russia-sanctions origin evidence file; Air waybill, inbound valuables consignment; Air waybill; Commercial invoice; Bar list (serials, weights, fineness)
Issues
CDS full import declaration
Official guidance
[conflict] gb.div-cpc-chief - VAT Notice 701/21 s.8.1 still gives CHIEF CPC 40 00 073; the tariff (28 Sep 2026) shows the exemption as additional code VATE. [not-read] The CDS procedure code and DE 1/10-1/11 entries for investment gold not read (UK Trade Tariff Vol. 3 listed in gb-fetch.tsv).
33
Account for import VAT: exempt for investment gold (additional code VATE); 20% standard rate (code 03020) on non-investment gold (dore, grain, scrap, sub-995 bars, non-qualifying coins); customs duty 0.00% (third-country rate on 7108 12, S.I. 2020/1430)
Who
Bullion dealer / trader (importer of record, usually an LBMA member)
Needs
CDS full import declaration
Official guidance
- VAT Act 1994 Sch 9 Group 15; VAT Notice 701/21, Notice s8.1, s10.7
34
Clear the goods (CDS message when cleared), or ask for supporting documents for a customs check; for 7108 the Russia/Belarus measures read "Import allowed after control"; HMRC enforces trade sanctions at the border
Who
HMRC (customs and VAT authority)
Needs
CDS full import declaration
Issues
CDS clearance notification (goods released)
Official guidance
35
Register with HMRC as a high value dealer before accepting or making any cash payment of GBP 10,000 or more (single or linked); pay annual fee
Who
Retail bullion dealer accepting cash (high value dealer)
Issues
HMRC MLR registration as high value dealer
Primary law
[conflict] gb.div-hvd-guidance-lag. Registration requirement ("must not accept or make a high value cash payment until you have registered") from the HMRC page; the MLR registration regulation not read.
- MLR 2017 as amended by SI 2026/621, reg 14 (definition)
36
Apply CDD to any occasional cash transaction of GBP 10,000 or more
Who
Retail bullion dealer accepting cash (high value dealer)
Needs
HMRC MLR registration as high value dealer
Issues
MLR customer due diligence file
Primary law
[not-read] Reg 27(3) quoted via WebFetch; amount confirmed by SI 2026/621 reg 14(c) (held).
- MLR 2017, reg 27(3)
37
Sell investment gold VAT-exempt to the retail customer: identity evidence (one List 1 and one List 2 document), invoice and records where the thresholds are met
Who
Retail bullion dealer accepting cash (high value dealer)
Needs
MLR customer due diligence file
Issues
Investment gold invoice (VAT tertiary legislation s.3 / VAT Regs reg 31A); Investment gold customer records and identity evidence
Official guidance
- VAT Notice 701/21; VAT Regs 1995 reg 31A, Notice s7.1

Taxes and fees

Customs duty on gold (UK Global Tariff)
0.00% (third-country duty on 7108 12 00 00; preferential rates also 0.00%) HS 7108 12 00 00 non-monetary gold, other unwrought forms (read); 7108 13 and 7112 91 not held
Official guidanceAmount not confirmed
- Customs Tariff (Establishment) (EU Exit) Regulations 2020 (S.I. 2020/1430), as shown on the tariff
Import VAT on investment gold
Exempt Bars/wafers 995+ of a weight accepted by the bullion markets; qualifying coins
Official guidanceAmount not confirmed
- VAT Act 1994 Sch 9 Group 15; VAT Notice 701/21 s.8.1; UK tariff additional code VATE
Import VAT on non-investment gold
20% (standard rate; tariff code 03020) Doré, grain, scrap, bars below 995, non-qualifying coins
Official guidanceAmount not confirmed
- VAT Notice 701/21, s10.7
VAT exemption for supplies of investment gold (with option to tax)
Exempt Supplies of investment gold (incl. rights to it, unallocated gold, loans, swaps, forwards and futures; not options) and agents' services for them; not between an LBMA member and a taxable non-member (standard-rated, SAS)
Official guidanceAmount not confirmed
- VAT Act 1994 Sch 9 Group 15; VAT (Investment Gold) Order 1999
Special accounting scheme (reverse charge) for gold
20%, accounted for by the buyer Standard-rated B2B supplies between VAT-registered (or liable) persons: fine gold, gold grain, gold coins (not margin-scheme), gold-containing goods priced at no more than a negligible amount above the gold value, investment gold on which the option to tax is exercised or supplied between an LBMA member and a non-member, and treatment/processing services producing such gold (Notice 701/21 s.11.2)
Official guidanceAmount not confirmed
- VAT Act 1994 s.55 (named in VGOLD1700; statute not held)
Zero rate for London Bullion Market and central-bank gold transactions
0% Investment gold (incl. futures and options) between taxable LBMA members (TMO; Notice 701/9 s.3.2.4); gold, rights to or part interests in gold held in the UK between central banks or between a central bank and an LBM member (VATA Sch 8 Group 10; Notice 701/21 s.10.4). Not zero-rated: investment gold between an LBMA member and a taxable non-member (standard-rated, special accounting scheme); a futures contract between a member and a non-member that leads to physical delivery (Notice 701/9 s.3.3.2).
Official guidanceAmount not confirmed
- VAT (Terminal Markets) Order 1973 art. 2(2), (4) and arts 4-7; VATA 1994 s.50, Sch 8 Group 10
HMRC MLR registration and annual supervision fee
Not read
Official guidance

Controls

The UK tariff attaches to 7108 12 00 00 a "Restriction on entry into free circulation for Belarus" (from 30 Sep 2023; legal base SI 2023/616) and a "Restriction on export for Belarus" (legal base SI 2022/748): allowed with document code 9011 (DBT licence, GBSAN reference) or 9022 (not subject to / e…
Official guidance
- Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 as amended
A trader accepting or making a cash payment of GBP 10,000 or more for goods (single or linked) is a high value dealer: must register with HMRC first and apply CDD. Threshold changed from EUR 10,000 to GBP 10,000 with effect from 30 Jun 2026.
GBP 10,000 cash (EUR 10,000 before 30 Jun 2026)
Primary lawAmount not confirmed
- MLR 2017 as amended by SI 2026/621, regs 14, 27(3); SI 2026/621 reg 9
Regulated firms apply CDD on a business relationship, a transfer of funds over GBP 800, an occasional transaction of GBP 12,000+ (HVDs: cash GBP 10,000+), suspicion or doubt; EDD for PEPs, non-face-to-face and FATF call-for-action countries (reg 33 as amended 30 Jun 2026); keep records 5 years; nomi…
Occasional transactions GBP 12,000 (general); GBP 10,000 cash (HVD); transfer of funds GBP 800 (from 30 Jun 2026; previously 15,000 / 10,000 / 1,000 euros)
Primary lawAmount not confirmed
- MLR 2017, reg 27
The import into the United Kingdom of gold originating from Russia is prohibited where it was exported from Russia on or after the relevant day. The ban goes by origin, so it applies whichever country the gold is shipped from.
Primary law
- The Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022, inserting reg 46Z11 into SI 2019/855, reg 46Z11(1)
  “The import of gold originating from Russia is prohibited, where that gold has been exported from Russia on or after the relevant day.”
No Great Britain statute imposing CAHRA/OECD due diligence on gold importers was found. Responsible-sourcing duties in London come from the LBMA (RGG mandatory for Good Delivery refiners since 2012; annual audit; Incident Review Process) and the GBI country-of-origin reporting (monthly, mandatory fr…
Standard
- LBMA Responsible Gold Guidance / Good Delivery Rules
UK persons may not provide financial services for foreign exchange reserve and asset management to the Central Bank of Russia, the National Wealth Fund or the Russian Ministry of Finance (or persons owned, controlled or acting for them); the reserves include bullion such as gold - "it is prohibited …
Official guidance
- Russia (Sanctions) (EU Exit) Regulations 2019, reg 18A (as named in the statutory guidance)
Only Good Delivery bars settle loco London: 350-430 fine troy oz, minimum 995.0 fineness, marks = refiner stamp, assay mark, fineness, serial number (max 11 digits or characters), month and year of manufacture (MMYY, since Jan 2019); no laser engraving. Vault managers have complete discretion and an…
Standard
- LBMA Good Delivery Rules 2026; LPMCL account agreements, GD Rules 2.1.5, 2.1.7, 2.4
The Hallmarking Act 1973 regulates describing articles as gold; Schedule 1 Part II exempts "Any raw material (including any bar, plate, sheet, foil, rod, wire, strip or tube) or bullion" (para 7) and coins that are or were current coin of the UK or any other territory (para 3). Bullion bars and lega…
Primary law
- Hallmarking Act 1973
Dealers in exempt investment gold must identify customers (one List 1 and one List 2 document), issue invoices with prescribed details, keep records at least 6 years and notify HMRC within 28 days when an exempt supply first exceeds GBP 5,000 or supplies to one customer exceed GBP 10,000 in 12 month…
GBP 5,000 per supply / GBP 10,000 per customer per 12 months
Primary lawAmount not confirmed
- VAT Regulations 1995; VAT tertiary legislation, reg 31A
LBMA suspended six Russian refiners (Krastsvetmet, Novosibirsk, Uralelectromed, Moscow Special Alloys, Prioksky, Shyolkovsky) from the Good Delivery List on 7 Mar 2022; their bars made from that date are not Good Delivery; stocks already in loco London/Swiss before then remain Good Delivery.
Standard
- LBMA Good Delivery List
Import of gold originating in Russia that was exported from Russia on or after 21 Jul 2022 is prohibited (reg 46Z11); so are acquiring gold that originated in and is located in Russia with the intention that it enter the UK (46Z12), supplying or delivering gold that originated in Russia on or after …
none
Primary law
- Russia (Sanctions) (EU Exit) Regulations 2019 as amended by SI 2022/850, regs 46Z11-46Z16; Sch 3G
Import of relevant processed gold - gold processed (altered, transformed or otherwise operated on) in a third country that incorporates gold which on or after 21 Jul 2022 originated in and was exported from Russia - is prohibited (46Z16C), as is import of gold jewellery (Sch 3G Part 3) originating i…
Primary law
- SI 2022/1110 (Chapter 4JA), regs 46Z16B, 46Z16C, 46Z16D-46Z16I
All smuggled gold may be liable to forfeiture under the Customs and Excise Management Act 1979, even in the hands of an innocent buyer; HMRC advises buyers to check where the gold came from, whether it was declared at import with import VAT paid, and warning signs (below-market price, quick settleme…
Official guidance
- Customs and Excise Management Act 1979; VAT Notice 701/21 s.14

Leg 4: Kazakhstan

Back in the origin country: the proceeds of the export

38
Repatriate the proceeds to a Kazakh bank account within the term of the currency contract; the bank monitors the contract
Who
Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)
Issues
Receipt of export proceeds on the exporter's Kazakh bank account
Primary law
Threshold and exact deadline rules are in NBK export-import currency control rules (not read). No mandatory sale of FX proceeds found in the law.
- Law 167-VI, art. 9

Crossings between countries

Kazakhstan → Australia Not researched
Papers that cross: Refiner's quality certificate / bar list for refined gold (999.9); Document confirming NBK refusal to exercise the priority right on refined gold; Accredited testing laboratory document on precious-metal content; Export licence for precious metals / raw materials (per foreign-trade contract); NBK control test result on samples (Cash Operations and Valuables Storage Centre); Act of state control of precious metals, issued per shipment; Certificate of origin (general form) for exported goods; EAEU goods declaration for export (ДТ); Air waybill for export shipment
Australia → United Kingdom Researched
Papers that cross: Import declaration, HS 7108 / 7112.91; Commercial invoice (GST-free / input-taxed treatment stated); Export declaration and export entry advice (authority to deal, with export entry advice number); Certificate of origin (on request); Air waybill