Australia (refine) → Russian Federation → Hong Kong (China SAR) · Sale on HKGX or OTC, with payment and AML duties

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

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Australia (Doré bar - unstamped → 999.9 kilobar) ⟶ Russia (999.9 kilobar) ⟶ Hong Kong SAR China (999.9 kilobar)

Not researched: Australia → Russia

Leg 1: Australia

Where the goods start

Doré bar - unstamped → 999.9 kilobar

1
Enrol with AUSTRAC within 28 days of starting a designated service and adopt an AML/CTF program (bullion dealing; from 31 Mar 2026 also buying or selling precious metal for $10,000 or more in physical currency or virtual assets, with obligations from 1 Jul 2026)
Who
Bullion dealer / dealer in precious metal
Issues
AUSTRAC enrolment; AML/CTF program
Primary law
- AML/CTF Act 2006, s.6(3) table 2 items 1-2; ss.26B, 51B
  “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”
2
Carry out customer due diligence before providing the designated service; enhanced due diligence in higher-risk cases
Who
Bullion dealer / dealer in precious metal
Needs
AUSTRAC enrolment
Issues
Customer due diligence file
Primary law
- AML/CTF Act 2006, s.28 (initial CDD); s.39E item 11 (bullion under $5,000)
  “A reporting entity must not commence to provide a designated service to a customer if the reporting entity has not established on reasonable grounds each of the matters in subsection (2)”
3
Sell or buy bars: input-taxed supply of precious metal (no GST charged, no input credits), or GST-free if it is the refiner's first supply after refining to a dealer
Who
Bullion dealer / dealer in precious metal
Needs
Customer due diligence file
Issues
Commercial invoice (GST-free / input-taxed treatment stated)
Primary law
- A New Tax System (Goods and Services Tax) Act 1999, s.40-100; s.38-385
4
Report each threshold transaction (transfer of $10,000 or more in physical currency) to AUSTRAC within 10 business days
Who
Bullion dealer / dealer in precious metal
Issues
Threshold transaction report
Primary law
- AML/CTF Act 2006, s.43; s.5 threshold transaction
5
Report suspicious matters to AUSTRAC (within 3 business days, or 24 hours for terrorism financing suspicions)
Who
Bullion dealer / dealer in precious metal
Issues
Suspicious matter report
Primary law
- AML/CTF Act 2006, s.41
6
Hold a granted mining lease (or state equivalent) with approvals to mine
Who
Mining tenement holder (mining lease) operating a gold mine and mill
Needs
Mining lease
Primary law
[not-read] Mining proposal and closure plan approvals not read.
- Mining Act 1978 (WA), ss.71, 78, 85
7
Mine ore, process (CIL/gravity), and pour doré bars at the mine site; mark each bar
Who
Mining tenement holder (mining lease) operating a gold mine and mill
Issues
Mine doré bar number and mine mark
Form
Ore (in situ / run-of-mine) → Doré bar - unstamped
Industry practice
Mine-site processing described only generally.
8
Collect doré under secure transport and deliver to the refinery
Who
Secure precious-metals carrier / airline
Needs
Refining (toll) agreement between miner and refiner
Industry practice
9
Receive, weigh and sample the doré; issue receipt. For WA royalty, gold metal is taken to be produced on delivery to the refinery if delivered within 3 months of the gold-bearing material being obtained; otherwise on the day after the 3-month period
Who
Australian gold refiner (LBMA Good Delivery-listed)
Issues
Refinery receipt and weigh-in of doré
Primary law
- Mining (Royalties) Regulations 2025 (WA), rr. 29, 31-32
10
Assay the doré and issue the outturn statement; credit the miner's metal account with fine gold (or buy the gold outright)
Who
Australian gold refiner (LBMA Good Delivery-listed)
Needs
Refinery receipt and weigh-in of doré
Issues
Outturn / assay statement; Metal account statement
Industry practice
11
First sale of refined gold: GST-free where it is the first supply after refining by or on behalf of the supplier, by a refiner of precious metal, to a dealer in precious metal; otherwise the supply of precious metal is input taxed
Who
Mining tenement holder (mining lease) operating a gold mine and mill
Needs
Metal account statement
Issues
Commercial invoice (GST-free / input-taxed treatment stated)
Primary law
[conflict] au.div-gst-scrap (refining from scrap).
- A New Tax System (Goods and Services Tax) Act 1999, s.38-385; s.40-100; s.195-1
12
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
Industry practice
13
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
Secondary
14
Report suspicious matters to AUSTRAC (refiner bullion business is a reporting entity)
Who
Australian gold refiner (LBMA Good Delivery-listed)
Issues
Suspicious matter report
Primary law
[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
15
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)
16
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”
17
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)
18
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

Export duty on gold
None All exports, including gold
Official guidanceAmount not confirmed
NSW gold royalty
4% of ex-mine value
Official guidanceAmount not confirmed
- Mining Act 1992 (NSW)
Queensland gold royalty
2.5% of value if the average market price for the return period is at or below A$600/oz (reference price 1); 5% if at or above A$890/oz (reference price 2); in between 2.5 + (PD/RFD) x 2.5 per cent, rounded down to 0.02%
Primary lawAmount not confirmed
- Mineral Resources (Royalty) Regulation 2025 (Qld), s.22; s.26; Sch 1 Pt 1 ss.1-2
Victorian gold royalty
2.75%
Primary lawAmount not confirmed
- Mineral Resources (Sustainable Development) (Mineral Industries) Regulations 2019 (Vic), regs 4, 5, 6(1A)-(1B), 8, 74
WA gold royalty (Mining Regulations 1981)
2.5%
Primary lawAmount not confirmed
- Mining Regulations 1981 (WA), r. 86AA(1), (4), (6), (7)
WA gold royalty
2.5% Gold metal (at least 99.5% pure) taken to be produced on delivery of gold-bearing material to a refinery within 3 months of extraction (r. 31), otherwise on the day after the 3-month refining period (r. 32), or, for gold-bearing material exported as concentrate or crushed/screened material, when the ship arrives at the unloading place (r. 33)
Primary lawAmount not confirmed
- Mining (Royalties) Regulations 2025 (WA), rr. 9, 10, 13(2)(a), 14, 21, 22, 30-33; Sch 1 Div 2

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 2: Russia

On the way

19
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)
20
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
21
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
22
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
23
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
24
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
25
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)
26
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
27
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
28
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: Hong Kong SAR China

Where the goods arrive

29
Onboard the supplier: KYC and source-of-supply review. Hong Kong law makes CDD mandatory for a Category B registrant only for specified cash transactions (AMLO s.5A(5A)); for bank-paid purchases the pack is the importer's own risk choice, with LBMA/OECD guidance applying where the buyer or refiner is bound by it
Who
Registered bullion dealer / trader (DPMS registrant)
Needs
DPMS Category A registration certificate; Commercial invoice
Issues
Supplier KYC pack held by the Hong Kong importer; Customer due diligence file (Category B, specified cash transaction); Supplier's commercial invoice
Official guidance
[inferred] No Hong Kong rule found that requires origin documents for imported gold; the KYC pack is commercial practice outside cash transactions. The legal scope of CDD is read in the Ordinance.
- AMLO s. 5A and Sch. 2 (only for specified cash transactions), s. 5A(5A)-(5B)
  “An AML/CTF requirement that applies to a DNFBP who is a Category B PMS registrant only applies when, by way of business, the registrant carries out, in Hong Kong with a customer, a specified cash transaction that is not an excluded transaction”
30
Fly the consignment into HKIA and deliver it to the importer's vault. If it is transhipment cargo (consigned on a through bill of lading or through air waybill to a place outside Hong Kong) or transit cargo, no Hong Kong declaration is required and the gold never enters the Hong Kong market
Who
Secure logistics carrier / forwarder
Needs
Supplier's commercial invoice; Air waybill; Export customs declaration accepted by the dispatching country's customs
Issues
Inbound air waybill
Primary law
- Import and Export (Registration) Regulations (Cap. 60E), reg. 3(a)-(b); Cap. 60 s. 2 (transhipment cargo, article in transit)
31
Receive the bars, weigh them and check serials against the bar list; credit the importer's allocated account
Who
Precious-metals vault operator
Needs
Inbound air waybill
Issues
Weight and quality verification record; Bar list (serials, weights, fineness); Allocated account weight list
Industry practice
[inferred] Vault intake practice is not documented in an official source; the clearing press release confirms designated vaults record deposits.
32
Lodge the import declaration within 14 days after the day of importation using the specified system (Trade Single Window, or during the transition a government-appointed service provider). Gold bars of fineness 995.0 or above (HKHS 7108 1210, 7108 2010) go on Form 1B with no declaration charge; other gold pays the charge. No customs duty or VAT; gold is not an exempted article
Who
Registered bullion dealer / trader (DPMS registrant)
Needs
Inbound air waybill; Supplier's commercial invoice
Issues
Hong Kong import declaration (Cap. 60E, lodged electronically within 14 days)
Primary law
- Import and Export (Registration) Regulations (Cap. 60E), regs 3, 4(1)-(2), 7, 8(1), (1AA), (4), 18
33
If the gold is paid for with physical currency or BNIs above HK$120,000 carried across the boundary, declare the cash (not the gold) to C&ED: advance CDS declaration for cargo, red channel for arriving travellers
Who
Registered bullion dealer / trader (DPMS registrant)
Issues
CBNI advance electronic declaration (CDS) for cash moved as cargo
Primary law
- Cap. 629, ss. 2, 4, 9, 11; Sch. 4
34
Agree price and terms: loco-London or loco-Hong Kong OTC off the LBMA Gold Price or dealer quotes (the HAU ticker, launched on Bloomberg on 7 July 2026, gives indicative loco-HK bid/offer); or trade on HKGX by open outcry or electronically
Who
Registered bullion dealer / trader (DPMS registrant)
Issues
Sale and Purchase Agreement (price clause); Price reference (LBMA Gold Price, or HAU ticker quotes for loco Hong Kong); HKGX trade record / transaction code
Official guidance
35
Before any specified cash transaction (cash of HK$120,000 or more, single or linked) with a customer, a Category B registrant identifies and verifies the customer and beneficial owner, verifies anyone acting for the customer, applies PEP and high-risk measures and keeps records at least 5 years. Only a Category B registrant may carry out such a transaction; cash paid only between two Category B registrants is excluded from CDD
Who
Registered bullion dealer / trader (DPMS registrant)
Needs
DPMS Category B registration certificate
Issues
Customer due diligence file (Category B, specified cash transaction)
Primary law
- AMLO s. 5A and Sch. 2; C&ED Guideline for Category B registrants, s. 5A(5A)-(5B); s. 53ZUE(2); Sch. 2 ss. 2, 3(1)(b), 10, 15, 20
  “for a period of at least 5 years beginning on the date on which the transaction is completed”
36
A visiting non-Hong Kong dealer that completes a cash transaction of HK$120,000 or more files a cash transaction report (Form CED418) with C&ED within one day or before leaving, whichever is earlier
Who
Non-Hong Kong dealer (visiting)
Issues
Cash transaction report by a non-Hong Kong dealer (Form CED418)
Primary law
- AMLO (Cap. 615) Part 5C, s. 53ZVK; Sch. 3J
37
Buyer pays by bank transfer (or ledger transfer through central clearing); seller issues the final invoice; title passes by vault transfer or clearing-ledger entry
Who
Authorised institution (bank) dealing in bullion
Needs
Sale and Purchase Agreement (price clause)
Issues
SWIFT MT103 payment confirmation (bank-to-bank, authenticated); Final invoice (against outturn assay); Settlement confirmation / custody account entry; Central clearing ledger entry (unallocated gold balance)
Official guidance
[inferred] Settlement mechanics for bilateral OTC outside central clearing are market practice.
38
Report any knowledge or suspicion that property is crime proceeds to JFIU through STREAMS 2 (applies to everyone, not only registrants); do not tip off
Who
Registered bullion dealer / trader (DPMS registrant)
Issues
Suspicious transaction report to JFIU (STREAMS 2)
Primary law
- OSCO (Cap. 455), DTROP (Cap. 405), UNATMO (Cap. 575), Cap. 455 s. 25A(1), (5), (7); Cap. 405 s. 25A(1); Cap. 575 s. 12(1), (5)
  “Where a person knows or suspects that any property— (a) in whole or in part directly or indirectly represents any person’s proceeds of; (b) was used in connection with; or (c) is intended to be used in connection with, an indictable offence, he shall as soon as it is reasonable for him to do so disclose that knowledge or suspicion … to an authorized officer”

Taxes and fees

Customs duty on gold
Nil All gold imports and exports; the Ordinance applies only to alcoholic liquors, tobacco, aircraft spirit, light diesel oil, motor spirit, kerosene and methyl alcohol (s.3(1))
Primary lawAmount not confirmed
- Dutiable Commodities Ordinance (Cap. 109), ss. 3(1), 4(1)
Profits tax on gold trading profits
Corporations: 8.25% on the first HK$2,000,000 of assessable profits and 16.5% above (Sch. 8B s.2(a)); unincorporated businesses: 7.5% and 15% (Sch. 8A s.2); years of assessment from 1 April 2018 Trading profits of Hong Kong gold dealers; not a transaction tax
Primary lawAmount not confirmed
- Inland Revenue Ordinance (Cap. 112), s. 14; Schs. 8A, 8B
  “Subject to the provisions of this Ordinance, profits tax shall be charged for each year of assessment on every person carrying on a trade, profession or business in Hong Kong in respect of his assessable profits arising in or derived from Hong Kong for that year from such trade, profession or business (excluding profits arising from the sale of capital assets)”
VAT / GST on gold
None (Hong Kong has no VAT or GST) Import and sale of gold
UnverifiedAmount not confirmed
Import/export declaration charge
Nil on declarations relating to gold bars (reg. 8(4)); C&SD defines these as gold bars of fineness 995.0 or above, HKHS codes 7108 1210 and 7108 2010, declared on Forms 1B/2B. Other gold (e.g. dore below 995.0): HK$0.20 for value up to HK$46,000, then 12.5 cents per additional HK$1,000 or part, rounded up to 10 cents, capped at HK$200 per declaration (reg. 8(1)(b)-(d), (1AA)) Each import and export declaration
Primary lawAmount not confirmed
- Import and Export (Registration) Regulations (Cap. 60E), reg. 8(1), (1AA), (4); reg. 7
  “No charge shall be payable under paragraph (1)(b), (c) or (d) in respect of a declaration relating to gold bars within the meaning of the Imports and Exports Classification List”

Controls

A Category B registrant must, before a specified cash transaction (cash of HK$120,000 or more) with a customer, identify and verify the customer and any beneficial owner, obtain the purpose of a business relationship and verify anyone acting for the customer (Sch. 2 ss.2, 3(1)(b)); obtain senior-man…
Cash payment of HK$120,000 or more
Primary law
- AMLO (Cap. 615) s. 5A and Sch. 2; C&ED Guideline for Category B registrants, s. 5A(5A)-(5B); Sch. 2 ss. 2, 3, 5, 10, 15, 19, 20; s. 53ZVF
  “for a period of at least 5 years beginning on the date on which the transaction is completed”
A non-Hong Kong dealer (an individual not ordinarily resident, or a foreign legal person that is neither a registered non-Hong Kong company nor a re-domiciled company; no place of business in Hong Kong; business in Hong Kong on no more than 60 days a year) is outside registration but must report eac…
HK$120,000 cash
Primary lawAmount not confirmed
- AMLO (Cap. 615) Part 5C, ss. 53ZTZ, 53ZUA(2), 53ZVK; Sch. 3J
Any person who knows or suspects that property represents proceeds of, or was or is intended to be used in connection with, an indictable offence (OSCO s.25A(1)) or drug trafficking (DTROP s.25A(1)), or that property is terrorist property (UNATMO s.12(1)), must disclose it to an authorized officer (…
Primary law
- OSCO (Cap. 455), DTROP (Cap. 405), UNATMO (Cap. 575), Cap. 455 s. 25A; Cap. 405 s. 25A; Cap. 575 s. 12
  “Where a person knows or suspects that any property— (a) in whole or in part directly or indirectly represents any person’s proceeds of; (b) was used in connection with; or (c) is intended to be used in connection with, an indictable offence, he shall as soon as it is reasonable for him to do so disclose that knowledge or suspicion … to an authorized officer”
Hong Kong applies only UN Security Council sanctions, through regulations the Chief Executive makes under Cap. 537 on instructions from the Ministry of Foreign Affairs (ss.2-3); dealing with funds or economic resources of designated persons without a licence is an offence under those regulations (C&…
Primary law
- United Nations Sanctions Ordinance (Cap. 537), ss. 2-3
  “the Ministry of Foreign Affairs of the People’s Republic of China”
Currency and bearer negotiable instruments above HK$120,000 (Sch. 4) must be declared by arriving travellers (s.4), disclosed on request by other arrivals and by departing travellers (ss.5-6), and declared in advance electronically when moved as cargo in one batch (ss.9-11). "CBNI" means notes or co…
HK$120,000 of CBNIs
Primary lawAmount not confirmed
- Cap. 629, ss. 2, 4-6, 9-11; Sch. 4
The central clearing system accepts only about-400-oz bars meeting international standards (in effect LBMA Good Delivery) into designated vaults, held unallocated and commingled.
Official guidance
- Clearing Rulebook
No new commodity exchange may be established or operated for gold, silver or the other listed commodities (Cap. 82 s.4 and Schedule items 6, 13; fine HK$500,000 plus HK$50,000 a day), except an exchange "which was in operation on 20 June 1973" (s.3(d)) or a recognized futures market under the Securi…
Primary law
- Commodity Exchanges (Prohibition) Ordinance (Cap. 82), ss. 3(d)-(e), 4; Schedule
  “(e) a recognized futures market”
Anyone who by way of business trades in, imports, exports, manufactures, refines or carries out value-adding work on precious metals (gold "in a manufactured or unmanufactured state"), issues or trades precious-asset-backed instruments, or acts as intermediary (s.53ZU(1)) must be registered before c…
HK$120,000 per transaction or linked transactions
Primary lawAmount not confirmed
- AMLO (Cap. 615) Part 5C, ss. 53ZTZ, 53ZU, 53ZUA, 53ZUE; Schs. 3H, 3I
Only bars from HKGX authorised minters (13 members) are good delivery on the exchange, by type: 99 gold 5-tael, 999.9 gold kilo, 999.9 gold 5-tael and 999.9 silver 15 kg.
Industry practice
- HKGX rules
A Legislative Council question of May 2026 refers to "the current 50-gram limit" on gold products for personal use carried by Mainland visitors, and asks about "simplifying the tax collection process for amounts exceeding the limit"; the limit is a Mainland rule. The Government replied only that Hon…
50 g (per LegCo question; Mainland rule not read)
SecondaryAmount not confirmed
Gold entering the Mainland from Hong Kong under general trade needs a PBOC Gold and Gold Products Import/Export Permit presented to customs (Art. 3), issued only to qualified importers (Art. 8, e.g. financial-institution members or market makers of the State Council-approved gold exchange); "one bat…
Primary law
- PBOC/GACC gold import-export measures (Order [2015] No. 1, amended 2020), Arts. 3, 4, 6, 8, 17, 20
No import or export licence, permit or duty applies to gold. Licences are needed only for articles listed in the regulations under Cap. 60 (s.6C: Cap. 60A Sch. 1; s.6D: Cap. 60A Sch. 2; s.6A: strategic commodities), and gold is not listed in Cap. 60A Schedules 1-2. The only customs formality is the …
Primary law
- Import and Export Ordinance (Cap. 60) and regulations, Cap. 60 ss. 6A, 6C, 6D; Cap. 60A Schs. 1-2; Cap. 60E regs 3-5

Leg 4: Australia

Back in the origin country: the proceeds of the export

39
Price the sale against the LBMA Gold Price (commonly in AUD) or a forward/hedge contract
Who
Mining tenement holder (mining lease) operating a gold mine and mill
Issues
LBMA Gold Price PM (AUD) reference
Industry practice
Commercial pricing practice not documented; the LBMA PM fix is the statutory WA royalty reference.
40
Transfer metal from the miner's metal account to the buyer, or deliver bars, against payment
Who
Australian gold refiner (LBMA Good Delivery-listed)
Issues
Payment for gold sold
Industry practice

Crossings between countries

Australia → Russia Not researched
Papers that cross: AUSTRAC enrolment; AML/CTF program; Outturn / assay statement; Metal account statement; Bar list for refined bars; 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
Russia → Hong Kong SAR China Researched
Papers that cross: FPP application for import control; Act of state control on import; EAEU goods declaration for import / customs processing; 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