Nigeria → Canada (refine) → United Arab Emirates · Reconcile assays and pay the balance

Extract ore within licensed area; process by gravity concentration and, commonly, mercury amalgamation

Who

Miner (artisanal/small-scale or licensed company)

Form

Ore (in situ / run-of-mine) → Sponge gold

• NMMA, s.90 (area of a Small-scale Mining Lease, rehabilitation of mined-out areas, mining restricted to established zones of mineralisation)

Smelt sponge gold with flux into a button/bar

Who

Miner (artisanal/small-scale or licensed company)

Issues

Unique reference number on each doré bar or sealed container of alluvial gold

Form

Sponge gold → Doré bar - unstamped

[unconfirmed] Smelting with flux is common practice not described in the OECD Supplement on Gold (3rd ed. 2016), whose "Gold sources" definitions say alluvial gold "may be easily melted and/or semi-refined into small ingots (normally of 85% - 92 % purity)" and "can ordinarily be directly refined", and associate doré with medium and large-scale mines.

Pay royalty monthly and file two returns: 15% ad valorem on gold concentrate (Nigeria Tax Act 2025, Eighth Schedule, from 1 Jan 2026), valued at the Ministry of Solid Minerals' official selling price or ruling international prices; monthly production return (Form 17) to the Mines Inspectorate before the 20th, and monthly royalty self-assessment return to the Nigeria Revenue Service by the 21st

Who

Miner (artisanal/small-scale or licensed company)

Issues

Royalty payment receipt; Monthly return on Form 17 ("Monthly returns on mineable & quarriable minerals", headed "Regulation 112 (a)" in the Cadastre Office copy): licence number, mineral, location, labour and wages (Nigerians / non-Nigerians), quantities won, used, sold and left on hand (tons or m3) with values, State, zone, remarks; certified by the lease manager or responsible person; due on the 20th day of the following month; Monthly royalty self-assessment return to the NRS: licence number, mineral and weight, location and labour, quantity won/sold/used/on hand, buyers, computation, evidence of payment, signed declaration - due by the 21st

[conflict] ng.div-tax-act-versions: two texts of the NTA and NTAA are held. The royalty table (Eighth Schedule, gold concentrate 15%) is the same in both; the gazetted NTAA s.20(1)(b) cites the "Seventh" schedule and the National Assembly text the "Ninth" - neither is the Eighth; printed commencement 26 June 2025 (gazette) vs 1 January 2026 (National Assembly text; the date applied). [inferred] The Eighth Schedule lists only "GOLD CONCENTRATE" (15%) and "ANY OTHER MINERAL" (10%); the OECD Gold Supplement defines concentrate as an intermediate still needing processing "to produce doré", so whether doré or alluvial gold is charged 15% or 10% is interpretive. [time-limited] NMMA s.33 (royalty "as prescribed in the regulations") was deleted by NTA s.197(9) (gazette numbering); Regs Schedule 4 (3%) and the MSMD notice of 4 July 2024 (3% on N1,081,200/oz) applied to 31 Dec 2025. [unconfirmed] no official selling-price list newer than July 2024 found. [ocr] reg 123 checked against gazette page image p.104; Form 17 read from the Cadastre Office page image. [blocked] Rev360 is a login shell, so the return form fields come from NTAA s.20(2).

• Nigeria Tax Act 2025; Nigeria Tax Administration Act 2025; Minerals and Mining Regulations 2011, NTA s.64(3)-(4) and Eighth Schedule paras 1-3, item 25 (gold concentrate 15%); NTAA s.20(1)-(2), s.63, s.123; Regs 99(1)-(2), 123

Customer due diligence on the miner / mining company before buying: identity (incl. NIN), proof of the company's existence, beneficial owners, source of funds; screen and keep records 5 years

Who

Mineral Buying Centre (MBC)

Issues

Buying centre CDD file on the miner / mining company: identity (incl. NIN), the company's name, legal form and proof of existence, beneficial owners (5%+), source of funds

[inferred] For a company, proof of existence is usually its Corporate Affairs Commission (CAC) documents; the Regulations do not name them.

• MLPPA 2022; EFCC AML/CFT/CPF Regulations for DNFBPs 2024, s.4, s.8, s.30; regs 18(2), 24(3), 40(5)-(6)

Sell gold to a licensed Mineral Buying Centre and obtain a valid sales receipt

Who

Miner (artisanal/small-scale or licensed company)

Needs

Buying centre CDD file on the miner / mining company: identity (incl. NIN), the company's name, legal form and proof of existence, beneficial owners (5%+), source of funds; Unique reference number on each doré bar or sealed container of alluvial gold

Issues

Sales receipt from the Mineral Buying Centre to the miner (NMMA s.95); Bank transfer record for payment to the miner

• NMMA 2007; MLPPA 2022, s.95 (sale to buying centre, valid sales receipts); MLPPA s.2(1) (cash limit)

Log the purchase, recording which mine the mineral came from

Who

Mineral Buying Centre (MBC)

Issues

MBC purchase/sale record naming mine of origin (NMMA s.96)

[ocr] Regs 133(4)(a) and 232(i) read in the gazette OCR and the Cadastre Office text.

• NMMA 2007; Minerals and Mining Regulations 2011, s.96(2); Regs 133(4)(a), 232(i)

If a single transaction, lodgment or transfer of funds exceeds N5m (individual) / N10m (body corporate): report it to SCUML in writing within 7 days. A cash payment above those sums is itself unlawful unless made through a financial institution

Who

Mineral Buying Centre (MBC)

Issues

Report to SCUML of any single transaction, lodgment or transfer of funds above N5m (individual) / N10m (body corporate), in writing within 7 days

Conditional step. MLPPA read in full in the gazette text (NFIU copy) 2026-09-28.

• MLPPA 2022, s.11(1) (report to SCUML within 7 days); s.2(1) (cash payment limit)

Negotiate and sign a Sale and Purchase Agreement: price = LBMA AM/PM reference on an agreed pricing date, +/- a premium/discount for location and form

Who

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

Issues

SPA between exporter and Dubai importer: price = LBMA reference +/- premium/discount, pricing-date mechanism; LBMA AM/PM gold price on the agreed pricing date

• Contract law; LBMA Gold Price administered by ICE Benchmark Administration

Consolidate gold purchased across multiple miners or buying centres, keeping each lot's purchase record and evidence of its source of supply

Who

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

Needs

MBC purchase/sale record naming mine of origin (NMMA s.96)

Issues

Exporter's record verifying weight and quality declared by the producer; Evidence of source of supply (purchase records and receipts tracing each lot to licensed buying centres / titles)

The export permit asks for evidence of source of supply; the royalty evidence it asks for is the export-stage royalty receipt (ng.gold.st-54), not the miner's receipt, which buying centres do not collect.

• reg 131(3)(iv)-(v)

  “Evidence of source of supply; (v) Evidence of the payment of royalties on the minerals to be exported”

Obtain fire-assay of the consolidated lot

Who

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

Issues

Fire-assay report, National Geosciences Research Laboratory Centre, Kaduna

Form

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

Whether this is a hard legal precondition to the export permit, or best-practice feeding it, was not confirmed from primary text

Register/renew as exporter with NEPC

Who

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

Issues

Certificate of origin; Evidence of NEPC registration

Mines Inspectorate assesses the export-stage royalty (3% ad valorem on gold) on the lot; the exporter pays; the receipt is filed with the Form 22 application as the evidence of the payment of royalties on the minerals to be exported

Who

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

Issues

Receipt for the royalty assessed on the lot to be exported: the evidence the export permit requires

[unconfirmed] whether the Nigeria Revenue Service collects it from 2026 (ng.gold.gap-export-royalty-2026).

• reg 131(3)(v)

  “Evidence of the payment of royalties on the minerals to be exported”

• reg 131(2)

  “An application for the issuance of permit to export minerals for commercial purpose shall be made to the Mines Inspectorate Department in the prescribed Form 22 in Schedule 3”

• Schedule 4 (gold)

  “4 Gold 3 5 Gypsum 5”

• Schedule 3, Form 22 item 7

  “7. Amount due as Royalty”

Apply to the Mines Inspectorate on Form 22 for a Permit to Export Minerals for Commercial Purpose; issued on Form 23 (fee: N10,000 in Regs Schedule 1 item 18(a); N100,000 in the MSMD fee notice of 4 July 2024)

Who

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

Needs

Certificate of Incorporation; Three years' Tax Clearance Certificate; Evidence of NEPC registration; Evidence of source of supply (purchase records and receipts tracing each lot to licensed buying centres / titles); SPA between exporter and Dubai importer: price = LBMA reference +/- premium/discount, pricing-date mechanism; Receipt for the royalty assessed on the lot to be exported: the evidence the export permit requires

Issues

Form 22 application: applicant; CAC and NEPC registration numbers and dates; address for notices; source of supply (lease no., grant and expiry dates, or possess/purchase permit no.); mineral types and weights; amount due as royalty; buyer's contact details; signed declaration; Revenue Collector's Receipt for the export-permit fee, quoted on the permit's payment schedule (N10,000 under Regs Schedule 1 item 18(a); N100,000 under the MSMD fee notice of 4 July 2024); Permit to Export Minerals for Commercial Purpose (Form 23): permit number, exporter, minerals and quantities, destination, fee receipt (RCR) number; signed by the Director of Mines Inspectorate for the Minister and copied to the Area Controller of Customs

[ocr] reg 131 checked against gazette page images pp.106-107. [inferred] Neither version says whether a permit covers one shipment; the Form 23 layout (named minerals, quantities and destination) points to a per-consignment permit. [conflict] ng.div-regs-form-numbering: Forms 22/23 are captioned "Regulation 117" in the Cadastre Office copy. [conflict] ng.div-fees-2024: fee. NTAA s.72(4)(e) also requires a tax clearance certificate for an application for an export licence. NEITI 2021 found Customs does not reliably verify permit numbers (ng.div-neiti-permit-check).

• Minerals and Mining Regulations 2011, reg 131(1)-(3); Schedule 1 item 18(a)

Register Form NXP through an Authorised Dealer bank (free of charge); open an export domiciliary account at that bank; quote the NXP number in all dealings with the bank, CBN, inspection agent and Customs

Who

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

Needs

Certificate of origin; Permit to Export Minerals for Commercial Purpose (Form 23): permit number, exporter, minerals and quantities, destination, fee receipt (RCR) number; signed by the Director of Mines Inspectorate for the Minister and copied to the Area Controller of Customs

Issues

e-NXP submission, bank-approved; Proforma / provisional invoice from the Nigerian exporter (against pre-shipment assay)

• CBN Foreign Exchange Manual, 4th Edition (May 2026), Memorandum 10.A (non-oil exports) i-v

Processing bank approves Form NXP; the inspection agent then sends the exporter a Request for Information (RFI) link on the Stakeholders Verification Portal

Who

Authorised Dealer bank (Nigeria)

Needs

e-NXP submission, bank-approved

Issues

e-NXP submission, bank-approved; Request for Information (RFI) on the Stakeholders Verification Portal: NXP no., RFI no., exporter and importer, description of goods, quantity, units, unit price; inspector completes the inspection section

Inspect the consignment within 48 hours of the RFI, at the approved location with Nigeria Customs and other agencies present, checking quantity and quality to determine fair value

Who

Pre-shipment inspecting agent (NESS)

Needs

e-NXP submission, bank-approved; Request for Information (RFI) on the Stakeholders Verification Portal: NXP no., RFI no., exporter and importer, description of goods, quantity, units, unit price; inspector completes the inspection section

• CBN Foreign Exchange Manual 4th Ed.; Pre-Shipment Inspection of Exports Act, Memorandum 10.A vi-vii, xi

After inspection, pay the assessed NESS levy (0.5% of FOB value) through a designated bank and deliver the receipt to the inspection agent

Who

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

Needs

e-NXP submission, bank-approved

Issues

NESS fee payment receipt

[conflict] Timing of payment: FX Manual 10.A.viii (followed) - after inspection; Anglia International - at a designated bank when Form NXP is submitted, i.e. before inspection; the NPA guide - paid on the intended export value, with an additional charge if inspection finds a higher FOB value.

• CBN Foreign Exchange Manual 4th Ed.; Pre-Shipment Inspection of Exports Act, Memorandum 10.A viii; Act s.14(2)

Once it holds Form NXP and the NESS levy receipt, the inspection agent issues the Clean Certificate of Inspection (NEPC: within 72 hours of inspection; Anglia: within 3 working days); where a discrepancy cannot be corrected, it issues a Non-negotiable Certificate of Inspection instead

Who

Pre-shipment inspecting agent (NESS)

Needs

Proforma / provisional invoice from the Nigerian exporter (against pre-shipment assay); NESS fee payment receipt; e-NXP submission, bank-approved

Issues

Clean Certificate of Inspection

No replacement or renewal of the Jan 2021 non-oil appointments was found for 2022-2026; the agents' sites are still active (Neroli 2026, Anglia 2025). Zones as published by NEPC (June 2022) and reported from the CBN circular of 26 Jan 2021: Anglia - North West and North Central; Neroli - South West and South-South; Gojopal - South East and North East. [inferred] Abuja/FCT falls in North Central. [conflict] Timing: FX Manual 10.A.xi and NEPC (2022) - within 72 hours of inspection; Anglia - within 3 working days; the Act sets no time. The later CBN appointments found (May 2024; 15 June 2026 per the CBN Reforms page) concern oil and gas terminals only.

• CBN Foreign Exchange Manual 4th Ed.; Pre-Shipment Inspection of Exports Act, Memorandum 10.A ix, xi-xiii; Act s.1(1), s.8(1)(b) (non-negotiable certificate), s.9(1)

  “no goods to which this Act applies shall be exported from Nigeria unless an inspecting agent … has issued in respect of the goods a Clean Certificate of Inspection”

File the export declaration (Single Goods Declaration) on the Customs system: NICIS II, being replaced by B'Odogwu

Who

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

Needs

e-NXP submission, bank-approved; Permit to Export Minerals for Commercial Purpose (Form 23): permit number, exporter, minerals and quantities, destination, fee receipt (RCR) number; signed by the Director of Mines Inspectorate for the Minister and copied to the Area Controller of Customs; Certificate of origin; Fire-assay report, National Geosciences Research Laboratory Centre, Kaduna; Clean Certificate of Inspection

Issues

Single Goods Declaration (NICIS II)

[unconfirmed] B'Odogwu replaces NICIS II and handles the Single Goods Declaration; its published rollout (PTML, Apapa, Tin Can Island, Port Harcourt Area II, Kano/Jigawa, Industrial Area Command) names no airport, so which system serves the airport commands is not confirmed. [conflict] ng.div-tax-act-versions: VAT section number.

• Nigeria Customs Service Act; Nigerian Minerals and Mining Act; Nigeria Tax Act (sections in refs), Nigeria Customs Service Act 2023 (No. 35 of 2023) s.148(1): export declaration lodged before goods leave

  “Goods destined to leave the customs territory including oil and gas shall be covered by an export declaration lodged at the relevant customs office before the goods are taken out of the customs territory.”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Act; Nigeria Tax Act (sections in refs), s.76: export value uses the valuation methodology of ss.69-74 (in this record the text of s.76 is parsed into section s-74)

  “The valuation methodology contained in sections 69-74 of this Act shall be used to determine the value of goods for export”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Act; Nigeria Tax Act (sections in refs), s.67(1)(a)

  “determine and declare the classification, valuation and origin of the goods”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Act; Nigeria Tax Act (sections in refs), s.79(2)(a): minerals exploited from Nigerian soil are wholly obtained there

  “mineral products exploited from its soil, territory water or sea-bed”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Act; Nigeria Tax Act (sections in refs), Nigerian Minerals and Mining Act 2007 s.143(1)(a)

  “before the mineral is entered for export declared on the appropriate customs entry from the State from which the mineral was extracted”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Act; Nigeria Tax Act (sections in refs), Nigeria Tax Act 2025 s.186 (National Assembly text; s.187 in the gazetted text, see ng.div-tax-act-versions)

  “the following taxable supplies are charged to VAT at the rate of zero percent”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Act; Nigeria Tax Act (sections in refs), s.186(n)

  “exported goods excluding oil and gas”

Nigeria Customs: document check, physical/X-ray examination, verify NXP/export-permit numbers, release

Who

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

Needs

Single Goods Declaration (NICIS II); e-NXP submission, bank-approved; Permit to Export Minerals for Commercial Purpose (Form 23): permit number, exporter, minerals and quantities, destination, fee receipt (RCR) number; signed by the Director of Mines Inspectorate for the Minister and copied to the Area Controller of Customs; Clean Certificate of Inspection

Issues

Customs release for export ("Export Release Note" in the NPA guide), granted as "release for exit" on the accepted declaration (NCS Act s.149(4))

The Act names no separate release document - "release for exit" is granted on the accepted declaration; the NPA guide calls it the Export Release Note. [not-read] The FMITI step pages for "Customs clearance at the airport in Abuja" are not held (index page only), so the airport sequence recorded earlier (NAHCO warehouse, joint inspection, NDLEA, NCS release, aviation security screening) is not confirmed and was removed from the notes. [ocr] The Regulations' seizure rule was checked against the gazette page image.

• Nigeria Customs Service Act; Nigerian Minerals and Mining Regulations (sections in refs), Nigeria Customs Service Act 2023 s.149(2): goods presented at the exit office; exit formalities

  “Goods leaving the customs territory shall be presented to the customs office at the place of exit or at any other place designated by the Service”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Regulations (sections in refs), s.149(2)(c)(vi): prohibitions incl. money laundering

  “money laundering and other cash transfers contrary to law”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Regulations (sections in refs), s.149(4): release for exit

  “Release for exit shall be granted to condition that the goods leave the customs territory in the same condition as when the export declaration was accepted.”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Regulations (sections in refs), s.150(2): loading before acceptance / goods not matching the declaration

  “commits an offence and is liable on conviction to imprisonment for a term of five years without an option of fine.”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Regulations (sections in refs), s.246(b): forfeiture of goods exported contrary to a prohibition (in this record the text of s.246 is parsed into section s-245)

  “the exportation of the goods is or would be contrary to any prohibition”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Regulations (sections in refs), Nigerian Minerals and Mining Regulations 2011 reg 132(3): seizure without export permit

  “shall seize any Mineral Commodity for export at the Port if the owner fails to present to the Custom Officer an export permit for sale or permit to export minerals for analysis”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Regulations (sections in refs), reg 132(4)

  “be conveyed to the Mines Inspectorate Department within 72 hours of the seizure.”

• Nigeria Customs Service Act; Nigerian Minerals and Mining Regulations (sections in refs), CBN Foreign Exchange Manual, Memorandum 10.A.xiii (no CCI, no loading)

• Nigeria Customs Service Act; Nigerian Minerals and Mining Regulations (sections in refs), NPA export procedure guide (Export Release Note)

Secure road transport, exporter premises -> Lagos/Abuja airport cargo area

Who

Secure logistics provider (Nigeria leg)

Needs

Single Goods Declaration (NICIS II); Customs release for export ("Export Release Note" in the NPA guide), granted as "release for exit" on the accepted declaration (NCS Act s.149(4)); Letter of identification as accredited agent (Form 30 in the Cadastre Office copy; Form 29 in the gazette): bearer, minerals, title/licence number, principal, mine site and destination of the movement

Issues

Packing list; Certificate of insurance

No gold-specific MMIA/airport procedure document was located; escort/desk arrangements are inferred from general secure-logistics practice, not a cited regulation

Airline acceptance of valuable cargo (IATA VAL special handling code) with a Consignment Security Declaration

Who

Secure logistics provider (Nigeria leg)

Issues

Consignment Security Declaration; Air waybill, Lagos/Abuja -> Dubai

[unconfirmed] The IATA VAL special handling code for valuable cargo is not stated in the sources read. Nig.CARs Part 17 read in the 2015 edition (S.I. 36 of 2015), held in laws/; 17.74.2 quoted.

• IATA Resolution 651 (Consignment Security Declaration programme); Nigeria Civil Aviation Regulations (Nig.CARs) Part 17, Nig.CARs 17.74.2 (goods accepted only with a valid consignment security declaration)

Send the pre-shipment notice to the Dubai importer/refiner (weights, estimated fineness, value, flight, AWB)

Who

Exporter (Possess/Purchase + MBC + NEPC + Mineral Export Permit holder)

Needs

Air waybill, Lagos/Abuja -> Dubai; Packing list

Issues

Pre-shipment notice: box count, weights, packing list, estimated fineness, value, carrier, flight, AWB

Hold a Business Number with RM import-export program account, registered in the CARM Client Portal (and optional RPP financial security)

Who

Importer of record (doré, scrap or bars for refining)

Present the shipment for release: classify doré as 7108.12.00.22 (bars 7108.12.00.11/.21, scrap 7112.91) - all Free under MFN and every preferential tariff; no import permit; gold goods from Russia or a person in Russia (Schedule 9) and precious-metal scrap from Russia (Schedule 13) are prohibited; goods produced wholly or in part by forced labour are prohibited

Who

Licensed customs broker

Needs

Export customs declaration accepted by the dispatching country's customs; Commercial invoice; Air waybill

Issues

Commercial invoice from the foreign shipper

Forced-labour prohibition: Customs Tariff item 9897.00.00 (ca.src-tariff-ch98). MFN is not available for goods of Belarus, North Korea or Russia (guide-3).

• Customs Tariff; SEMA (Russia) Regulations, Tariff item 7108.12.00; SEMA (Russia) ss.3.11, 3.16

Account for the goods on a Commercial Accounting Declaration (Type C at release, or Type AB within five business days of release under RPP) and pay duties and taxes on the statement of account; imported precious-metal bars are non-taxable for GST, and doré, unwrought gold, scrap and concentrates imported to be refined are non-taxable

Who

Importer of record (doré, scrap or bars for refining)

Needs

Commercial invoice from the foreign shipper

Issues

Commercial Accounting Declaration

• Customs Act; Accounting for Imported Goods and Payment of Duties Regulations; Excise Tax Act; Non-Taxable Imported Goods (GST/HST) Regulations, Customs Act s.32; SOR/86-1062 s.10; ETA Sched VII s.8; SOR/91-31 s.3(a), (b)

Keep import records for 6 years; self-correct within 90 days; CBSA may verify origin, value and classification for 4 years

Who

Importer of record (doré, scrap or bars for refining)

Needs

Commercial Accounting Declaration

90-day correction duty read in Customs Act s.32.2(2); six-year retention and four-year verification from CBSA guide-7 and D17-1-21 (the regulation fixing the period was not read).

Onboard the supplier: KYC, OECD five-step risk assessment, sanctions/PEP/adverse-media screening, confirm gold is not imported, purchased or acquired from Russia or a person in Russia

Who

Private LBMA Good Delivery refiner in Canada

Needs

Refining (toll) agreement, mine - Canadian refiner; Origin country's export authorisation for the gold (permit, licence or clearance issued by the mining or trade authority)

Issues

Supplier KYC pack and acknowledgement of the refiner's procurement policy; Onboarding and daily screening record; non-Russian origin confirmation

[inferred] SEMA element is law; KYC and OECD process are LBMA/refiner practice, not a Canadian statute for refiners.

• SEMA (Russia) Regulations s.3.11; LBMA RGG; OECD DDG, s.3.11

Receive, weigh, melt and sample the lot; assay in the refinery lab and issue the outturn

Who

Private LBMA Good Delivery refiner in Canada

Needs

Supplier KYC pack and acknowledgement of the refiner's procurement policy; Onboarding and daily screening record; non-Russian origin confirmation

Issues

Refiner outturn assay and settlement statement

Refine to 999.9 (or 999.99) and cast LBMA Good Delivery 400 oz bars, 100 oz or 1 kg bars bearing the refiner's mark

Who

Private LBMA Good Delivery refiner in Canada

Issues

Bar list of refined bars (GD 400 oz, 100 oz, kilobars)

Form

Doré bar - stamped/exporter-sealed → LBMA Good Delivery 400oz bar

Settle outturn with the supplier: credit fine metal to its metal account or buy the metal, with final invoice

Who

Private LBMA Good Delivery refiner in Canada

Needs

Refiner outturn assay and settlement statement

Issues

Refiner's final invoice / metal-account credit against outturn

First supply of the refined bars by the refiner (or the owner on whose behalf they were refined) is zero-rated for GST/HST; refining fees charged to the metal owner are generally taxable

Who

Private LBMA Good Delivery refiner in Canada

Issues

Invoice for sale of refined bars (zero-rated first supply by the refiner / exempt resale)

Refining-fee taxability is CRA guidance (17-1 para 35), not a specific statutory provision.

• Excise Tax Act, s.123(1) 'precious metal'; Sched VI Part IX s.3

For any purchase or sale of $10,000 or more as a dealer in precious metals: verify identity, keep records, report cash of $10,000+ (LCTR), virtual currency (LVCTR) and suspicious transactions

Who

Private LBMA Good Delivery refiner in Canada

Issues

Record of $10,000+ purchase or sale and client identification; Large cash transaction report; Suspicious transaction report; Large virtual currency transaction report

s.65(2) excludes purchases/sales in connection with extracting precious metals from a mine or manufacturing a product; its application to refiners buying doré is not settled in the texts read.

• PCMLTF Regulations, ss.65, 66, 126, 148

Optionally hold refined bars in allocated (segregated, identified bars) or unallocated storage at the Royal Canadian Mint vaults in Ottawa or Winnipeg (institutional clients only), with semi-annual counts

Who

Royal Canadian Mint (federal Crown corporation: refinery and vault)

Needs

Bar list of refined bars (GD 400 oz, 100 oz, kilobars)

Issues

Allocated weight list / unallocated account statement

Re-export imported or toll-refined bars: file CERS export declaration (non-US destinations, CAD 2,000+) and hand the proof of report number to the carrier

Who

Exporter of record (mine, refiner or bullion trader)

Needs

Commercial Accounting Declaration

Issues

CERS export declaration and proof of report number

Carry the re-exported bars under air waybill

Who

Secure precious-metals carrier / airline

Needs

CERS export declaration and proof of report number

Issues

Air waybill

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

Credit export proceeds to the exporter's export domiciliary account at the bank where the NXP was registered, within 180 days of the bill of lading / air waybill date; CBN monitors banks on repatriation

Who

Authorised Dealer bank (Nigeria)

Issues

Credit of export proceeds to the exporter's export domiciliary account at the NXP bank

[inferred] The Manual speaks of the bill of lading; for air freight the air waybill is the equivalent transport document.

• CBN Foreign Exchange Manual 4th Ed., Memorandum 10.A iii, xiv(a) (180 days for non-oil; 90 days applies to oil and gas); Memorandum 20; Appendix II Contravention 6