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Indonesia (refine) → Australia → Singapore · Sale or purchase of gold in Singapore

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

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Indonesia (Doré bar - unstamped → 999.9 kilobar) ⟶ Australia (999.9 kilobar) ⟶ Singapore (999.9 kilobar)

Not researched: Indonesia → Australia, Australia → Singapore

Leg 1: Indonesia

Where the goods start

Doré bar - unstamped → 999.9 kilobar

  1. 1

    Sell 999.9 bars to a bullion institution; from 1 Aug 2025 no PPh 22 is collected on this sale; the LJK bulion collects 0.25% PPh 22 on its purchases above IDR 10 million from non-exempt sellers

    Who
    LBMA Good Delivery refiner (state-owned; the only LBMA-accredited refiner in Indonesia)
    Needs
    Refiner bar certificate / bar list for 999.9 bars
    Issues
    PPh Article 22 collection slip (0.25%)
    Official guidance
    • PMK 48/2023 as amended by PMK 52/2025; PMK 81/2024 as amended by PMK 51/2025

  2. 2

    Hold bullion (min 99.9% Au) for customers: gold deposits, financing, trading, custody

    Who
    Bullion financial institution (LJK bulion)
    Needs
    OJK bullion business licence
    Issues
    Bullion institution custody/deposit account entry
    Secondary
    • POJK 17/2024

  3. 3

    Sell gold bars or jewellery: PPh 22 at 0.25% of selling price on bar sales (except to consumers, Bank Indonesia, digital gold market, bullion institutions); VAT on jewellery at 1.1% (to traders) or 1.65% (to consumers)

    Who
    Gold bar / gold jewellery business (pengusaha emas batangan / emas perhiasan)
    Issues
    VAT invoice (faktur pajak) - PPN besaran tertentu on gold jewellery; PPh Article 22 collection slip (0.25%)
    Primary law
    • PMK 48/2023, Arts 2(5), 5, 14(4)

  4. 4

    Know-your-customer; report cash or equivalent transactions of IDR 500 million or more and suspicious transactions to PPATK within 14 working days

    Who
    Gold bar / gold jewellery business (pengusaha emas batangan / emas perhiasan)
    Issues
    Cash transaction report (LTKT) to PPATK; Suspicious transaction report (LTKM) to PPATK
    Primary law
    • UU 8/2010, Arts 17, 27

  5. 5

    Hold an IPR for a WPR area (max 5 ha individual / 10 ha cooperative) before mining; start within 3 months

    Who
    People's-mining permit holder (IPR: local individual or local cooperative)
    Issues
    Izin Pertambangan Rakyat (IPR)
    Primary law
    • UU 3/2020, Arts 67, 68, 70

  6. 6

    Extract alluvial or shallow primary ore (no explosives, no underground work by individuals) and concentrate by gravity

    Who
    People's-mining permit holder (IPR: local individual or local cooperative)
    Needs
    Izin Pertambangan Rakyat (IPR)
    Form
    Ore (in situ / run-of-mine) → Concentrate / black sand
    Primary law
    • PP 96/2021, Art 66

  7. 7

    Recover gold from concentrate and smelt to a button; use of banned hazardous substances (mercury) is prohibited, though amalgamation and cyanide remain common in practice

    Who
    People's-mining permit holder (IPR: local individual or local cooperative)
    Issues
    Lot number marked on doré/button at mine site
    Form
    Concentrate / black sand → Smelted button/bar
    Secondary

    Legal prohibition read only in general terms (banned hazardous substances); mercury and cyanide use from press reports.

  8. 8

    Pay the people's-mining fee (iuran pertambangan rakyat) and report activities to the Minister

    Who
    People's-mining permit holder (IPR: local individual or local cooperative)
    Primary law

    Art 70 requires payment of mining fees and reporting; the fee rate was not found (not in PP 19/2025).

    • UU 3/2020, Art 70

  9. 9

    Sell gold to a licensed buyer (IPP holder, refiner or dealer); buying from an unlicensed source is a crime under Art 161

    Who
    People's-mining permit holder (IPR: local individual or local cooperative)
    Issues
    Sale contract / purchase note between miner and buyer; Mine-site production/sale record of gold lot
    Primary law

    Whether IPR output may be sold to IPP holders is not explicit in the Art 135 extract read.

    • UU 3/2020, Art 161

  10. 10

    Hold IUP/IUPK production-operation licence and a processing/refining arrangement in Indonesia

    Who
    Industrial mining company (IUP/IUPK production-operation holder)
    Issues
    IUP/IUPK Operasi Produksi
    Primary law
    • UU 3/2020, Arts 35(3), 102, 103

  11. 11

    Mine ore and process on site to doré (gold mines) or to copper concentrate containing gold (copper-gold mines)

    Who
    Industrial mining company (IUP/IUPK production-operation holder)
    Needs
    IUP/IUPK Operasi Produksi
    Issues
    Lot number marked on doré/button at mine site
    Form
    Ore (in situ / run-of-mine) → Doré bar - unstamped
    Primary law

    Processing routes from the royalty schedule's product lines (emas primer; gold in copper concentrate; gold in anode slime).

  12. 12

    Smelt copper concentrate; refine the anode slime in the precious-metal refinery to 99.99% gold bars

    Who
    Copper smelter with precious-metal refinery (anode-slime refinery)
    Issues
    Refiner bar certificate / bar list for 999.9 bars
    Form
    Concentrate / black sand → 999.9 kilobar
    Industry practice
  13. 13

    Pay royalty (PNBP) at 7%-16% of price, by the monthly HMA gold band

    Who
    Industrial mining company (IUP/IUPK production-operation holder)
    Issues
    PNBP royalty payment proof (royalty on gold)
    Primary law
    • PP 19/2025, Lampiran (emas primer; emas dalam konsentrat tembaga; emas dalam lumpur anoda)

  14. 14

    Deliver doré to the LBMA refiner for toll refining or sale, or sell PMR bars to the state refiner under offtake (30 t/yr contract from Nov 2024)

    Who
    Industrial mining company (IUP/IUPK production-operation holder)
    Needs
    PNBP royalty payment proof (royalty on gold)
    Issues
    Sale contract / purchase note between miner and buyer
    Industry practice
  15. 15

    Onboard supplier: KYC and responsible-sourcing check under LBMA Responsible Gold (source mine, licence, royalty paid)

    Who
    LBMA Good Delivery refiner (state-owned; the only LBMA-accredited refiner in Indonesia)
    Needs
    Sale contract / purchase note between miner and buyer
    Issues
    Refiner supplier KYC / responsible-sourcing file
    Industry practice

    Refiner's supplier document list not published; KYC contents inferred from the LBMA RGG commitment.

    • LBMA Responsible Gold Guidance

  16. 16

    Weigh, sample and assay the doré (fire assay cupellation, ICP-OES) in the KAN ISO/IEC 17025 lab

    Who
    LBMA Good Delivery refiner (state-owned; the only LBMA-accredited refiner in Indonesia)
    Needs
    Refiner supplier KYC / responsible-sourcing file
    Issues
    Refiner intake record: weight, sample and fire-assay result
    Form
    Doré bar - unstamped → Doré bar - stamped/exporter-sealed
    Industry practice
  17. 17

    Refine to 999.9 and cast/mint bars; issue bar certificate and bar list

    Who
    LBMA Good Delivery refiner (state-owned; the only LBMA-accredited refiner in Indonesia)
    Needs
    Refiner intake record: weight, sample and fire-assay result
    Issues
    Refiner bar certificate / bar list for 999.9 bars
    Form
    Doré bar - stamped/exporter-sealed → 999.9 kilobar
    Industry practice
  18. 18

    Return fine gold to toll customer or settle purchase against assay

    Who
    LBMA Good Delivery refiner (state-owned; the only LBMA-accredited refiner in Indonesia)
    Needs
    Refiner bar certificate / bar list for 999.9 bars
    Issues
    Bank transfer record
    Industry practice

    Settlement terms not published.

  19. 19

    Establish exporter identity (NIB) and access to the customs system

    Who
    Gold exporter (company with NIB)
    Unverified

    General practice; not read in PMK 155/2022 extract.

  20. 20

    Prepare commercial invoice and packing list; obtain AWB booking

    Who
    Gold exporter (company with NIB)
    Issues
    Commercial invoice; Packing list; Air waybill
    Primary law
    • PMK 155/PMK.04/2022, Art 12(4)

  21. 21

    Compute export duty: rate (by product and by Kemendag reference price band) x quantity x export price per unit x exchange rate; doré 12.5%/15%, granules 10%/12.5%, cast bars 7.5%/10%, minted bars 7.5%/10%

    Who
    Gold exporter (company with NIB)
    Needs
    Commercial invoice
    Issues
    Export duty (bea keluar) payment proof
    Primary law
    • PMK 80/2025, Arts 3, 4, 5(1)

  22. 22

    Apply for a certificate of origin (SKA) through e-SKA where the buyer or destination requires it

    Who
    Gold exporter (company with NIB)
    Issues
    Surat Keterangan Asal (certificate of origin) via e-SKA
    Official guidance
  23. 23

    Lodge the PPE (export customs declaration) no earlier than 7 days before export and before goods enter the customs area, with invoice, packing list, AWB and export-duty payment proof

    Who
    Gold exporter (company with NIB)
    Needs
    Commercial invoice; Packing list; Air waybill; Export duty (bea keluar) payment proof
    Issues
    Pemberitahuan Pabean Ekspor (PPE, formerly PEB, BC 3.0)
    Primary law
    • PMK 155/PMK.04/2022, Arts 2(1), 12(3)-(4)

  24. 24

    Risk-based document or physical examination; approval for loading

    Who
    Customs (DJBC)
    Needs
    Pemberitahuan Pabean Ekspor (PPE, formerly PEB, BC 3.0)
    Issues
    Customs approval for loading / export (persetujuan ekspor, NPE)
    Primary law
    • PMK 155/PMK.04/2022, Arts 13, 16(2)-(3)

  25. 25

    Carry the consignment as valuable cargo under AWB

    Who
    Airline / secure valuables carrier
    Needs
    Customs approval for loading / export (persetujuan ekspor, NPE); Air waybill
    Industry practice

    Valuable-cargo handling is standard trade practice; no Indonesian gold-specific carrier rule found.

  26. 26

    Passenger carrying gold abroad must declare it to Customs and pay export duty before departure; carrying IDR 100 million or more in cash also requires a declaration

    Who
    Gold exporter (company with NIB)
    Issues
    Cross-border cash declaration to Customs (IDR 100 million or more)
    Secondary
    • PMK 80/2025; UU 8/2010 Art 34

Taxes and fees

  • Export duty (bea keluar) on gold

    Column 1 (reference price USD 2,800-<3,200/oz): doré 12.5%, granules 10%, cast bars 7.5%, minted bars 7.5%. Column 2 (>= USD 3,200/oz): doré 15%, granules 12.5%, cast bars 10%, minted bars 10% Gold doré, granules, cast bars and minted bars

    SecondaryAmount not confirmed
    • PMK 80/2025, Arts 2-5 and Lampiran

  • Income tax Article 22 on gold bar purchases/sales

    0.25% Gold bars; exempt: sales to consumers, Bank Indonesia, digital gold market, bullion institutions (from 1 Aug 2025), holders of exemption certificates

    Primary lawAmount not confirmed
    • PMK 48/2023 as amended by PMK 52/2025; PMK 81/2024 as amended by PMK 51/2025, PMK 48/2023 Arts 2(5), 5

  • Royalty (PNBP) on gold

    7% (HMA < USD 1,800/oz); 10% (1,800-<2,000); 11% (2,000-<2,200); 12% (2,200-<2,500); 14% (2,500-<2,700); 15% (2,700-<3,000); 16% (HMA >= USD 3,000/oz) Primary gold (emas primer), gold in copper concentrate, and gold in anode slime, each at the same banded rates

    Primary lawAmount not confirmed
    • PP 19/2025, Lampiran

  • Royalty on gold under PP 26/2022 (superseded)

    Official guidance
    • PP 26/2022

  • People's mining fee (iuran pertambangan rakyat)

    Primary law
    • UU 3/2020, Art 70

Controls

  • Carrying cash of IDR 100 million or more across the border must be declared to Customs; fine 10% of the cash, max IDR 300 million.

    IDR 100,000,000

    Primary lawAmount not confirmed
    • UU 8/2010, Arts 34, 35

  • Natural-resource export proceeds must be placed in a DHE SDA special account and 100% retained in Indonesia for at least 12 months (from 1 Mar 2025, replacing 30%/3 months); sanction: suspension of export services.

    Primary law
    • PP 36/2023 as amended by PP 8/2025, Arts 6, 7, 16

  • IPR holders may not use explosives or banned hazardous and toxic substances; government targets mercury-free status by 2030.

    Primary law
    • PP 96/2021, Art 66

  • Mining without a permit (PETI) is punishable by up to 5 years' prison and IDR 100 billion fine (Art 158); receiving, processing, transporting or selling minerals not from a permit holder likewise (Art 161).

    Primary law
    • UU 3/2020, Arts 158, 161

  • Precious-metal and jewellery traders are AML reporting parties: KYC, cash/equivalent transaction reports at IDR 500 million or more and STRs to PPATK within 14 working days.

    IDR 500,000,000

    Primary lawAmount not confirmed
    • UU 8/2010; PP 43/2015, UU 8/2010 Arts 17, 23, 27; PP 43/2015 Arts 2(1)(b), 4

  • Bullion for OJK-licensed bullion business must be bars or plates of at least 99.9% Au.

    Secondary
    • POJK 17/2024

  • IUP/IUPK production holders must process and/or refine mineral output in Indonesia; unprocessed ore cannot be exported. Gold leaves as refined bars, and since Dec 2025 doré carries the highest export duty (15%) to push refining at home.

    Primary law
    • UU 3/2020, Arts 102, 103

  • Gold carried by departing travellers must be declared and export duty paid before departure (applied at airports since PMK 80/2025).

    Secondary
    • PMK 80/2025

  • No general statutory cap on cash payments for gold was found; control is through reporting at IDR 500 million.

    Unverified

Leg 2: Australia

On the way

  1. 27

    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.

  2. 28

    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

  3. 29

    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

  4. 30

    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

  5. 31

    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.

  6. 32

    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)

  7. 33

    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”

  8. 34

    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)

  9. 35

    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: Singapore

Where the goods arrive

  1. 36

    Screen the foreign supplier and its owners against MHA terrorist-designation lists, MAS targeted financial sanctions lists and UN lists (myPal); apply enhanced checks if the supplier is in a FATF call-for-action or increased-monitoring jurisdiction; record in the supplier file

    Who
    Registered bullion dealer / trader (PSPM registered dealer)
    Needs
    Certificate of registration as a regulated dealer (PSPM Act); ML/TF/PF enterprise risk assessment and IPPC (internal policies, procedures and controls)
    Issues
    Supplier KYC file (incl. sanctions screening); Sanctions/terrorist-designation screening record (MHA lists, MAS TFS lists, myPal)
    Official guidance

    [inferred] PSPM CDD is triggered by designated transactions and prescribed circumstances (cash/cash equivalent, or gold/DPT payment, above S$20,000), which bank-paid wholesale imports usually are not; supplier screening rests on the entity-level risk assessment (reg 14) and the targeted-financial-sanctions duty (reg 16), and the Guidelines' supplier red flags.

    • PMLTFPF Regulations 2019 regs 14, 16; ACD Guidelines v5.1

  2. 37

    Ship bars by secure air freight to Changi with commercial invoice, packing list and bar list naming the producing refiner

    Who
    Foreign supplier (refiner, bank or trader abroad)
    Needs
    Export customs declaration accepted by the dispatching country's customs; Refiner's certificate for the bars it produced (serials, fineness, weights, year)
    Issues
    Inbound air waybill; Foreign supplier's commercial invoice; Packing list; Bar list from the foreign supplier (serials, weights, fineness, refiner)
    Official guidance
  3. 38

    File a TradeNet In-Non-Payment (GST Relief) permit: declaration type GTR, place of receipt IGPM, HS 7108.13.00 (bars/wafers) or 7108.12.10 (ingots), CA/SC product code BAR/INGOT/WAFER, purity in CA/SC code 1, and the producing refiner's name as supplier

    Who
    Declaring agent (TradeNet)
    Needs
    Foreign supplier's commercial invoice; Packing list; Inbound air waybill; Commercial invoice; Packing list; Air waybill
    Issues
    TradeNet In-Non-Payment (GST Relief) permit for IPM (declaration type GTR, place of receipt IGPM)
    Official guidance
    • GST Act 1993; RIER, s.8(4), s.22(1A); RIER reg 3(1), (2A)

  4. 39

    Clear the consignment at Changi against the approved permit; no customs duty (gold is not a dutiable good) and no import GST for qualifying IPM

    Who
    Singapore Customs
    Needs
    TradeNet In-Non-Payment (GST Relief) permit for IPM (declaration type GTR, place of receipt IGPM)
    Official guidance
  5. 40

    Receive the bars, check serials, weights and hallmarks against the bar list, and book them to the depositor's allocated account

    Who
    Vault operator / precious-metals custodian (incl. in the Changi FTZ Freeport)
    Needs
    Bar list from the foreign supplier (serials, weights, fineness, refiner); TradeNet In-Non-Payment (GST Relief) permit for IPM (declaration type GTR, place of receipt IGPM)
    Issues
    Inbound weight and serial check; Vault deposit receipt and allocated weight list
    Industry practice
  6. 41

    Keep the import permit, purchase order, invoice and delivery note to support the exempt import; exempt IPM imports are not reported in the GST return

    Who
    Registered bullion dealer / trader (PSPM registered dealer)
    Needs
    TradeNet In-Non-Payment (GST Relief) permit for IPM (declaration type GTR, place of receipt IGPM); Foreign supplier's commercial invoice
    Official guidance
    • IRAS IPM e-Tax Guide (20th ed.) para 8.2; Customs: keep trade documents 5 years

  7. 42

    Open a custody account after KYC of the depositor; agree allocated (serial-numbered) or pooled storage, insurance and audit rights

    Who
    Vault operator / precious-metals custodian (incl. in the Changi FTZ Freeport)
    Issues
    Vault deposit receipt and allocated weight list
    Industry practice
  8. 43

    Hold bars in the allocated register and issue periodic weight-list statements

    Who
    Vault operator / precious-metals custodian (incl. in the Changi FTZ Freeport)
    Needs
    Vault deposit receipt and allocated weight list
    Issues
    Allocated or unallocated metal account statement
    Industry practice
  9. 44

    Store non-IPM gold (or goods not entered for home use) in a free trade zone or a licensed zero-GST warehouse with GST suspended until the goods enter customs territory for local use; storing gold as a "listed good" in a zero-GST warehouse needs Customs' written approval and beneficial-owner records

    Who
    Vault operator / precious-metals custodian (incl. in the Changi FTZ Freeport)
    Primary law

    [summary] the listed-goods approval and beneficial-owner records are Customs ZGS scheme conditions (official guidance), not statute.

    • Free Trade Zones Act 1966 ss.2, 5; GST Act 1993 s.37(1); GST (General) Regulations 1993 reg 94; Singapore Customs FTZ and Zero-GST Warehouse guidance

  10. 45

    Hold foreign central banks' and sovereign entities' gold under the MAS central bank gold vaulting service; MAS also extends gold accounts to selected Singapore bullion banks to manage those holdings

    Who
    Monetary Authority of Singapore (central bank gold custody service)
    Official guidance

    [unconfirmed] launch not confirmed as of 28 Sep 2026; terms of the service not published in the texts held.

  11. 46

    Release bars on the account holder's instruction against a delivery order to a carrier or another vault account

    Who
    Vault operator / precious-metals custodian (incl. in the Changi FTZ Freeport)
    Needs
    Allocated or unallocated metal account statement
    Issues
    Outbound bar list
    Industry practice
  12. 47

    Determine whether the deal is a designated transaction (payment in cash or cash equivalent above S$20,000, single or same-day aggregate; secondhand-dealer purchase from a non-dealer for cash above S$20,000; token redemption for cash above S$20,000) or a prescribed circumstance (payment in non-jewellery gold or digital payment tokens above S$20,000)

    Who
    Registered bullion dealer / trader (PSPM registered dealer)
    Needs
    Certificate of registration as a regulated dealer (PSPM Act)
    Primary law
    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.15 "designated transaction" (a)

      “a sale of any precious stone, precious metal, precious product or asset-backed token by a regulated dealer to a customer, for which cash or a cash equivalent exceeding the threshold amount is received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.15 (b)

      “2 or more sales of any precious stone, precious metal, precious product or asset-backed token in a single day by a regulated dealer to the same customer, or to customers whom the regulated dealer knows act on behalf of the same person, for which cash or a cash equivalent in total exceeding the threshold amount is received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.15 (c)

      “a purchase of any precious stone, precious metal or precious product from a customer (who is not a regulated dealer) by a regulated dealer (who is a secondhand goods dealer), for which cash or a cash equivalent exceeding the threshold amount is received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.15 "threshold amount"

      “"threshold amount" means $20,000 or its equivalent in value, or an amount prescribed in substitution.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PMLTFPF Regulations reg 3(1)

      “For the purposes of section 15 of the Act, "cash equivalent" means any of the following:”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 4(1)(a)

      “a redemption of an asset-backed token from a customer (who is not a regulated dealer) by a regulated dealer, for cash or a cash equivalent exceeding the threshold amount;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 4A(1)(a)

      “for which gold (except in the form of jewellery) the value of which exceeds the threshold amount is received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 4A(1)(c)

      “for which digital payment tokens the value of which exceeds the threshold amount are received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), ACD Transaction-Based Requirements page

      “"threshold amount" means S$20,000 or its equivalent in value, or an amount prescribed in substitution.”

  13. 48

    Perform CDD before the transaction: identify and verify the customer and beneficial owners, screen against sanctions lists; stop and consider an STR if CDD cannot be completed

    Who
    Registered bullion dealer / trader (PSPM registered dealer)
    Issues
    CDD record (customer and beneficial-owner identification and verification); Sanctions/terrorist-designation screening record (MHA lists, MAS TFS lists, myPal)
    Primary law
    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.16(1)(a)

      “before entering into a designated transaction;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.16(1)(b)

      “where the regulated dealer has reason to suspect money laundering, terrorism financing or the financing of proliferation of weapons of mass destruction;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.16(1)(c)

      “where the regulated dealer has reason to doubt the veracity or adequacy of information obtained from earlier customer due diligence measures;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.16(5)(a)

      “decline to enter into any transaction with the customer;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.16(5)(b)

      “terminate any transaction entered into with the customer;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.16(5)(c)

      “determine whether to make a disclosure under section 45 of the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 or section 8 or 10 of the Terrorism (Suppression of Financing) Act 2002;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PMLTFPF Regulations reg 5(1)(a)

      “obtain the customer's identifying information;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 5(1)(b)

      “verify the customer's identity using reliable and independent sources, such as the customer's identity card, passport or other document of identity issued by a government;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 6(1)(b)

      “identify each beneficial owner of the customer and take reasonable measures to verify the identity of each beneficial owner by obtaining the following information from reliable and independent sources:”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 16(1): sanctions screening

      “A regulated dealer must, before dealing with any customer, take reasonable measures to assess whether the customer, any person on whose behalf the customer is acting, or a beneficial owner of the customer (where the customer is an entity or a legal arrangement) is -”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 16(1)(a)

      “a terrorist or terrorist entity under the Terrorism (Suppression of Financing) Act 2002;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 16(1)(b)

      “a designated person as defined in any regulations made under the United Nations Act 2001; or”

  14. 49

    Apply enhanced CDD (senior-management approval, source of wealth and funds, enhanced monitoring) for PEPs, FATF-listed jurisdictions, Registrar-notified persons or high-risk customers; apply the A.C.T. anti-scam protocol on gold bar purchases above S$20,000

    Who
    Registered bullion dealer / trader (PSPM registered dealer)
    Needs
    CDD record (customer and beneficial-owner identification and verification)
    Issues
    Enhanced CDD file with senior-management approval and source-of-wealth/source-of-funds evidence
    Primary law
    • PMLTFPF Regulations 2019 reg 7; Code of Practice (2026) under PSPM Act s.35(1)

  15. 50

    Sell the IPM without GST and issue an invoice for the exempt supply; transfer title by delivery or book transfer in the vault

    Who
    Registered bullion dealer / trader (PSPM registered dealer)
    Needs
    CDD record (customer and beneficial-owner identification and verification)
    Issues
    Invoice for an exempt supply of IPM; Bank transfer record; Allocated or unallocated metal account statement
    Primary law
    • GST Act 1993; GST (General) Regulations, Fourth Schedule Part 1 para 1A; reg 13A

  16. 51

    Settle wholesale loco Singapore trades between banks and dealers by metal account transfer; SGX is to operate an OTC gold clearing system for loco Singapore by end-2026, with interbank trading building up from 2027 (six bullion banks signing as clearing members)

    Who
    Bullion bank (MAS-licensed bank)
    Issues
    Loco Singapore settlement / account transfer confirmation
    Official guidance

    [not-read] the SGX clearing rulebook is not published in the texts held; timing from the MAS speech of 15 Jun 2026.

  17. 52

    File a Cash Transaction Report (Form NP 784) on SONAR

    Who
    Registered bullion dealer / trader (PSPM registered dealer)
    Needs
    CDD record (customer and beneficial-owner identification and verification)
    Issues
    Cash Transaction Report, Form NP 784 (filed on SONAR)
    Primary law
    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.17(1)

      “A regulated dealer who enters into any designated transaction must submit to a Suspicious Transaction Reporting Officer, within the prescribed time, a cash transaction report relating to that transaction in the prescribed form and manner.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.17(1A)

      “A regulated dealer must not, without reasonable excuse, submit a cash transaction report under subsection (1) that is incomplete or inaccurate.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.17(3)

      “A regulated dealer must, at the time of submitting a cash transaction report under subsection (1) or immediately thereafter, submit a copy of the cash transaction report to the Registrar.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PMLTFPF Regulations reg 12(1)(a)

      “the prescribed form for a cash transaction report is Form NP 784 as set out at the website at https://www.police.gov.sg; and”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 12(1)(b)

      “the prescribed time for the submission of a cash transaction report is not later than 15 business days after the date on which the designated transaction is entered into.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), STRO Cash Transaction Reporting page

      “You can file a Cash Transaction Report (CTR) (Form NP 784) electronically via STRO Online Notices And Reporting platform (SONAR).”

    • PSPM Act; PMLTFPF Regulations (sections in refs), STRO page

      “When you e-file through SONAR, your CTR will automatically be forwarded to ACD on your behalf.”

  18. 53

    File an STR on SONAR where ML/TF/PF is suspected; do not tip off

    Who
    Registered bullion dealer / trader (PSPM registered dealer)
    Issues
    Suspicious Transaction Report (SONAR)
    Primary law

    [unconfirmed] the 5-business-day / one-business-day timelines are the Registrar's Guidelines (STR paragraph), not statute.

    • CDSA; CDSA (Disclosure under Section 45) Regulations (SONAR); TSOFA; PSPM Act (sections in refs), CDSA s.45(1) (parsed into section a1-s-42 of this record)

      “Where a person knows or has reasonable grounds to suspect that any property -”

    • CDSA; CDSA (Disclosure under Section 45) Regulations (SONAR); TSOFA; PSPM Act (sections in refs), CDSA s.45(1)

      “the person must disclose the knowledge or suspicion or the information or other matter on which that knowledge or suspicion is based to a Suspicious Transaction Reporting Officer as soon as is reasonably practicable after it comes to the person's attention.”

    • CDSA; CDSA (Disclosure under Section 45) Regulations (SONAR); TSOFA; PSPM Act (sections in refs), CDSA s.57(2)(a) tipping-off

      “knows or has reasonable grounds to suspect that a disclosure has been or is being made to an authorised officer under this Act (called in this section the disclosure); and”

    • CDSA; CDSA (Disclosure under Section 45) Regulations (SONAR); TSOFA; PSPM Act (sections in refs), CDSA s.57(2)(b)

      “discloses to any other person information or any other matter which is likely to prejudice any investigation which might be conducted following the disclosure, shall be guilty of an offence”

    • CDSA; CDSA (Disclosure under Section 45) Regulations (SONAR); TSOFA; PSPM Act (sections in refs), CDSA (Disclosure under Section 45) Regulations 2024 reg 3

      “A disclosure made under section 45(1) of the Act must be made -”

    • CDSA; CDSA (Disclosure under Section 45) Regulations (SONAR); TSOFA; PSPM Act (sections in refs), reg 3(a)

      “electronically by using SONAR; or”

    • CDSA; CDSA (Disclosure under Section 45) Regulations (SONAR); TSOFA; PSPM Act (sections in refs), TSOFA s.8(1)

      “must immediately inform the Commissioner of Police of that fact or information.”

    • CDSA; CDSA (Disclosure under Section 45) Regulations (SONAR); TSOFA; PSPM Act (sections in refs), TSOFA s.10(1)

      “who fails to disclose the information immediately to a police officer shall be guilty of an offence.”

    • CDSA; CDSA (Disclosure under Section 45) Regulations (SONAR); TSOFA; PSPM Act (sections in refs), PSPM Act s.21(2)

      “A regulated dealer must, at the time of disclosing a matter under subsection (1) or immediately thereafter, submit a copy of the information so disclosed to the Registrar.”

    • CDSA; CDSA (Disclosure under Section 45) Regulations (SONAR); TSOFA; PSPM Act (sections in refs), Guidelines v5.1 para 12.2.1

      “is required to submit an STR to STRO as soon as reasonably practicable upon the establishment of suspicion (i.e. no longer than 5 business days).”

    • CDSA; CDSA (Disclosure under Section 45) Regulations (SONAR); TSOFA; PSPM Act (sections in refs), Guidelines para 12.4.1

      “Regulated dealers are reminded that it is an offence23 to disclose the fact that an STR was filed.”

  19. 54

    Keep CDD, transaction and report records

    Who
    Registered bullion dealer / trader (PSPM registered dealer)
    Needs
    CDD record (customer and beneficial-owner identification and verification)
    Primary law
    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.18(1)(a)

      “a record of every designated transaction (whether or not completed) and every other transaction for which the customer due diligence measures mentioned in section 16 must be performed, containing the prescribed information on that transaction;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.18(1)(b)

      “a record of all information relating to a customer which is obtained through the customer due diligence measures performed under section 16;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.18(1)(c)

      “a copy of each supporting document relied on in support of any information referred to in paragraph (b);”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.17(2)

      “A regulated dealer must keep a copy of each cash transaction report submitted under subsection (1) for the prescribed period.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PMLTFPF Regulations reg 13(1)

      “For the purposes of section 18(1) or (1A) of the Act, the period for which the documents and information in that section must be kept is 5 years after whichever of the following dates is applicable:”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 13(1)(a)

      “the date of the designated transaction;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 13(3)(c)

      “a record of the supporting information or a copy of each supporting document relied on by the regulated dealer in making a cash transaction report;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 13(4)

      “All the records, information and documents required to be kept under section 18 of the Act and these Regulations must be kept in a manner so as to be accurate, complete, legible and accessible to the Registrar, an auditor, an authorised officer or a Suspicious Transaction Reporting Officer.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 12(2)

      “For the purposes of section 17(2) of the Act, the period for which a copy of a cash transaction report must be kept is 5 years after the date of submission of the cash transaction report.”

Taxes and fees

  • Customs duty on gold

    None All gold (HS 7108 etc.); only liquor, tobacco, motor vehicles and petroleum products are dutiable

    Official guidanceAmount not confirmed
  • Import GST suspension under ARCS

    Suspended Materials imported by Approved Refiners/Consolidators for refining into IPM; supplies between ARCS persons (except refining services)

    Primary law
    • GST (General) Regulations, reg 46A(8), (12)

  • GST on exports of gold

    0% (zero-rated) Export of IPM and non-IPM gold with export documentation

    Primary lawAmount not confirmed
    • GST Act 1993, s.21(1)-(2)

  • Import GST - IPM exemption

    Exempt Gold bars, ingots, wafers of 99.5%+ from current/former LBMA GD refiners (or ESG-endorsed), with hallmark; prescribed coins; not decorative/collector bars

    Primary lawAmount not confirmed
    • GST Act 1993, s.8(4), s.22(1A); Fourth Schedule Part 2 paras 1(a), 1A; Part 3 para 2

  • GST on non-IPM gold

    9% Import and supply of doré, scrap, jewellery, non-qualifying bars (e.g. from non-LBMA refiners, decorative)

    Primary lawAmount not confirmed
    • GST Act 1993, s.16(cb)

  • GST on non-IPM gold (2023 rate)

    8% Import and supply of doré, scrap, jewellery, non-qualifying bars

    Primary lawAmount not confirmed
    • GST Act 1993, s.16(ca)

  • GST on refining services

    9% local; zero-rated to overseas customers Refining/toll-refining fees

    Official guidanceAmount not confirmed
  • GST on local supply of IPM

    Exempt Sale of qualifying IPM in Singapore

    Primary lawAmount not confirmed
    • GST Act 1993, s.22(1); Fourth Schedule Part 1 para 1A

  • Regulated dealer registration fees

    S$120 application fee (not on renewal since 10 Apr 2021); S$250 (Class A) or S$350 (Class B) per year per place of business

    Primary lawAmount not confirmed
    • PMLTFPF Regulations 2019, regs 17-18

Controls

  • Cash transaction report on Form NP 784 to a Suspicious Transaction Reporting Officer for every designated transaction, not later than 15 business days after the date the transaction is entered into; a copy goes to the Registrar at the time of submission or immediately after (e-filing through SONAR f…

    Cash or cash equivalent exceeding S$20,000 (payments in gold other than jewellery, or in digital payment tokens, are prescribed circumstances for CDD, not designated transactions, and need no CTR)

    Primary law
    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.17(1)

      “A regulated dealer who enters into any designated transaction must submit to a Suspicious Transaction Reporting Officer, within the prescribed time, a cash transaction report relating to that transaction in the prescribed form and manner.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.17(1A)

      “A regulated dealer must not, without reasonable excuse, submit a cash transaction report under subsection (1) that is incomplete or inaccurate.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.17(2)

      “A regulated dealer must keep a copy of each cash transaction report submitted under subsection (1) for the prescribed period.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.17(3)

      “A regulated dealer must, at the time of submitting a cash transaction report under subsection (1) or immediately thereafter, submit a copy of the cash transaction report to the Registrar.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.17(4)

      “A regulated dealer who fails to comply with subsection (1), (1A), (2) or (3) shall be guilty of an offence and shall be liable on conviction to a fine not exceeding $20,000 or to imprisonment for a term not exceeding 2 years or to both.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.15 "designated transaction" (a)

      “a sale of any precious stone, precious metal, precious product or asset-backed token by a regulated dealer to a customer, for which cash or a cash equivalent exceeding the threshold amount is received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.15 "threshold amount"

      “"threshold amount" means $20,000 or its equivalent in value, or an amount prescribed in substitution.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PMLTFPF Regulations reg 4A(1)(a): gold payment is a prescribed circumstance for CDD (s.16(1)(d)), not a designated transaction

      “for which gold (except in the form of jewellery) the value of which exceeds the threshold amount is received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 4A(1)(c)

      “for which digital payment tokens the value of which exceeds the threshold amount are received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PMLTFPF Regulations reg 12(1)(a)

      “the prescribed form for a cash transaction report is Form NP 784 as set out at the website at https://www.police.gov.sg; and”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 12(1)(b)

      “the prescribed time for the submission of a cash transaction report is not later than 15 business days after the date on which the designated transaction is entered into.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 12(2)

      “For the purposes of section 17(2) of the Act, the period for which a copy of a cash transaction report must be kept is 5 years after the date of submission of the cash transaction report.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), STRO Cash Transaction Reporting page

      “When you e-file through SONAR, your CTR will automatically be forwarded to ACD on your behalf.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), ACD Compliance Toolkit, footnote 6 (conflicting definition)

      “The dealer sells or barters a precious stone, precious metal, precious product or asset-backed token and receives payment in cash or cash equivalent or gold (except in the form of jewellery) or digital payment tokens, where the value exceeds S$20,000 in total value.”

  • Enhanced CDD (senior-management approval, income, source of wealth and funds, enhanced monitoring) where the customer, principal or beneficial owner is a PEP or family/associate, resides in or originates from a FATF call-for-action jurisdiction (DPRK, Iran countermeasures; Myanmar enhanced due dilig…

    Primary law
    • PMLTFPF Regulations 2019, reg 7(2)(a)(ii), (3), (4)

  • IPM imports need an In-Non-Payment (GST relief) permit: air freight above S$400 CIF (non-controlled air imports up to S$400 need no permit, RIER reg 3(2A)), all sea and land freight, all commercial hand-carry, and personal hand-carry above 0.5 kg; parcel post needs no permit (reg 3(2)(b)).

    S$400 CIF (air); 0.5 kg (personal hand-carry)

    Official guidanceAmount not confirmed
    • Regulation of Imports and Exports Regulations, reg 3(1), (2)(b), (2A)

  • Code of Practice issued by the Registrar of Regulated Dealers under the PSPM Act codes-of-practice power (issued 2 April 2026): dealers apply the A.C.T. framework (Add immediate intervention, Check the customer's behaviour against anti-scam information, Tell the customer to call the ScamShield Helpl…

    S$20,000

    Official guidance
    • PSPM Act, codes of practice power (section in refs), CoP para 1.1

      “This Code of Practice ("CoP") is issued by the Registrar of Regulated Dealers under section 35(1) of the Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act 2019 ("PSPM Act").”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.1

      “PSMDs should apply the A.C.T. framework at paragraph 5.2 when encountering customers making purchases under the following circumstances, regardless of payment mode:”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.1(a)

      “Single transaction of more than S$20,000; or”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.1(b)

      “Multiple transactions below S$20,000 that collectively exceed S$20,000, whether conducted on the same day or over a few days.”

    • PSPM Act, codes of practice power (section in refs), CoP Annex B-2 item 7 (A.C.T.)

      “A - Add immediate intervention by asking the customer for reasons behind the purchase.”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.2 (C)

      “Check for the customer's”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.2 (T): call the ScamShield Helpline

      “Tell the customer that”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.3(a)

      “Conduct enhanced customer due diligence in accordance with the Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Regulations 2019;”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.3(e)

      “Escalate the matter to the supervisor or senior management and document the customer's behaviour and the basis for proceeding with the transaction;”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.3(f)

      “Call the police at 999 if the customer chooses to proceed with the purchase despite repeated warnings that red flags are present; and”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.3(g)

      “File a Suspicious Transaction Report ("STR").”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.4

      “For online sales, in-person collection should be required for purchases above S$20,000.”

    • PSPM Act, codes of practice power (section in refs), ACD News: issuance of the CoP

      “2 April 2026 ## Issuance of Code of Practice on AML Measures for PSMDs to Combat Scam Related Money Laundering Cases”

    • PSPM Act, codes of practice power (section in refs), PSPM Act s.35(5)

      “Any code of practice, guideline or standard of performance has no legislative effect.”

    • PSPM Act, codes of practice power (section in refs), PSPM Act s.35(6)

      “Any failure by a regulated dealer to comply with any code of practice, guideline or standard of performance applicable to the regulated dealer does not of itself render the regulated dealer liable to criminal proceedings, but the failure may, in any proceedings (criminal or otherwise), be relied on by any party to those proceedings as tending to establish or negate any liability which is in question in those proceedings.”

    • PSPM Act, codes of practice power (section in refs), PSPM Act s.35(1)

      “The Registrar may issue, approve, amend or revoke one or more codes of practice, guidelines or standards of performance for all or any of the following purposes:”

  • STR to a Suspicious Transaction Reporting Officer as soon as reasonably practicable on knowledge or reasonable grounds to suspect (CDSA), or the TSOFA disclosure where it applies, with a copy to the Registrar at the time of disclosure or immediately after (PSPM Act); records of every designated tran…

    Primary law
    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), CDSA s.45(1) (parsed into section a1-s-42 of this record)

      “Where a person knows or has reasonable grounds to suspect that any property -”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), CDSA s.45(1)

      “the person must disclose the knowledge or suspicion or the information or other matter on which that knowledge or suspicion is based to a Suspicious Transaction Reporting Officer as soon as is reasonably practicable after it comes to the person's attention.”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.21(1)

      “A regulated dealer must, if circumstances exist that require the regulated dealer to do so, make a disclosure under whichever of the following is applicable:”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.21(2)

      “A regulated dealer must, at the time of disclosing a matter under subsection (1) or immediately thereafter, submit a copy of the information so disclosed to the Registrar.”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.18(1)(a)

      “a record of every designated transaction (whether or not completed) and every other transaction for which the customer due diligence measures mentioned in section 16 must be performed, containing the prescribed information on that transaction;”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.18(1)(b)

      “a record of all information relating to a customer which is obtained through the customer due diligence measures performed under section 16;”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.18(1)(c)

      “a copy of each supporting document relied on in support of any information referred to in paragraph (b);”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.19(1)

      “A regulated dealer must, in relation to the regulated dealer's business of regulated dealing or business as an intermediary for regulated dealing, implement adequate programmes and measures to prevent money laundering, terrorism financing and the financing of proliferation of weapons of mass destruction.”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PMLTFPF Regulations reg 13(1)

      “For the purposes of section 18(1) or (1A) of the Act, the period for which the documents and information in that section must be kept is 5 years after whichever of the following dates is applicable:”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 13(3)(f)

      “a record of the following information for each period of 6 months beginning on 1 January or 1 July of any year:”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 13(5)

      “the prescribed manner of making any record kept under paragraph (3)(f) available to the Registrar is by submitting the record to the Registrar through the electronic system of the Ministry of Law at https://acd.mlaw.gov.sg.”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 14(1)(b)(i)

      “document the risk assessments;”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 14(1)(c)

      “develop and implement internal policies, procedures and controls, which must be approved by its senior management, to manage and effectively mitigate the risks of money laundering, terrorism financing and proliferation financing identified by it or notified to it by the Registrar, including -”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 14(1)(c)(i)

      “making appropriate compliance management arrangements, including the appointment of a compliance officer; and”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 14(1)(c)(ii)

      “applying adequate screening procedures when hiring employees;”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 14(1)(e)

      “have an ongoing programme to train employees on the internal policies, procedures and controls in sub-paragraph (c); and”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 14(2)

      “A regulated dealer that carries out one or more designated transactions must, in addition to the matters mentioned in paragraph (1), have an independent audit function to test the internal policies, procedures and controls in paragraph (1)(c).”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), Guidelines v5.1 para 12.2.1

      “is required to submit an STR to STRO as soon as reasonably practicable upon the establishment of suspicion (i.e. no longer than 5 business days).”

  • Before dealing, dealers must assess whether the customer, principal or beneficial owner is a terrorist or terrorist entity (TSOFA), a designated person under UN Act regulations, or a Registrar-notified person; if suspected they must decline or terminate the transaction, report to the police and copy…

    Primary law
    • PMLTFPF Regulations 2019 reg 16; TSOFA s.8

  • CDD before any designated transaction (sale for cash or cash equivalent above S$20,000, single or same-day aggregate; purchase by a secondhand-goods dealer from a non-dealer for cash above S$20,000; token redemptions for cash above S$20,000), on suspicion of ML/TF/PF, or on doubts about earlier CDD;…

    S$20,000

    Primary law
    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.16(1)(a)

      “before entering into a designated transaction;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.16(1)(b)

      “where the regulated dealer has reason to suspect money laundering, terrorism financing or the financing of proliferation of weapons of mass destruction;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.16(1)(c)

      “where the regulated dealer has reason to doubt the veracity or adequacy of information obtained from earlier customer due diligence measures;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.16(1)(d)

      “under circumstances prescribed for the purposes of this section.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.16(5)(a)

      “decline to enter into any transaction with the customer;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.16(5)(b)

      “terminate any transaction entered into with the customer;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.16(5)(c)

      “determine whether to make a disclosure under section 45 of the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 or section 8 or 10 of the Terrorism (Suppression of Financing) Act 2002;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.15 "designated transaction" (a)

      “a sale of any precious stone, precious metal, precious product or asset-backed token by a regulated dealer to a customer, for which cash or a cash equivalent exceeding the threshold amount is received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.15 (b)

      “2 or more sales of any precious stone, precious metal, precious product or asset-backed token in a single day by a regulated dealer to the same customer, or to customers whom the regulated dealer knows act on behalf of the same person, for which cash or a cash equivalent in total exceeding the threshold amount is received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.15 (c)

      “a purchase of any precious stone, precious metal or precious product from a customer (who is not a regulated dealer) by a regulated dealer (who is a secondhand goods dealer), for which cash or a cash equivalent exceeding the threshold amount is received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.15 "threshold amount"

      “"threshold amount" means $20,000 or its equivalent in value, or an amount prescribed in substitution.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PMLTFPF Regulations reg 4(1)(a)

      “a redemption of an asset-backed token from a customer (who is not a regulated dealer) by a regulated dealer, for cash or a cash equivalent exceeding the threshold amount;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 4(1)(c)

      “2 or more redemptions of any asset-backed token in a single day by a regulated dealer from the same customer”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 4A(1)

      “For the purpose of section 16(1)(d) of the Act, each of the following circumstances are circumstances in which a regulated dealer must perform the prescribed customer due diligence measures in regulations 5 and 6”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 4A(1)(a)

      “for which gold (except in the form of jewellery) the value of which exceeds the threshold amount is received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 4A(1)(c)

      “for which digital payment tokens the value of which exceeds the threshold amount are received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 5(1)

      “the customer due diligence measures to be performed by a regulated dealer before entering into any designated transaction with a customer who is an individual are all of the following:”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 6(1)

      “the customer due diligence measures to be performed by a regulated dealer before entering into any designated transaction with a customer who is an entity or a legal arrangement are all of the following:”

  • Anyone moving physical currency or bearer negotiable instruments above the prescribed amount (S$20,000, CMR Regulations reg 2A) into or out of Singapore must report it: travellers on Form NP 727 within 72 hours before immigration clearance; senders and commercial carriers of cash by post or courier …

    S$20,000

    Primary lawAmount not confirmed
    • CDSA 1992 Part 6A; CDSA (Cross Border Movements of Physical Currency and Bearer Negotiable Instruments) Regulations 2007, CDSA ss.59-62; regs 2A, 3, 4, 4A, 5

  • Anyone carrying on a business of manufacturing, importing or possessing for sale, selling or offering for sale, or buying for resale any precious metal (gold, silver, platinum group metals, and alloys with at least 2% in weight of them, in manufactured or unmanufactured state), precious stone or pre…

    No value floor for bullion; unregistered dealing: fine up to S$75,000 or imprisonment up to 3 years or both, plus up to S$7,500 for every day of a continuing offence

    Primary law
    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), PSPM Act s.6(1)

      “A person must not act as or hold out to be a regulated dealer unless the person is a registered dealer.”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), PSPM Act s.6(2)

      “A person who contravenes subsection (1) shall be guilty of an offence and shall be liable on conviction to a fine not exceeding $75,000 or to imprisonment for a term not exceeding 3 years or to both and, in the case of a continuing offence, to a further fine not exceeding $7,500 for every day or part of a day during which the offence continues after conviction.”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), s.2 "regulated dealing" (a)

      “manufacturing any precious stone, precious metal or precious product;”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), (b)

      “importing or possessing for sale any precious stone, precious metal or precious product;”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), (c)

      “selling or offering for sale any precious stone, precious metal or precious product;”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), (d)

      “selling or redeeming asset-backed tokens;”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), (e)

      “purchasing any precious stone, precious metal or precious product for the purposes of resale;”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), s.2 "regulated dealer" (b)

      “business as an intermediary for regulated dealing, but excludes a pawnbroker and any other person as may be prescribed;”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), s.2 "precious metal"

      “"precious metal" means any precious metal specified in Part 1 of the Schedule in a manufactured or unmanufactured state;”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), the Schedule Part 1 item 9 (items 1-8: gold, silver, platinum, iridium, osmium, palladium, rhodium, ruthenium)

      “An alloy with at least 2% in weight of any substance mentioned in items 1 to 8”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), ACD Regulatory Regime page

      “"Precious metals" include gold, silver, platinum, iridium, osmium, palladium, rhodium, ruthenium, and alloys with at least 2% in weight of any of the metals stated above.”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), Exempt Persons Order para 3

      “Every financial institution that carries on a business of regulated dealing, or business as an intermediary for regulated dealing, in Singapore is exempt from -”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), Order para 4(1)

      “A foreign dealer carrying on a business of regulated dealing, or business as an intermediary for regulated dealing, in Singapore on a transitory basis, is exempt from -”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), Order para 4(2)

      “A foreign dealer carries on business in Singapore on a transitory basis if the foreign dealer carries on business in Singapore for not more than a total of 90 days in a year.”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), PSPM Act Legislative History item 1

      “Commencement : 10 April 2019”

  • Gold may not be imported, transhipped or brought in transit from the DPRK (Seventh Schedule, prohibited imports item (9)), nor exported, transhipped or brought in transit to the DPRK (luxury items, prohibited exports item (5)(k) "gold, silver and platinum"); any goods for trade with a person in the …

    Primary law
    • Regulation of Imports and Exports Regulations, regs 5A, 6(1)(b), 6(2)(c); Seventh Schedule item 2 (DPRK)

  • GST-exempt status depends on the bar: gold of at least 99.5% purity in bar, ingot or wafer form, refined by a refiner who is or was on the LBMA Good Delivery list (or an Enterprise Singapore-endorsed intending refiner — none endorsed on 28 Sep 2026), bearing a mark internationally accepted as guar…

    Primary law
    • GST Act 1993, Fourth Schedule, Part 2 paras 1(a), 1A; Part 3 para 2

  • No Singapore statute requires importers, dealers or refiners to verify mine origin or apply OECD/CAHRA due diligence: the PSPM Act and Regulations impose customer (not supplier-origin) due diligence, the GST investment-precious-metal exemption turns on form, purity, a refiner on the LBMA Good Delive…

    Primary law
    • PSPM Act s.2 "customer"

      “"customer" means a person with whom a regulated dealer enters into or intends to enter into a transaction;”

    • PSPM Act s.16(1): CDD is on the customer

      “a regulated dealer must perform the prescribed customer due diligence measures in any of the following circumstances:”

    • PMLTFPF Regulations reg 5(1)

      “the customer due diligence measures to be performed by a regulated dealer before entering into any designated transaction with a customer who is an individual are all of the following:”

    • reg 6(1)

      “the customer due diligence measures to be performed by a regulated dealer before entering into any designated transaction with a customer who is an entity or a legal arrangement are all of the following:”

    • GST Act Fourth Schedule Part 2 para 1(a)(i) (parsed into section sch-3 of this record)

      “is in the form of a bar, an ingot or a wafer;”

    • para 1(a)(ii)

      “is of a purity of at least 99.5%; and”

    • Fourth Schedule Part 2 para 2(a)(i)

      “in the case of gold or silver, a refiner who is or was in the "Good Delivery" list of the London Bullion Market Association;”

    • para 2(b)

      “it bears a mark or characteristic that is internationally accepted as guaranteeing its quality.”

    • Singapore Customs IPM page, permit field "Supplier name"

      “Name of refiner who produced the bar/wafer/ingot”

    • Guidelines v5.1 Annex D, red flag indicators

      “Supplier/ introducer is evasive when being asked about the source of its gold supply.”

  • Singapore's Russia measures ban the export, transhipment and transit to Russia of military goods and of dual-use goods in Categories 3 (electronics), 4 (computers) and 5 (telecommunications and information security) of the Strategic Goods (Control) Order 2021 as in force on 16 Mar 2022 (RIER reg 6(2…

    Primary law
    • Regulation of Imports and Exports Regulations, reg 6(2B); Eighth Schedule

  • Goods to or from UNSC-sanctioned countries need a TradeNet permit applied for at least 3 working days before shipment. Iran lists cover nuclear, arms and S/2015/546 items, not gold.

    Official guidance
    • Regulation of Imports and Exports Regulations, regs 5A, 6(1)(b), 6(2)(c)

  • Zero-GST warehouse licensees may store "listed goods" (incl. HS 7108 gold, silver, platinum and precious stones) only with Singapore Customs' written approval, at least a Type II licence, and records of the persons controlling and beneficially owning the goods, screened and kept up to date (since 1 …

    Official guidance

Leg 4: Indonesia

Back in the origin country: the proceeds of the export

  1. 55

    Receive export proceeds into a DHE SDA special account at LPEI or a foreign-exchange bank

    Who
    Gold exporter (company with NIB)
    Issues
    Bank transfer record
    Primary law

    Whether gold falls within the DHE SDA goods list was not confirmed.

    • PP 36/2023 as amended by PP 8/2025, Arts 6, 8(1)

  2. 56

    Retain 100% of DHE SDA in the Indonesian financial system for at least 12 months (from 1 Mar 2025); non-compliance leads to suspension of export services

    Who
    Foreign-exchange bank / LPEI holding the DHE SDA special account
    Issues
    DHE SDA special-account placement record
    Primary law
    • PP 8/2025, Arts 7(1)-(2), 16(1)

Crossings between countries

  • Indonesia → Australia Not researched

    Papers that cross: Izin Pertambangan Rakyat (IPR); IUP/IUPK Operasi Produksi; Refiner bar certificate / bar list for 999.9 bars; Sale contract / purchase note between miner and buyer; Refiner intake record: weight, sample and fire-assay result; Commercial invoice; Packing list; Air waybill; Surat Keterangan Asal (certificate of origin) via e-SKA; Pemberitahuan Pabean Ekspor (PPE, formerly PEB, BC 3.0); Customs approval for loading / export (persetujuan ekspor, NPE); Cross-border cash declaration to Customs (IDR 100 million or more)

  • Australia → Singapore Not 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

Indonesia (refine) → Australia → Singapore · Sale or purchase of gold in Singapore — Research · Nelum