Ghana [GoldBod channel (small-scale gold)] → Russian Federation → United Arab Emirates · Reconcile assays and pay the balance

Mine and concentrate ore on the licensed small-scale area

Who

Licensed small-scale miner (Ghanaian citizen, individual, group or cooperative)

Needs

Small-scale mining licence

Form

Ore (in situ / run-of-mine) → Concentrate / black sand

Licence requirement read in Act 703 s.82(1) and operations in s.93; the ore/concentrate states are general ASM practice.

• Minerals and Mining Act, 2006 (Act 703), ss.82-83

Amalgamate with mercury bought from an authorised mercury dealer, then burn off the mercury to recover sponge gold

Who

Licensed small-scale miner (Ghanaian citizen, individual, group or cooperative)

Form

Concentrate / black sand → Sponge gold

s.96 allows a small-scale miner to buy "the quantities of mercury that may be reasonably necessary" from an authorised mercury dealer; the amalgam and retort states are industry practice, not in the Act.

• Minerals and Mining Act, 2006 (Act 703), s.96

Melt sponge into a small unstamped doré bar (often done at the buyer's premises)

Who

Licensed small-scale miner (Ghanaian citizen, individual, group or cooperative)

Form

Sponge gold → Doré bar - unstamped

GoldBod directives call the purchased product 'gold doré'; who melts it is not stated

Weigh on calibrated balances and set purity by XRF (from 1 Sept 2026 the water-density method is no longer definitive; without XRF the doré is bought at a purity discount of at least 0.5% and GoldBod's later XRF assessment is final; successive XRF reports on the same gold must agree within +/-0.05%)

Who

Tier 2 licensed gold buyer

Issues

XRF purity measurement record

• GoldBod XRF directive

Price at the GoldBod published price for the current window (LBMA AM at 10:30 / PM at 15:00, converted at the BoG Reference Rate), plus any approved rate-gap bonus for licensed miners and at most GHS 30 of the Tier 2 buyer's commission

Who

Tier 2 licensed gold buyer

• GoldBod pricing notices of 23 June 2026; Ghana Gold Board Act, 2025 (Act 1140), s.63(1)(c) and (2) (knowing failure to comply with licence terms), as cited by the threshold notice

Pay the miner and immediately issue the official GoldBod-prescribed receipt showing the exact time of purchase

Who

Tier 2 licensed gold buyer

Needs

Tier 2 buyer licence; XRF purity measurement record

Issues

GoldBod-prescribed receipt to the miner

• Ghana Gold Board Act, 2025 (Act 1140), s.67(1): a GoldBod licensee may purchase gold from the local gold trading sector only from GoldBod, a miner or a GoldBod licensee; s.63(1)(f)

Book the purchase with the financing Tier 2 buyer or aggregator within 5 minutes, by phone, text or another approved channel

Who

Tier 2 licensed gold buyer

Needs

GoldBod-prescribed receipt to the miner

Issues

Purchase booking with the financing Tier 2 buyer or aggregator (within 5 minutes)

[conflict] gh.div-conflict-booking-citation: the notice cites Act 1140 "Section 64 (1) (c) and (2)", which does not exist (s.64 is about embezzlement of funds and has no (1)(c)); the article is therefore left out. [inferred] A breach is at least a failure to comply with licence conditions (s.63(1)(c)).

• GoldBod compliance notice on timely booking (23 June 2026)

Sell gold bought from miners to a licensed Tier 2 buyer, against a GoldBod-prescribed receipt

Who

Tier 1 licensed gold buyer

Needs

Tier 1 buyer licence; GoldBod-prescribed receipt to the miner

Issues

GoldBod-prescribed receipt for an onward sale

• Ghana Gold Board Act, 2025 (Act 1140), s.67(1)

Sell to a licensed aggregator at the official price, against a GoldBod-prescribed receipt

Who

Tier 2 licensed gold buyer

Needs

Tier 2 buyer licence; Purchase booking with the financing Tier 2 buyer or aggregator (within 5 minutes)

Issues

GoldBod-prescribed receipt for an onward sale

• Ghana Gold Board Act, 2025 (Act 1140), s.67(1)

Carry gold between buying points and to GoldBod by licensed bullion van with the necessary documentation and authorisation; no tampering with quantity or purity, no diversion (transporting cash or gold other than by licensed bullion van is a material breach of aggregator licence conditions)

Who

Licensed bullion van operator

• Ghana Gold Board Act, 2025 (Act 1140), s.66(1)

Record supplier and lot under GoldBod's unique ID system and hold KYC on suppliers

Who

GoldBod-licensed aggregator

Issues

Unique supplier and lot ID; Supplier onboarding KYC (documents, beneficial ownership, site verification)

Deliver aggregated doré to GoldBod

Who

GoldBod-licensed aggregator

Needs

Aggregator licence; GoldBod-prescribed receipt for an onward sale

Aggregation is defined as collecting gold "for onward delivery to the Gold Board" (Act 1140 s.74).

• Ghana Gold Board Act, 2025 (Act 1140), s.3(2)(b); s.74

Weigh, grade, assay (XRF standard from 1 Sept 2026) and value the doré

Who

GoldBod assay laboratory (Kotoka International Airport)

Issues

GoldBod assay and valuation certificate

Form

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

• Ghana Gold Board Act, 2025 (Act 1140), s.3(2)(a)

Pay the aggregator in cedis at the GoldBod price. Purchases were funded through Bank of Ghana bills to 2025; from 3 Aug 2026 a new model with commercial banks applies

Who

Ghana Gold Board (state buyer and exporter)

Needs

GoldBod assay and valuation certificate

The funding mechanism is from press analysis; GoldBod has not published the payment procedure

Agree the sale with an international offtaker (pricing basis and discount not published)

Who

Ghana Gold Board (state buyer and exporter)

Issues

Commercial invoice

GoldBod's sale contracts were not seen; the losses analysis reports a ~17% loss on doré sold in 2025

Issue the export authorisation for its own lot (as sole exporter of non-large-scale gold)

Who

Ghana Gold Board (state buyer and exporter)

Needs

GoldBod assay and valuation certificate

Issues

GoldBod export approval / export permission

[unconfirmed] Act 1140 s.3(2)(c) makes GoldBod the sole exporter of non-large-scale gold, and "licence" includes any GoldBod approval (s.74); whether GoldBod issues itself a separate export document was not found.

• Ghana Gold Board Act, 2025 (Act 1140), s.3(2)(c)

Apply to the Ghana National Chamber of Commerce and Industry for a certificate of origin for the consignment (gold wholly obtained in Ghana), where the buyer or the importing country's customs requires one

Who

Ghana Gold Board (state buyer and exporter)

Needs

Commercial invoice

Issues

GNCCI certificate of origin

[summary] GNCCI as issuer from a summarised read (Ghana Shippers Authority item); [blocked] GNCCI's own page returned 403; [unconfirmed] whether gold exporters in practice obtain a GNCCI certificate, and its fee and form, were not found. [inferred] Treated as optional because no Ghanaian rule requiring it on export was found.

• Customs Act, 2015 (Act 891), s.70(3) (wholly obtained goods originate in Ghana); s.70(6) (certificate of origin provided to the proper officer on request)

Obtain a Bank of Ghana Exchange Control Form A2 from the bank (traditional export); lodge the customs declaration electronically on ICUMS with the export approval, invoice and other certificates attached; present the gold at the exit port or station for customs inspection; release for export

Who

Ghana Gold Board (state buyer and exporter)

Needs

GoldBod export approval / export permission; Commercial invoice

Issues

Bank of Ghana Exchange Control Form A2 (from the exporter's bank, traditional exports); ICUMS customs export declaration

[unconfirmed] The GRA procedure is general to traditional exports (it names "Unprocessed gold"); the gold-specific attachments and whether a state exporter uses Form A2 were not found. [not-read] The export-entry sections of the Customs Act 2015 were not read.

• GRA Customs export procedure (traditional exports); Customs Act, 2015 (Act 891)

Ship by air from Accra (Kotoka International Airport) to the offtaker

Who

Ghana Gold Board (state buyer and exporter)

Needs

ICUMS customs export declaration

Issues

Air waybill

Air route inferred from GoldBod's assay lab at KIA; carriers and routing not published

File the FPP import-control application in GIIS DMDK with the foreign-trade contract, specification, document on precious-metal content and special-registration record

Who

Importer of gold-bearing material for refining (refiner or special-registered company)

Needs

Special-registration register entry (FPP); Assay certificate (fineness and fine weight); Commercial invoice

Issues

FPP application for import control

• EEC Board Decision 30, Annex 14, Annex 2 (Rules) para 4(a), Rules para 4(a)

State control at a specialised customs post (all goods except ores and concentrates), within 5 working days; act of state control

Who

Federal Assay Chamber

Needs

FPP application for import control

Issues

Act of state control on import

• Presidential Decree 1137 para 19¹; EEC Board Decision 30, Annex 14, Annex 2 para 10, para 19¹

Declare the goods at a specialised customs post for release or processing, presenting the act of state control, and take delivery to the refinery

Who

Importer of gold-bearing material for refining (refiner or special-registered company)

Needs

Act of state control on import

Issues

EAEU goods declaration for import / customs processing

[not-read] Import duty and import VAT treatment of gold-bearing material not read.

• EEC Board Decision 30, Annex 14 paras 4, 8, Regulation para 8

Screen buyer and destination: Russian-origin gold exported after the sanctions dates cannot be imported into the EU, UK, US, Switzerland or Japan, and Russian bars made from 7 Mar 2022 are not LBMA Good Delivery; sales go to non-sanctioning markets

Who

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

Sign the export contract and issue the commercial invoice

Who

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

Issues

Export contract with foreign buyer; Commercial invoice

Apply to Minpromtorg for an export licence (one-off for a contract, or a general licence under Decree 1126 or 867); Minfin approves the application in GIIS DMDK within 10 working days (Order 10n from 1 Sep 2026), except credit organisations' applications for refined gold, silver, platinum and palladium bars since 8 May 2026

Who

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

Needs

Export contract with foreign buyer; Special-registration register entry (FPP)

Issues

Minfin conclusion (permissive document) approving an export-licence application (Order 10n from 1 Sep 2026); EAEU export licence issued by Minpromtorg (one-off or general)

Licence validity and issue time from EEC Council Decision 125 Rules paras 9 and 13: a one-off licence is valid up to 1 year from its start (may be limited to the contract term); a general licence up to 1 year; the licensing authority decides within 15 working days of receiving the documents unless the Commission decision introducing the measure sets another term. [unconfirmed] Decision 125's own in-force date depends on the Protocol of 25.05.2023 (see ru.law-eec-125).

• Presidential Decree 1137, Regulation paras 4 and 22; Minfin Order 10n, paras 4, 22

File the application letter for FPP state control through GIIS DMDK with: the export licence copy (table-1 goods), the contract, the specification, the invoice, the calculation of the value of the precious metals (within 5% of world prices), special-registration record or bank licence, proof of lawful ownership, the precious-metal content document, technical documentation, the subsoil licence (mining subjects) and the document on the State Fund's refusal to buy (mining and producing subjects)

Who

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

Needs

EAEU export licence issued by Minpromtorg (one-off or general); Export contract with foreign buyer; Commercial invoice; Document on the authorised bodies' refusal (non-exercise) to purchase; Passport for standard bar / certificate for measured bar of refined precious metal (FPP Order 154n; replaced by a single certificate under Order 144n from 1 Mar 2027)

Issues

Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK; Calculation of the value of precious metals in the consignment

[transcription] EEC Board Decision 30 read in the ConsultantPlus copy published by the FPP; the FPP list reproduces the same paragraph.

• EEC Board Decision 30, Annex 14, Annex 2 (Rules) para 4(b); Minfin Order 11n (valuation), Rules para 4(b)

State control of the whole consignment within 5 working days: check against documents, origin, compliance with transaction rules, valuation, optional sampling; issue the act of state control (3 copies; the first for customs) or a refusal

Who

Federal Assay Chamber

Needs

Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK

Issues

Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber

• EEC Board Decision 30, Annex 14, Annex 2 (Rules) paras 3, 8, 10; 41-FZ art. 26², Rules para 10

Lodge the export declaration at a specialised customs post, presenting the export licence and the act of state control

Who

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

Needs

EAEU export licence issued by Minpromtorg (one-off or general); Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber; Commercial invoice

Issues

Export goods declaration (accepted and released by customs); Certificate of origin (general form) for non-EAEU destinations

[not-read] The customs rules on the declaration itself were not read.

• EEC Board Decision 30, Annex 14 paras 4-5; Presidential Decree 1137 para 19¹, Regulation paras 4-5

Carry the sealed consignment to the airport and hand to the airline (valuable cargo)

Who

Secure carrier of valuables

Needs

Export goods declaration (accepted and released by customs)

Issues

Packing list; Air waybill

The armed-escort rule (41-FZ art. 29(3)) covers transport to the airport; no rule on the hand-over to the airline was read.

• Federal Law 41-FZ, art. 29(3)

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

Sell FX from gold exports to commercial banks (spot and funded forwards) and supply the rest to the Bank of Ghana for reserves under GANRAP (from 3 Aug 2026; Aug 2026: US$668.21m to banks, US$646.59m to BoG)

Who

Ghana Gold Board (state buyer and exporter)

Issues

FX sale confirmation (spot or funded forward)

Repatriate export proceeds through sales of FX and bullion to the Bank of Ghana and transfers through Ghanaian commercial banks, keeping any retention account the Minister for Finance allows

Who

Large-scale mining company (mining lease holder)

Act 703 s.30(2) read: the Minister for Finance may permit a lease holder with foreign-exchange earnings to keep "not less than twenty five percent" in a retention account. [summary] A BoG notice of 30 Oct 2025 (reported by GhanaWeb) requires exporters to repatriate proceeds through their nominated bank within 120 days of shipment (one 60-day extension); the notice and the Foreign Exchange Act 2006 (Act 723) are not held. Share repatriated is disputed: Chamber of Mines ~70% (70.8% in 2024) vs GoldBod 20%.

• Minerals and Mining Act, 2006 (Act 703), s.30(2)