Papua New Guinea [alluvial] → Australia (refine) · Domestic bullion dealing (AML/CTF and GST)

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

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Papua New Guinea (Doré bar - unstamped) ⟶ Australia (Doré bar - unstamped → 999.9 kilobar)

Leg 1: Papua New Guinea

Where the goods start

1
Mine alluvial gravels by panning and sluicing on own customary land (no tenement, s.9) or within an Alluvial Mining Lease; recover black-sand concentrate
Who
Alluvial miner (citizen landowner or land group; non-mechanised under Mining Act s.9 or holder of an alluvial mining lease)
Form
Ore (in situ / run-of-mine) → Concentrate / black sand
Primary law
- Mining Act 1992, s.9(2); ss.48-51
2
Separate gold from the concentrate by panning (mercury amalgamation used in parts of the sector) to obtain gold dust and nuggets
Who
Alluvial miner (citizen landowner or land group; non-mechanised under Mining Act s.9 or holder of an alluvial mining lease)
Form
Concentrate / black sand → Gold dust / nuggets
Industry practice
The Minister's update describes panning and sluicing; the extent of mercury use was not documented in any source read.
3
Customer due diligence on the seller (identify the miner, risk-rate, screen) and keep records for 7 years
Who
Domestic gold buyer (rural buying agent / shop)
Issues
Gold buyer's CDD record on the miner (AMLCTF Act ss.20-29)
Official guidance
- AMLCTF Act 2015, s.5; ss.20-29; ss.47-50
4
Sell gold dust to a domestic gold buyer, usually for cash, weighed at the counter; no BPNG authority needed for resident-to-resident trade
Who
Alluvial miner (citizen landowner or land group; non-mechanised under Mining Act s.9 or holder of an alluvial mining lease)
Needs
Gold buyer's CDD record on the miner (AMLCTF Act ss.20-29)
Issues
Buyer's purchase record / weigh-in (weight, price, seller)
Official guidance
FE Notice 17.3 permits domestic trade without restriction, although Regulation ss.25-26 on their face limit gold purchases to BPNG and authorised dealers; see divergences.
- BPNG Foreign Exchange Manual, FE Notice 17, 17.3
5
File a Threshold Transaction Report with FASU for a cash transaction of K20,000 or more within 10 working days; file a Suspicious Matter Report within 5 working days where suspicion arises
Who
Domestic gold buyer (rural buying agent / shop)
Issues
TTR for cash purchase of K20,000 or more
Official guidance
- AMLCTF Act 2015, s.39
6
Customer due diligence and enhanced due diligence on the gold buyer or miner (BPNG Enhanced Due Diligence Guidelines apply to all gold dealings)
Who
Licensed alluvial gold exporter (BPNG Gold Export Licence holder)
Issues
Exporter's CDD on the gold buyer/miner and enhanced due diligence
Official guidance
- BPNG FE Manual FE Notice 17; AMLCTF Act 2015, 17.2; ss.20-29
7
Sell aggregated gold dust to the licensed exporter (often via the exporter's own buying network)
Who
Domestic gold buyer (rural buying agent / shop)
Needs
Exporter's CDD on the gold buyer/miner and enhanced due diligence
Issues
Exporter's purchase record
Official guidance
Domestic purchase terms and payment method not documented; bank payment implied by the two-account limit in the licence conditions.
8
Melt gold dust into bars and number them
Who
Licensed alluvial gold exporter (BPNG Gold Export Licence holder)
Issues
Bar number / lot reference after melting
Form
Gold dust / nuggets → Smelted button/bar
Industry practice
The Operational Requirements speak of 'dore or fine gold'; melting practice itself is inferred.
9
Assay the bars and issue an assay report certified by MRA (or another competent institution)
Who
MRA-certified assayer / competent assay institution
Needs
Bar number / lot reference after melting
Issues
Assay report certified by MRA or other competent institution
Form
Smelted button/bar → Doré bar - stamped/exporter-sealed
Official guidance
- BPNG Operational Requirements for Gold Export Licence (2015)
10
Prepare signed pro-forma invoice (expected USD receipts, weight in grams and ounces, LBMA spot USD price) under the refining agreement; sales abroad must be in USD at LBMA spot
Who
Licensed alluvial gold exporter (BPNG Gold Export Licence holder)
Needs
Assay report certified by MRA or other competent institution; Refining agreement with overseas refiner (LBMA spot, max 2% discount)
Issues
Signed pro-forma invoice (USD receipts, grams and ounces, LBMA spot price)
Official guidance
11
Apply to BPNG with Form G, the pro-forma invoice and the MRA-certified assay report for a specific authorisation to export this shipment; BPNG approves the Form G
Who
Licensed alluvial gold exporter (BPNG Gold Export Licence holder)
Needs
Gold Export Licence (alluvial); Performance bond in favour of BPNG; Assay report certified by MRA or other competent institution; Signed pro-forma invoice (USD receipts, grams and ounces, LBMA spot price)
Issues
BPNG-approved Form G (specific authorisation for one shipment)
Official guidance
- Central Banking (Foreign Exchange and Gold) Regulation 2000; FE Notice 17, s.24; FE 17.4(a)
12
For a consignment worth K5,000 or less: obtain a BPNG clearance on the strength of an assay report from a recognised assayer instead of a licence-based authorisation
Who
Licensed alluvial gold exporter (BPNG Gold Export Licence holder)
Needs
Assay report certified by MRA or other competent institution
Issues
BPNG clearance for gold export of K5,000 or less
Official guidance
- BPNG FE Manual FE Notice 17, 17.4(b)
13
Obtain MRA mineral export permit, where required
Who
Licensed alluvial gold exporter (BPNG Gold Export Licence holder)
Unverified
PNG Customs lists MRA as the permit authority for 'minerals', but no MRA gold export permit, form or legal basis was found; for gold the Prohibited Exports Regulation names only BPNG.
14
Pack and seal consignment; commercial invoice and packing list
Who
Licensed alluvial gold exporter (BPNG Gold Export Licence holder)
Needs
BPNG-approved Form G (specific authorisation for one shipment)
Issues
Commercial invoice; Packing list
Official guidance
15
Lodge the export SAD in ASYCUDA World (nature, quantity, FOB value, supplier, origin, TFN) with BPNG written authority attached, before goods are loaded
Who
Licensed customs broker
Needs
BPNG-approved Form G (specific authorisation for one shipment); Commercial invoice; Packing list
Issues
Export SAD / Form 15 accepted by PNG Customs
Primary law
- Customs Act 1951; Customs (Prohibited Exports) Regulation 1963, s.42; Schedule item 13B
16
Verify classification and permits, risk-based physical examination, collect administrative fees, issue release
Who
PNG Customs Service
Needs
Export SAD / Form 15 accepted by PNG Customs; BPNG-approved Form G (specific authorisation for one shipment)
Issues
Customs release notification
Official guidance
- Customs Act 1951; Central Banking (FX and Gold) Regulation 2000, FX Reg s.19(2) (Customs may require documents to check BPNG compliance)
17
Carry consignment as valuable cargo from Jacksons International Airport (Port Moresby) with air waybill, security declaration and insurance
Who
Air carrier / secure logistics provider
Needs
Customs release notification
Issues
Air waybill; Consignment Security Declaration; Certificate of insurance
Industry practice
Airport and valuable-cargo handling for gold not documented in sources read; standard air-freight documents assumed.
18
Aircraft master presents final manifest; Customs issues Certificate of Clearance
Who
PNG Customs Service
Issues
Certificate of Clearance (conveyance)
Primary law
- Customs Act 1951, s.47
19
Send pre-shipment notice (weights, assay, AWB) to the consignee refiner
Who
Licensed alluvial gold exporter (BPNG Gold Export Licence holder)
Needs
Air waybill
Issues
Pre-shipment notification to refiner/buyer
Industry practice

Taxes and fees

Export duty on gold
None found (administrative fees only)
UnverifiedAmount not confirmed
Gold Export Licence application fee
K5,000 per application (annual)
Official guidanceAmount not confirmed
Mineral royalty
2% Mined product incl. doré and concentrate
Official guidanceAmount not confirmed
- Mining Act 1992, s.148
Alluvial Mining Lease application fee
PGK 250
Official guidanceAmount not confirmed
MRA production levy
0.25% (2014) - 0.5% (statutory maximum; reported current rate 2025)
Official guidanceAmount not confirmed
- Mineral Resources Authority Act, s.30(3)-(4) per DMPGM 2014

Controls

Travellers may take PNG or foreign currency up to K20,000; more needs BPNG authority on Form-C1 (with tax clearance, passport, ticket). Customs currency declaration system being rolled out, most advanced at Jacksons International Airport (APG 2024).
K20,000
Official guidanceAmount not confirmed
- FE Manual FE Notice 8; Customs (Prohibited Exports) Regulation 1963, 8.5; item 13A
Dealers in precious metals are DNFBPs: risk-based CDD, enhanced CDD for PEPs, SMR within 5 working days, Threshold Transaction Report for cash or bearer instruments of K20,000 or more within 10 working days, international funds transfer reports of K20,000 or more, records for 7 years. FASU is the su…
K20,000 cash (TTR)
Official guidanceAmount not confirmed
- AMLCTF Act 2015, ss.5, 20-29, 39, 47-50
Alluvial mining is reserved to PNG citizens (AML only for citizens/land groups; alluvial mining leases need 51% national ownership). The 2021 Alluvial Mining Policy extends the reservation to buying and exporting alluvial gold, with existing foreign operators exempted. Confirmed by the Mining Minist…
Official guidance
- Mining Act 1992 s.48; Alluvial Mining Policy 2021
No person may take or send gold out of (or bring into) PNG without BPNG's written consent; alluvial gold, concentrates and gold compounds are a restricted export under Customs item 13B. In practice: annual Gold Export Licence plus a per-shipment authorisation (Form G) for consignments above K5,000; …
K5,000 per consignment
Primary lawAmount not confirmed
- Central Banking (Foreign Exchange and Gold) Regulation 2000; Customs (Prohibited Exports) Regulation 1963, s.24; item 13B
Refining agreement must reference LBMA spot with a discount of no more than 2%; export sales in USD at LBMA spot.
Official guidance
- BPNG Requirements and Operational Requirements for Gold Export Licence (2015)
All export proceeds must be received through an authorised dealer, repatriated and converted into kina: within 2 weeks of export for alluvial Gold Export Licence holders; within 3 months of shipment under FE Notice 6. Sales abroad in USD at LBMA spot. Mineral exporters may not use forward exchange c…
2 weeks (alluvial GEL); 3 months (general)
Official guidanceAmount not confirmed
- BPNG Operational Requirements (2015); FE Manual, FE 6.5, 17.5; FX Operational Guidelines 9.9.5
A person holding gold (other than for professional use) must sell it within one month to BPNG, an authorised dealer, or with written consent to a person outside PNG; only BPNG and authorised dealers may buy gold (s.26). BPNG's FE Manual nonetheless states domestic resident-to-resident gold trade is …
1 month from possession
Primary lawAmount not confirmed
- Central Banking (Foreign Exchange and Gold) Regulation 2000, ss.25-26

Leg 2: Australia

Where the goods arrive

Doré bar - unstamped → 999.9 kilobar

20
Onboard the foreign supplier: KYC, origin and chain-of-custody documents, export authorisation of the origin country, under LBMA RGG
Who
Australian gold refiner (LBMA Good Delivery-listed)
Issues
Supplier KYC pack for imported doré/scrap
Standard
RGG duties inferred from GD status; no Australian statute imposes refiner origin checks.
21
Screen for Russian-origin gold: import, purchase or transport of Russian gold exported after 30 Sep 2022 is prohibited without a sanctions permit
Who
Importer of doré or bullion (usually the refiner or a dealer)
Issues
Screen for Russian-origin gold
Primary law
- Autonomous Sanctions Regulations 2011 regs 4A, 12A, 18(1)(b); Import Sanctioned Goods-Russia Designation 2022 Sch 1 item 16
22
Lodge the import declaration (entry for home consumption) in the Integrated Cargo System for consignments above the entry thresholds; customs duty Free for 7108 and 7112.91; importation of precious metal (99.5%+, investment form) is a non-taxable importation for GST; dore is a taxable importation (GST 10% of the value of the taxable importation)
Who
Licensed customs broker
Needs
Screen for Russian-origin gold; Export customs declaration accepted by the dispatching country's customs; Air waybill; Commercial invoice
Issues
Import declaration, HS 7108 / 7112.91
Primary law
[inferred] GST on imported dore follows from ss.13-5/13-10 with the precious-metal definition; [not-read] duty rate from the ABF tariff page, not the Act.
- Customs Act 1901 ss.68, 71A; Customs Tariff Act 1995 Sch 3; GST Act 1999 ss.13-5, 13-10, 13-20
23
Refine doré to 999.9 kilobars/minted bars or 995+ Good Delivery bars; cast, mark (refiner mark, serial, fineness) and record
Who
Australian gold refiner (LBMA Good Delivery-listed)
Needs
Outturn / assay statement
Issues
Bar list for refined bars
Form
Doré bar - unstamped → 999.9 kilobar
Industry practice
24
Maintain LBMA Good Delivery and RGG compliance; publish the annual RGG compliance report with independent assurance
Who
Australian gold refiner (LBMA Good Delivery-listed)
Issues
Refiner RGG report and assurance
Secondary
25
Report suspicious matters to AUSTRAC (refiner bullion business is a reporting entity)
Who
Australian gold refiner (LBMA Good Delivery-listed)
Issues
Suspicious matter report
Primary law
[inferred] The refiner is a reporting entity because it buys and sells bullion in a bullion-dealing business (s.6 table 2 item 1); the Perth Mint enforceable undertaking confirms it for that refiner.
- AML/CTF Act 2006, s.6(3) table 2 item 1; s.41
26
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
27
Enrol with AUSTRAC within 28 days of starting a designated service and adopt an AML/CTF program (bullion dealing; from 31 Mar 2026 also buying or selling precious metal for $10,000 or more in physical currency or virtual assets, with obligations from 1 Jul 2026)
Who
Bullion dealer / dealer in precious metal
Issues
AUSTRAC enrolment; AML/CTF program
Primary law
- AML/CTF Act 2006, s.6(3) table 2 items 1-2; ss.26B, 51B
  “buying or selling one or more of the following items in the course of carrying on a business, where the purchase involves the transfer of physical currency or virtual assets (or a combination of physical currency and virtual assets) with a total value of not less than $10,000, whether the purchase is made in a single transaction or in several transactions that are linked or appear to be linked: (a) precious metal; (b) precious stones; (c) precious products”
28
Carry out customer due diligence before providing the designated service; enhanced due diligence in higher-risk cases
Who
Bullion dealer / dealer in precious metal
Needs
AUSTRAC enrolment
Issues
Customer due diligence file
Primary law
- AML/CTF Act 2006, s.28 (initial CDD); s.39E item 11 (bullion under $5,000)
  “A reporting entity must not commence to provide a designated service to a customer if the reporting entity has not established on reasonable grounds each of the matters in subsection (2)”
29
Sell or buy bars: input-taxed supply of precious metal (no GST charged, no input credits), or GST-free if it is the refiner's first supply after refining to a dealer
Who
Bullion dealer / dealer in precious metal
Needs
Customer due diligence file
Issues
Commercial invoice (GST-free / input-taxed treatment stated)
Primary law
- A New Tax System (Goods and Services Tax) Act 1999, s.40-100; s.38-385
30
Report each threshold transaction (transfer of $10,000 or more in physical currency) to AUSTRAC within 10 business days
Who
Bullion dealer / dealer in precious metal
Issues
Threshold transaction report
Primary law
- AML/CTF Act 2006, s.43; s.5 threshold transaction
31
Report suspicious matters to AUSTRAC (within 3 business days, or 24 hours for terrorism financing suspicions)
Who
Bullion dealer / dealer in precious metal
Issues
Suspicious matter report
Primary law
- AML/CTF Act 2006, s.41

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: Papua New Guinea

Back in the origin country: the proceeds of the export

32
Refine consignment, issue outturn statement; exporter issues final invoice at LBMA spot less agreed discount (max 2%)
Who
Overseas refiner / buyer (consignee)
Issues
Refiner outturn statement; Final invoice (against outturn assay)
Official guidance
33
Receive USD proceeds from abroad (only through an authorised dealer); alluvial exporters must repatriate within 2 weeks of export, others within 3 months of shipment; convert to kina with an authorised dealer
Who
Authorised foreign-exchange dealer (commercial bank)
Issues
USD payment from refiner/buyer to exporter's PNG bank
Official guidance
- BPNG Operational Requirements (2015); FE Manual FE Notices 6 and 17, FE 6.5(a); FE 17.5
34
Submit Form-X with the licence or BPNG-approved Form G, commercial invoice and Customs-processed Form 15 to the authorised dealer; bank stamps the Yellow Form G
Who
Licensed alluvial gold exporter (BPNG Gold Export Licence holder)
Issues
Form-X submitted through the authorised dealer; Yellow Form G completed and stamped by the commercial bank
Official guidance
- FE Manual FE Notices 6 and 17, 6.3; 17.7(a)

Crossings between countries

Papua New Guinea → Australia Researched
Papers that cross: Assay report certified by MRA or other competent institution; BPNG-approved Form G (specific authorisation for one shipment); BPNG clearance for gold export of K5,000 or less; Commercial invoice; Packing list; Export SAD / Form 15 accepted by PNG Customs; Customs release notification; Air waybill; Consignment Security Declaration; Certificate of insurance; Certificate of Clearance (conveyance); Pre-shipment notification to refiner/buyer