Russian Federation (refine) [Licensed export (miner, refiner or bank)] → Hong Kong (China SAR) → United Arab Emirates · Reconcile assays and pay the balance

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

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Russia (Doré bar - unstamped → 999.9 kilobar) ⟶ Hong Kong SAR China (999.9 kilobar) ⟶ United Arab Emirates (999.9 kilobar)

Not researched: Hong Kong SAR China → United Arab Emirates

Leg 1: Russia

Where the goods start

Doré bar - unstamped → 999.9 kilobar

1
Extract gold ore or placer sands within the licensed plot
Who
Subsoil user (gold mining company)
Needs
Subsoil-use licence (electronic); Special-registration register entry (FPP)
Form
Ore (in situ / run-of-mine) → Concentrate / black sand
Primary law
- Law 'On Subsoil', art. 11
2
Process on site (gravity, leaching, smelting) into dore bars or placer (shlikh) gold; the metal must then go to refining
Who
Subsoil user (gold mining company)
Issues
Batch number / GIIS UIN of the dore lot
Form
Concentrate / black sand → Doré bar - unstamped
Primary law
Processing technology is industry practice; the law only requires "necessary processing" before refining.
- Federal Law 41-FZ, art. 20(1)
3
Sign a refining agreement with a listed refiner; it must set the delivery schedule and volumes, limits of harmful substances, the inventory of each lot, commission acceptance with control sampling, timing and specifications of the output, return-waste norms, the recipients of refined metal, the owner's delivery obligations to the State Fund or regional funds, liability and dispute settlement
Who
Subsoil user (gold mining company)
Issues
Refining (tolling) agreement miner-refiner
Primary law
- Government Decree 972, Procedure para 3, para 3
4
Record the lot in GIIS DMDK and issue an electronic accompanying document (ESD) with the lot's UIN for dispatch to the refiner
Who
Subsoil user (gold mining company)
Needs
Batch number / GIIS UIN of the dore lot; Refining (tolling) agreement miner-refiner
Issues
ESD for dispatch of dore/placer gold to the refiner
Official guidance
[not-read] The GIIS DMDK Rules (Decree 270) were not read in full; the ESD fields for dore were not seen.
- Government Decree 270 of 26.02.2021
5
Transport dore to the refinery by air, sea, inland water, rail or a specialised equipped road vehicle under armed escort
Who
Secure carrier of valuables
Needs
ESD for dispatch of dore/placer gold to the refiner
Primary law
- Federal Law 41-FZ, art. 29(3)
6
Receive the lot, weigh, sample and assay; record receipt in GIIS DMDK
Who
Refining organisation on the Government list
Needs
ESD for dispatch of dore/placer gold to the refiner; Refining (tolling) agreement miner-refiner
Issues
Refiner receipt: weighing and sampling record; Refiner assay of the incoming lot (metallurgical balance)
Primary law
- Government Decree 972, Procedure paras 3, 7, paras 3, 7
7
Refine to standard bars (gold at least 995 fine; usually 999.9)
Who
Refining organisation on the Government list
Form
Doré bar - unstamped → 999.9 kilobar
Primary law
[unconfirmed] 999.9 as the usual fineness is market practice; the legal minimum for refined gold is 995 parts per 1,000 (41-FZ art. 1).
- 41-FZ art. 1 (definition of refining), art. 20(1), art. 1
8
Issue the quality document for each bar - a passport for a standard bar or a certificate for a measured bar (FPP Order 154n, to 28 Feb 2027); from 1 Mar 2027 a single certificate generated in GIIS DMDK (FPP Order 144n); prepare the bar list
Who
Refining organisation on the Government list
Issues
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); Bar list (serials, weights, fineness)
Primary law
- Government Decree 972, Procedure para 7¹; FPP Orders 154n and 144n, para 7¹
9
Deliver bars to the owner (or to the buyer on the owner's instruction) with a GIIS DMDK ESD; metal is booked on the owner's balance and enters civil circulation
Who
Refining organisation on the Government list
Needs
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
ESD for shipment of refined bars to the owner or buyer
Primary law
- Federal Law 41-FZ, art. 20(3)
10
Screen buyer and destination: Russian-origin gold exported after the sanctions dates cannot be imported into the EU, UK, US, Switzerland or Japan, and Russian bars made from 7 Mar 2022 are not LBMA Good Delivery; sales go to non-sanctioning markets
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Primary law
11
Sign the export contract and issue the commercial invoice
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Issues
Export contract with foreign buyer; Commercial invoice
Primary law
12
Apply to Minpromtorg for an export licence (one-off for a contract, or a general licence under Decree 1126 or 867); Minfin approves the application in GIIS DMDK within 10 working days (Order 10n from 1 Sep 2026), except credit organisations' applications for refined gold, silver, platinum and palladium bars since 8 May 2026
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Needs
Export contract with foreign buyer; Special-registration register entry (FPP)
Issues
Minfin conclusion (permissive document) approving an export-licence application (Order 10n from 1 Sep 2026); EAEU export licence issued by Minpromtorg (one-off or general)
Primary law
Licence validity and issue time from EEC Council Decision 125 Rules paras 9 and 13: a one-off licence is valid up to 1 year from its start (may be limited to the contract term); a general licence up to 1 year; the licensing authority decides within 15 working days of receiving the documents unless the Commission decision introducing the measure sets another term. [unconfirmed] Decision 125's own in-force date depends on the Protocol of 25.05.2023 (see ru.law-eec-125).
- Presidential Decree 1137, Regulation paras 4 and 22; Minfin Order 10n, paras 4, 22
13
File the application letter for FPP state control through GIIS DMDK with: the export licence copy (table-1 goods), the contract, the specification, the invoice, the calculation of the value of the precious metals (within 5% of world prices), special-registration record or bank licence, proof of lawful ownership, the precious-metal content document, technical documentation, the subsoil licence (mining subjects) and the document on the State Fund's refusal to buy (mining and producing subjects)
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Needs
EAEU export licence issued by Minpromtorg (one-off or general); Export contract with foreign buyer; Commercial invoice; Document on the authorised bodies' refusal (non-exercise) to purchase; Passport for standard bar / certificate for measured bar of refined precious metal (FPP Order 154n; replaced by a single certificate under Order 144n from 1 Mar 2027)
Issues
Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK; Calculation of the value of precious metals in the consignment
Primary law
[transcription] EEC Board Decision 30 read in the ConsultantPlus copy published by the FPP; the FPP list reproduces the same paragraph.
- EEC Board Decision 30, Annex 14, Annex 2 (Rules) para 4(b); Minfin Order 11n (valuation), Rules para 4(b)
14
State control of the whole consignment within 5 working days: check against documents, origin, compliance with transaction rules, valuation, optional sampling; issue the act of state control (3 copies; the first for customs) or a refusal
Who
Federal Assay Chamber
Needs
Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK
Issues
Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber
Primary law
- EEC Board Decision 30, Annex 14, Annex 2 (Rules) paras 3, 8, 10; 41-FZ art. 26², Rules para 10
15
Lodge the export declaration at a specialised customs post, presenting the export licence and the act of state control
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Needs
EAEU export licence issued by Minpromtorg (one-off or general); Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber; Commercial invoice
Issues
Export goods declaration (accepted and released by customs); Certificate of origin (general form) for non-EAEU destinations
Primary law
[not-read] The customs rules on the declaration itself were not read.
- EEC Board Decision 30, Annex 14 paras 4-5; Presidential Decree 1137 para 19¹, Regulation paras 4-5
16
Carry the sealed consignment to the airport and hand to the airline (valuable cargo)
Who
Secure carrier of valuables
Needs
Export goods declaration (accepted and released by customs)
Issues
Packing list; Air waybill
Unverified
The armed-escort rule (41-FZ art. 29(3)) covers transport to the airport; no rule on the hand-over to the airline was read.
- Federal Law 41-FZ, art. 29(3)

Taxes and fees

Exchange-rate-linked export duty on gold
0% (average USD/RUB below 80), 4% (80-85), 4.5% (85-90), 5.5% (90-95), 7% (95 and above) of the customs value
Primary lawAmount not confirmed
- Government Decree 1538 of 21.09.2023, para 1; Decree 532 of 25.04.2024, para 1
Export duty on gold-bearing concentrates
Same exchange-rate-linked bands (0-7%) as Decree 1538 para 1 - group 26 (except 2609 00 000 0) is in the list, which covers precious-metal ores and concentrates (HS 2616) Precious-metal ores and concentrates (HS 2616) exported outside the EAEU
Primary lawAmount not confirmed
- Government Decree 1538 of 21.09.2023, para 1, para 1
Mineral extraction tax (NDPI) on gold
6.0% (art. 342(2)(5): "концентратов и других полупродуктов, содержащих в себе один или несколько драгоценных металлов"), times the rent coefficient KRENTA = 1 for these minerals (art. 342⁸(3)(2)) and the territory coefficient Ktd (art. 342(2²)) Gold-bearing semi-products at the end of the extraction operations (dore/ligature gold, placer and native gold, concentrates)
Primary lawAmount not confirmed
- Tax Code Part Two, ch. 26, arts. 337(2)(13), 340(5), 342(2)(5), 342⁸(3)(2)
NDPI surcharge on gold (2024)
RUB 78,000 per kg of gold contained in the extracted semi-product (КДРМ = VДРМ x 78 000) Tax periods beginning 1 June - 31 December 2024; gold in semi-products under art. 337(2)(13) extracted on licensed plots
Primary lawAmount not confirmed
- Federal Law 96-FZ of 22.04.2024, art. 1(7), adding Tax Code art. 343(21), art. 343(21) (2024 wording)
NDPI surcharge on gold from 2025
КДРМ = 0.1 x (ЦЗ / 1000 - 61 000) x VДРМ x Р: 10% of the excess of the month's average world gold price in USD per kg (ЦЗ is USD per tonne, art. 342¹⁰(1)) over USD 61,000 per kg, times the kg of gold contained, times the month's average USD/RUB rate
Primary lawAmount not confirmed
- Tax Code art. 343(21) as restated by Federal Law 176-FZ of 12.07.2024, art. 343(21)

Controls

FPP state control of every import from and export to non-EAEU states of goods in tables 1 and 3 of section 2.10 (41-FZ art. 26²; Decree 1137 para 19(b)): the whole batch is presented (for ores and concentrates, HS 2616, the documents only) and controlled within 5 working days; checks of the batch a…
Primary law
- EEC Board Decision 30, Annex 14, Annex 2 (Rules) paras 3, 4, 7, 8, 10; Presidential Decree 1137 paras 19, 19¹, Rules paras 3, 10
From 1 May 2026 export from Russia of refined gold in bars with a total weight over 100 g by individuals, legal entities and entrepreneurs is prohibited, except (a) to EAEU member states through the international airports Moscow (Vnukovo), Moscow (Domodedovo), Moscow (Sheremetyevo) and Vladivostok (…
Total weight over 100 g
Primary lawAmount not confirmed
- Presidential Decree 193 of 25.03.2026; Government Decree 450 of 23.04.2026, para 2, para 4
Purchase and sale of precious metals (and jewellery and scrap) of RUB 1,000,000 or more is subject to mandatory control and reported to Rosfinmonitoring by the seller within 3 working days; individuals buying jewellery up to RUB 60,000 (RUB 400,000 with a personalised e-payment means) are not identi…
RUB 1,000,000
Primary lawAmount not confirmed
- Law 115-FZ, art. 6(1)(4) sixth paragraph; art. 7(1.4-2)
Only listed refiners, Goznak and credit organisations may sell refined (investment) bars to individuals, and retailers only bars received on commission or agency from them; buy-back dealers and pawnshops may pass bars bought from individuals only to refiners. Deals between individuals in precious me…
Primary law
- Government Decree 604 of 15.05.2024 (Rules paras 3-4, 8); 41-FZ art. 22(6), Rules para 4
No gold-specific cash-payment limit was found. The RUB 1,000,000 mandatory-control threshold applies whatever the means of payment.
Unverified
Export to non-EAEU states of goods in tables 1 and 2 of section 2.10 of the EAEU Single List (table 1 includes refined gold in bars, plates, powder and granules, unique and non-refinable nuggets, other unwrought gold incl. dore, scrap, ores and concentrates) requires a licence issued by Minpromtorg …
Primary law
- Presidential Decree 1137 (Regulation paras 4, 22, 23); EEC Board Decision 30, Annex 14 para 5; Minfin Order 10n, paras 4, 22, 23
Residents must receive export proceeds on their accounts in authorised banks (173-FZ art. 19(1)(1)). Under art. 19(8) this does not apply to contracts priced or payable in foreign currency, except for goods listed there; the list includes HS 7101-7103 and 7112 but not 7108 (gold). Where art. 19 appl…
Primary law
- Federal Law 173-FZ art. 19; Presidential Decrees 79 (para 2) and 430, art. 19(1), (8)
Traceability: participants must record precious-metal operations in GIIS DMDK, with UINs and electronic accompanying documents between participants; refiners report receipt and shipment of metal in any form.
Primary law
- 41-FZ art. 12², art. 20(2); Government Decree 270 of 26.02.2021, art. 12²
Refined metal in standard form must, before it enters circulation, be offered by a purchase proposal to the State Fund institution under Minfin and to the authority of the mining region (where a regional fund exists) - for the next year by 31 December, with an additional proposal within 10 working d…
Primary law
- Federal Law 41-FZ, art. 2(5), art. 20(4)-(5)
LBMA suspended six Russian refiners on 7 Mar 2022; their bars produced from that date are not Good Delivery; Russian bars already in loco London/Swiss before then remain Good Delivery, with clearing banks attesting conformity.
Standard
Mined and produced precious metals (except nuggets) must, after the necessary processing, go for refining to organisations on the Government list (41-FZ art. 20(1)); only listed organisations may refine (art. 4(4)); the refining agreement's mandatory terms and the refiner's reporting duties are set …
Primary law
- Federal Law 41-FZ, art. 20(1)
Switzerland: purchase, import, transit and transport into and through Switzerland of gold under Annex 26 (includes HS 7108) originating in Russia and exported from Russia after 4 August 2022 are prohibited (Art. 14d(1)); the same applies to such gold processed in a third country (Art. 14d(2)) and, s…
Primary law
- Swiss Ukraine Ordinance SR 946.231.176.72 (Stand 21.09.2026), Art. 14d
EU: it is prohibited to purchase, import or transfer, directly or indirectly, gold listed in Annex XXVI (HS 7108; 7112 91 gold waste and scrap; ex 7118 90 gold coins) that originates in Russia and was exported from Russia into the Union or to any third country after 22 July 2022 (art. 3o(1)); the sa…
Primary law
- Regulation (EU) 833/2014 as amended by 2022/1269, art. 3o
Japan: import of precious metals originating in Russia and shipped from Russia on or after 1 August 2022 requires the Minister of Finance's permission under FEFTA art. 19(2) (MOF Notice No 443 of 2006 as amended 25 July 2022, item 4); the government announced it on 5 July 2022 as an import ban.
Primary law
- MOF Notice No 443 of 2006 as amended 25 Jul 2022, item 4
UK: import of gold originating in Russia and exported from Russia on or after 21 July 2022 is prohibited (reg 46Z11, Chapter 4J inserted by SI 2022/850, in force 21 Jul 2022), with prohibitions on acquisition with intent to import, supply and delivery, technical assistance, financial services and br…
Primary law
- Russia (Sanctions) (EU Exit) Regulations 2019, regs 46Z11-46Z16, 46Z16A-46Z16C
US: import of gold of Russian Federation origin is prohibited from 28 Jun 2022, except gold located outside Russia before that date (OFAC determination under E.O. 14068 s. 1(a)(i)(A), amended version of 22 Dec 2023). U.S. persons may not deal with the Central Bank, the National Wealth Fund or the Mi…
Primary law
- E.O. 14068 and the OFAC determination; E.O. 14024 as amended by E.O. 14114, E.O. 14068 s. 1(a)(i)(A); E.O. 14024 s. 11
  “the importation into the United States of … products of Russian Federation origin”
Temporary ban from 1 June to 30 November 2026 on export from Russia of precious-metal waste and scrap (HS 7112) and electrical and electronic waste used mainly to recover precious metals (8549 21 000 0, 8549 29 000 0), with exceptions for samples of up to 500 g per batch exported by listed refiners …
Primary law
- Government Decree 558 of 16.05.2026, para 1
Legal entities, entrepreneurs and artist-jewellers operating with precious metals must be on the FPP special register kept in GIIS DMDK; those that should be registered and are not may not carry out operations (41-FZ art. 13¹(2)). Registration within 30 calendar days of state registration (Rules pa…
Primary law
- 41-FZ art. 13¹; Government Decree 1052 (Rules paras 2, 5), art. 13¹
Precious metals and products from them are transported by air, sea, inland water, rail or specialised equipped road vehicles under armed escort; raw materials with less than 1% gold (or 5% silver), jewellery, investment metals (within a weight limit set by the Government) and some other items may mo…
Primary law
- Federal Law 41-FZ, art. 29(3)

Leg 2: Hong Kong SAR China

On the way

17
Onboard the supplier: KYC and source-of-supply review. Hong Kong law makes CDD mandatory for a Category B registrant only for specified cash transactions (AMLO s.5A(5A)); for bank-paid purchases the pack is the importer's own risk choice, with LBMA/OECD guidance applying where the buyer or refiner is bound by it
Who
Registered bullion dealer / trader (DPMS registrant)
Needs
DPMS Category A registration certificate; Commercial invoice
Issues
Supplier KYC pack held by the Hong Kong importer; Customer due diligence file (Category B, specified cash transaction); Supplier's commercial invoice
Official guidance
[inferred] No Hong Kong rule found that requires origin documents for imported gold; the KYC pack is commercial practice outside cash transactions. The legal scope of CDD is read in the Ordinance.
- AMLO s. 5A and Sch. 2 (only for specified cash transactions), s. 5A(5A)-(5B)
  “An AML/CTF requirement that applies to a DNFBP who is a Category B PMS registrant only applies when, by way of business, the registrant carries out, in Hong Kong with a customer, a specified cash transaction that is not an excluded transaction”
18
Fly the consignment into HKIA and deliver it to the importer's vault. If it is transhipment cargo (consigned on a through bill of lading or through air waybill to a place outside Hong Kong) or transit cargo, no Hong Kong declaration is required and the gold never enters the Hong Kong market
Who
Secure logistics carrier / forwarder
Needs
Supplier's commercial invoice; Air waybill; Export customs declaration accepted by the dispatching country's customs
Issues
Inbound air waybill
Primary law
- Import and Export (Registration) Regulations (Cap. 60E), reg. 3(a)-(b); Cap. 60 s. 2 (transhipment cargo, article in transit)
19
Receive the bars, weigh them and check serials against the bar list; credit the importer's allocated account
Who
Precious-metals vault operator
Needs
Inbound air waybill
Issues
Weight and quality verification record; Bar list (serials, weights, fineness); Allocated account weight list
Industry practice
[inferred] Vault intake practice is not documented in an official source; the clearing press release confirms designated vaults record deposits.
20
Lodge the import declaration within 14 days after the day of importation using the specified system (Trade Single Window, or during the transition a government-appointed service provider). Gold bars of fineness 995.0 or above (HKHS 7108 1210, 7108 2010) go on Form 1B with no declaration charge; other gold pays the charge. No customs duty or VAT; gold is not an exempted article
Who
Registered bullion dealer / trader (DPMS registrant)
Needs
Inbound air waybill; Supplier's commercial invoice
Issues
Hong Kong import declaration (Cap. 60E, lodged electronically within 14 days)
Primary law
- Import and Export (Registration) Regulations (Cap. 60E), regs 3, 4(1)-(2), 7, 8(1), (1AA), (4), 18
21
If the gold is paid for with physical currency or BNIs above HK$120,000 carried across the boundary, declare the cash (not the gold) to C&ED: advance CDS declaration for cargo, red channel for arriving travellers
Who
Registered bullion dealer / trader (DPMS registrant)
Issues
CBNI advance electronic declaration (CDS) for cash moved as cargo
Primary law
- Cap. 629, ss. 2, 4, 9, 11; Sch. 4
22
Mainland buyer (holder of a PBOC gold import qualification) obtains a PBOC Gold and Gold Products Import/Export Permit for the consignment: one shipment, one permit, used within 40 working days
Who
Mainland importer holding a PBOC gold import qualification
Issues
PBOC Gold and Gold Products Import/Export Permit (中国人民银行黄金及黄金制品进出口准许证)
Primary law
- PBOC/GACC gold import-export measures, Arts. 3, 8, 17
23
Agree the sale with the Mainland importer and release bars (typically 999.9 kilobars or bank-refined bars) to the cross-boundary carrier
Who
Registered bullion dealer / trader (DPMS registrant)
Needs
PBOC Gold and Gold Products Import/Export Permit (中国人民银行黄金及黄金制品进出口准许证); Allocated account weight list
Issues
Hong Kong exporter's commercial invoice; Packing list; Outbound air waybill / cross-boundary transport document
Official guidance
[unconfirmed] Bar form preferred by the Mainland market not confirmed from an opened source.
24
Lodge the Hong Kong export declaration within 14 days; C&SD records the flow as an export to the Mainland
Who
Registered bullion dealer / trader (DPMS registrant)
Needs
Hong Kong exporter's commercial invoice
Issues
Hong Kong export / re-export declaration (Cap. 60E, lodged within 14 days)
Primary law
C&SD FAQ Q1: Hong Kong is a separate customs territory, so a declaration is required for goods exported to the Mainland.
- Import and Export (Registration) Regulations (Cap. 60E), reg. 5(1)-(2)
25
Clear Mainland customs by presenting the PBOC permit, then register the gold on the State Council-approved gold spot exchange and complete its first trade there
Who
Mainland importer holding a PBOC gold import qualification
Needs
PBOC Gold and Gold Products Import/Export Permit (中国人民银行黄金及黄金制品进出口准许证); Hong Kong export / re-export declaration (Cap. 60E, lodged within 14 days); Export customs declaration accepted by the dispatching country's customs
Primary law
This step happens under Mainland law and belongs to the China module; kept here to show the hand-off.
- PBOC/GACC gold import-export measures, Arts. 6, 17

Taxes and fees

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

Controls

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

Leg 3: United Arab Emirates

Where the goods arrive

26
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
Official guidance
[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)
27
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)
Official guidance
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)
28
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)
Primary law
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)
29
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
Primary law
[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)
30
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)
Official guidance
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.
31
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
Secondary
[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

Taxes and fees

Customs duty on gold imports
0% for goods entering a free zone (FZ Transit In); mainland imports of gold: 0% under the GCC exempted-commodities list (read via WebFetch only) Unwrought and semi-manufactured gold
Official guidanceAmount not confirmed
- Dubai Customs Customer Guide v3.03; GCC common customs law; UAE list of exempted commodities, Customer Guide s.9 (duty suspended for goods admitted into free zones), s.15.12.2
Domestic reverse charge on precious metals and precious stones between registered businesses
Recipient accounts for VAT Supplies of gold, silver, platinum, palladium, precious stones and jewellery made of them, for resale or production, between VAT-registered persons, with the buyer's written declaration (CD 127/2024, replacing CD 25/2018)
Primary law
- Cabinet Decision 127/2024; FTA VATP043, Art. 1 (Goods: precious metals - gold, silver, palladium, platinum - precious stones and jewellery mostly of them), Art. 2(1)-(4), Art. 4 (repeals CD 25/2018)
  “Precious Metals, Precious Stones and jewelry made of any Precious Metals or Precious Stones”
Special reverse charge on gold and diamonds between registrants (Cabinet Decision 25/2018)
Registered recipient accounts for VAT Gold and products mostly of gold not qualifying for zero-rating, and diamonds, supplied between registrants; exports of gold items and investment precious metals outside its scope (VATP029)
Official guidance
- Cabinet Decision No. 25 of 2018
Import VAT
5% standard; 0% for investment precious metals (99%+ purity, tradeable form) Doré is not investment gold, so it is standard-rated; refined bars of 99%+ are zero-rated
Primary lawAmount not confirmed
- Federal Decree-Law 8/2017 on VAT; Executive Regulation, Art. 3 (5%), 45(8), 48(1), 49; Exec. Reg. Art. 36(2), 48, 50(1)
  “a standard rate of 5% Tax shall be imposed on any supply or Import”

Controls

Precious metals crossing the UAE border must be disclosed; declarations are also required for precious metals over AED 60,000 crossing through cargo, mail or shipments, cargo being declared through the official customs systems.
AED 60,000
Primary lawAmount not confirmed
- Federal Decree-Law 10/2025; CBUAE Regulation on the Declaration of Currencies, BNIs, and Precious Metals and Stones (OG 703, 31 May 2021), FDL 10/2025 Art. 10 (duty to disclose, per the disclosure system issued by the ICP with the Central Bank), Art. 41(3) (regulations under FDL 20/2018 remain effective insofar as not conflicting), Art. 34 (penalty)
  “Any person entering into or departing from the State shall be under the obligation to make a disclosure whenever they carry currencies, bearer negotiable instruments, precious metals, or valuable stones, in accordance with the disclosure system issued by the Federal Authority for Identity, Citizenship, Customs and Port Security, in coordination with the Central Bank”
Dealers in precious metals and stones are DNFBPs for any single cash transaction, or linked transactions, of AED 55,000 or more (CR 134/2025 Art. 3 item 3), and keep records for at least 5 years (Art. 25). The DPMSR report, including for dealings with companies of AED 55,000 or more paid in cash or …
AED 55,000
Primary law
- Cabinet Resolution 134/2025; MoET Supplemental Guidance for DPMS 2026, CR 134 Art. 3(3), Art. 25(1); Guidance s.1.4.1
  “when carrying out any single cash transaction or several transactions that appear to be linked and whose value equals or exceeds fifty-five thousand dirhams (AED 55,000)”
Supply-chain entities and precious-metals dealers must have due-diligence management systems, identify and assess supply-chain risks and adopt a risk-management strategy (Decree Art. 1(A)); refiners must also appoint an independent third-party auditor and submit a due-diligence report (Art. 1(B)), u…
Primary law
- Ministerial Decree 68/2024; MoE Due Diligence Regulations v1 (2022), Decree Art. 1(A), 1(B), Art. 3 (penalties under the AML law)

Leg 4: Russia

Back in the origin country: the proceeds of the export

32
Receive payment through an authorised bank; the statutory repatriation duty (173-FZ art. 19(1)(1)) applies to rouble-priced contracts but not, under art. 19(8), to FX-priced gold contracts; foreign currency credited under the contract is subject to mandatory sale in the share set by the Government Commission (Decree 79 para 2)
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Issues
Receipt of export proceeds
Primary law
[inferred] Exemption of FX-priced gold contracts read from the absence of 7108 in the art. 19(8) list. [unconfirmed] The current mandatory-sale share is not in a legal act found. Western bank channels are largely closed by sanctions (OFAC FAQ 1029).
- Federal Law 173-FZ art. 19; Presidential Decrees 79 and 430, art. 19

Crossings between countries

Russia → Hong Kong SAR China Researched
Papers that cross: Refiner receipt: weighing and sampling record; Refiner assay of the incoming lot (metallurgical balance); 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); Bar list (serials, weights, fineness); Minfin conclusion (permissive document) approving an export-licence application (Order 10n from 1 Sep 2026); EAEU export licence issued by Minpromtorg (one-off or general); Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK; Calculation of the value of precious metals in the consignment; Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber; Export goods declaration (accepted and released by customs); Certificate of origin (general form) for non-EAEU destinations; Packing list; Air waybill
Hong Kong SAR China → United Arab Emirates Not researched
Papers that cross: Inbound air waybill; Hong Kong import declaration (Cap. 60E, lodged electronically within 14 days); CBNI advance electronic declaration (CDS) for cash moved as cargo; PBOC Gold and Gold Products Import/Export Permit (中国人民银行黄金及黄金制品进出口准许证); Hong Kong exporter's commercial invoice; Packing list; Outbound air waybill / cross-boundary transport document; Hong Kong export / re-export declaration (Cap. 60E, lodged within 14 days)