Switzerland (refine) → Hong Kong (China SAR) · Sale on HKGX or OTC, with payment and AML duties

Weigh-in, seal-check, drill/dip-sample, fire-assay (ASTM E1335/ISO 11426) the incoming 995 bar

Who

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

Needs

Refining/re-refining agreement, Swiss refiner; Refiner file on the Dubai supplier: identity, commercial-register extract, proof of lawful acquisition (export permit/declaration, mining licence where applicable), SECO embargo check, origin clarification (kept for the period the EMKV sets: zehn Jahren)

Issues

Refiner outturn/assay report (Switzerland); Purchase book: customer, ID proof, acceptance date, description and marking, weight on acceptance, weight after melting, completion

[unconfirmed] Weigh-in, seal check and ISO 11426 are not in the sources read; ASTM E1335-24 covers fire assay of bullion, and Valcambi describes fire assay of drillings from samples taken from the melt of the received material.

• Fire assay standard practice

Pay the Dubai counterparty for the imported bar once the Swiss refiner's own assay confirms fine content

Who

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

Needs

Refiner outturn/assay report (Switzerland)

Issues

Final invoice from the Dubai seller (against Swiss outturn assay); Settlement wire, Swiss refiner -> Dubai counterparty

• Refining/sale contract; SWIFT MT103

Wohlwill electrolytic re-refine to 999.9, or cast directly to LBMA Good Delivery 400oz spec (995 min) if already qualifying

Who

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

Needs

Refiner outturn/assay report (Switzerland)

Form

Pre-refined 995 bar (e.g. 'Dubai 995') → LBMA Good Delivery 400oz bar

[unconfirmed] Wohlwill electrolytic refining to 999.9 is industry practice not described in the Good Delivery Rules, which set only the bar specification (350-430 fine troy ounces, minimum fineness 995.0).

• LBMA Good Delivery Rules (bar spec, marking)

Stamp each bar with the melting-licence holder's stamp (Stempelzeichen); bars for resale are assayed by a control office or sworn trade assayer and marked with fineness and the assayer's mark; for LBMA Good Delivery bars also serial number, fineness to four figures and year

Who

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

Issues

Bar list (serials, weights, fineness)

Serial number and year are LBMA requirements, not Swiss law. The earlier wording "registered responsibility mark" was wrong for bars (that mark, EMKG Art. 9, applies to finished wares). EMKV marking articles (Arts. 169, 173) were read only as restated by the BAZG (Vorschriften Dec 2023, held); the EMKV text is not yet held.

• PMCA (EMKG, SR 941.31); BAZG R-247; LBMA Good Delivery Rules, EMKG Art. 31(1); R-247 s.3.4.1; LBMA GD Rules s.2.1.7

File annual LBMA RGG independent assurance report; and (if volume threshold met) CO 964j-l conflict-minerals public report

Who

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

Issues

LBMA Responsible Gold Guidance annual assurance report; CO 964j-l conflict-minerals due-diligence public report

[time-limited] RGG v9 applies until RGG v10 takes effect: implementation 1 Jan-31 Dec 2027, first v10 audits for the reporting year ending 31 Dec 2027 (consultation closed 10 Jul 2026).

• LBMA RGG v9; CO Art. 964j-964l

Screen the bars, buyer and destination against Swiss sanctions before release: no purchase, import, transit or related services (including brokerage and financing) for gold of Russian origin exported after 4 Aug 2022 or gold processed from it in third countries

Who

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

[transcription] Art. 14d paras 1-4 read in an unofficial third-party English translation (as at 22 Mar 2024, held in laws/); Annex 26 covers 7108, 7112 91 and ex 7118 90 gold coins; Annex 27 ex 7113 and ex 7114. [unconfirmed] The official consolidation is now Stand 21 Sep 2026 and was not read (the fetch tool truncates before Art. 14d); changes after March 2024 are not ruled out. The ordinance contains no explicit ban on selling gold to Russia; the export-side effect is through the services ban.

• Ordinance of 4 March 2022 on measures in connection with the situation in Ukraine (SR 946.231.176.72), Art. 14d

Release the bars from the refinery vault or free port against the owner's instruction and prepare the weight list (bar list), commercial invoice and packing list for the shipment

Who

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

Issues

Outbound weight list / bar list; Commercial invoice to the foreign buyer; Packing list

The weight list is sourced to LBMA Annex C; commercial invoice and packing list are standard export practice, not read in a Swiss source.

• LBMA Good Delivery Rules, Annex C (weight lists); Customs Act Arts. 62-66 (free ports)

Lodge the electronic export declaration in Passar (HS 7108; e-dec Export was usable only to end-2025); the declarant must make it binding and physically export the goods within 120 days of its acceptance in the IT system

Who

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

Issues

Passar export declaration (HS 7108)

R-10-10 (valid 1 Jan 2026) cites Art. 25-29 ZG and Art. 79-83 ZV for the declaration duty, says declarations are electronic in principle, and sets the 120-day limit from acceptance in the IT system. R-10-10 held and read in full on 2026-09-28; the Customs Act and Ordinance texts themselves were not read. R-10-10 has no gold-specific rule.

• Customs Act (ZG, SR 631.0); BAZG R-10-10, ZG Arts. 25-29 (as cited in R-10-10)

Receive the export assessment notice (Veranlagungsverfuegung Ausfuhr), the evidence that the goods were properly cleared for export

Who

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

Issues

Veranlagungsverfuegung Ausfuhr

R-10-10 cites Art. 38 and 69 ZG and Art. 92 ZV for the export assessment notice and says it is evidence of proper assessment and of export for VAT. R-10-10 held and read in full on 2026-09-28.

• Customs Act (ZG); BAZG R-10-10, ZG Arts. 38 and 69; ZV Art. 92 (as cited in R-10-10)

Treat the sale as a VAT-exempt export (supply of goods directly transported abroad) and keep the export assessment notice as evidence

Who

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

Needs

Veranlagungsverfuegung Ausfuhr

Art. 23(2) no. 1 read in the held MWSTG (Stand 1 Jan 2025, German wording current). Art. 23(3): direct export includes export into an open customs warehouse or a free port. Investment gold of at least 995 fineness is separately exempt with credit under Art. 23(2) no. 12 (see ch.tax-import-vat).

• Federal VAT Act (MWSTG, SR 641.20), Art. 23(2) no. 1

Hand the sealed consignment to a secure valuables carrier and fly it out (Zurich or Geneva) under an air waybill

Who

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

Issues

Air waybill (outbound)

Carrier practice. Cantonal licensing: in the Canton of Zurich "Sicherheitstransporte von Personen, Gütern und Wertsachen" require a licence under the Polizeigesetz, 9. Abschnitt (cantonal page, read by WebFetch 2026-09-28; PolG text not read). Geneva and other cantons not checked. No Swiss source read describes the outbound air leg for gold.

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

[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”

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

• Import and Export (Registration) Regulations (Cap. 60E), reg. 3(a)-(b); Cap. 60 s. 2 (transhipment cargo, article in transit)

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

[inferred] Vault intake practice is not documented in an official source; the clearing press release confirms designated vaults record deposits.

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)

• Import and Export (Registration) Regulations (Cap. 60E), regs 3, 4(1)-(2), 7, 8(1), (1AA), (4), 18

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

• Cap. 629, ss. 2, 4, 9, 11; Sch. 4

Hold bars in allocated storage and issue periodic weight lists to the owner

Who

Precious-metals vault operator

Issues

Allocated account weight list

[not-read] Private vault terms not researched; no statute governing private bullion vaults was found in the texts held.

Deposit eligible about-400-oz bars that meet international standards into a designated vault of the central clearing system; the central ledger credits the participant with unallocated, commingled gold

Who

Authorised institution (bank) dealing in bullion

Needs

Bar list (serials, weights, fineness)

Issues

Central clearing ledger entry (unallocated gold balance)

• Clearing Rulebook

Transfer gold under Delivery Connect into the SGE International Board designated vault in Hong Kong through the physical gold account the clearing company opened with the SGE, so that it can be traded on the SGE, and back again

Who

Precious metals central clearing company (government-owned)

Needs

Central clearing ledger entry (unallocated gold balance)

Issues

SGE International Board vault account record (Delivery Connect)

The press release says the HKPMCC "has applied to become an international member of the Shanghai Gold Exchange and opened a physical gold account"; r1 said it was already a member.

• Clearing Rulebook

Withdraw physical bars from a designated vault against the participant's ledger balance for delivery or export

Who

Authorised institution (bank) dealing in bullion

Needs

Central clearing ledger entry (unallocated gold balance)

Issues

Bar list (serials, weights, fineness)

• Clearing Rulebook

Agree price and terms: loco-London or loco-Hong Kong OTC off the LBMA Gold Price or dealer quotes (the HAU ticker, launched on Bloomberg on 7 July 2026, gives indicative loco-HK bid/offer); or trade on HKGX by open outcry or electronically

Who

Registered bullion dealer / trader (DPMS registrant)

Issues

Sale and Purchase Agreement (price clause); Price reference (LBMA Gold Price, or HAU ticker quotes for loco Hong Kong); HKGX trade record / transaction code

Before any specified cash transaction (cash of HK$120,000 or more, single or linked) with a customer, a Category B registrant identifies and verifies the customer and beneficial owner, verifies anyone acting for the customer, applies PEP and high-risk measures and keeps records at least 5 years. Only a Category B registrant may carry out such a transaction; cash paid only between two Category B registrants is excluded from CDD

Who

Registered bullion dealer / trader (DPMS registrant)

Needs

DPMS Category B registration certificate

Issues

Customer due diligence file (Category B, specified cash transaction)

• AMLO s. 5A and Sch. 2; C&ED Guideline for Category B registrants, s. 5A(5A)-(5B); s. 53ZUE(2); Sch. 2 ss. 2, 3(1)(b), 10, 15, 20

  “for a period of at least 5 years beginning on the date on which the transaction is completed”

A visiting non-Hong Kong dealer that completes a cash transaction of HK$120,000 or more files a cash transaction report (Form CED418) with C&ED within one day or before leaving, whichever is earlier

Who

Non-Hong Kong dealer (visiting)

Issues

Cash transaction report by a non-Hong Kong dealer (Form CED418)

• AMLO (Cap. 615) Part 5C, s. 53ZVK; Sch. 3J

Buyer pays by bank transfer (or ledger transfer through central clearing); seller issues the final invoice; title passes by vault transfer or clearing-ledger entry

Who

Authorised institution (bank) dealing in bullion

Needs

Sale and Purchase Agreement (price clause)

Issues

SWIFT MT103 payment confirmation (bank-to-bank, authenticated); Final invoice (against outturn assay); Settlement confirmation / custody account entry; Central clearing ledger entry (unallocated gold balance)

[inferred] Settlement mechanics for bilateral OTC outside central clearing are market practice.

Report any knowledge or suspicion that property is crime proceeds to JFIU through STREAMS 2 (applies to everyone, not only registrants); do not tip off

Who

Registered bullion dealer / trader (DPMS registrant)

Issues

Suspicious transaction report to JFIU (STREAMS 2)

• OSCO (Cap. 455), DTROP (Cap. 405), UNATMO (Cap. 575), Cap. 455 s. 25A(1), (5), (7); Cap. 405 s. 25A(1); Cap. 575 s. 12(1), (5)

  “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”

Identify contracting party and beneficial owner; assess source of wealth/funds for the specific bullion; sanctions/PEP screening

Who

Swiss bank (bullion buyer)

Issues

Bank KYC file (CDB 20): name, date of birth, nationality, domicile and ID for natural persons; company name, registered office and proof for entities; Form A - declaration of the beneficial owner of the assets; Form K - controlling persons with 25%+ of an operating entity (CDB 20 Art. 20-21)

Downgraded 2026-09-28 from primary-law: the provisions cited are CDB 20 (a self-regulatory agreement of the SBA, held and read for Arts. 4, 7, 20-21, 27-28); the AMLA itself was not read for this step. The SBA says the revised CDB will not be available until 1 Jan 2027 at the earliest. [unconfirmed] Source-of-wealth assessment and sanctions/PEP screening were not found in the CDB 20 text read. [time-limited] The GwG consolidation of 1 Oct 2026 amends the AMLA widely; effects not assessed.

• AMLA; SBA Agreement on due diligence (CDB 20), CDB 20 Art. 4 (identification; precious-metals trading and cash transactions over CHF 15,000 are separate cases), Art. 7 (data recorded), Art. 20-21 (controlling persons 25%+, Form K), Art. 27-28 (beneficial owner, Form A)

Seller presents bar list, refiner's assay certificate, chain-of-custody documentation, commercial invoice, proof of title

Who

Swiss bank (bullion buyer)

Issues

Commercial invoice from the seller to the bank (VAT law requires one only if the buyer asks for it: MWSTG Art. 26(1); contents Art. 26(2); the sale of investment gold is VAT-exempt: Art. 23(2) Ziff. 12)

A bar not from an LBMA Good-Delivery-listed refiner generally cannot be sold to a major bank without re-refining - this is market practice, not itself a statute Commercial invoice and delivery receipt are practice (no primary source); "proof of title" for allocated bars is the weight list plus the custody contract - no statutory title document found.

Verify bars against the bank's accepted-refiner list / Good Delivery List; settle loco Zurich or loco London, allocated or unallocated

Who

Swiss bank (bullion buyer)

Issues

Settlement confirmation / custody account entry; Allocated account weight list (specific bars = ownership) or unallocated account statement (contractual claim only)

Record the transaction and the clarifications made; retain the records for at least ten years after the end of the business relationship or completion of the transaction

Who

Swiss bank (bullion buyer)

The official fedlex consolidation of the GwG is now held on the server and the article was read there; this replaces the earlier reading on droit-bilingue.ch and fedlex by WebFetch. The ten-year retention is written in words in the law (zehn Jahren), so it is kept in words here and not as an amount: the verifier reads number words in English only.

• Anti-Money Laundering Act (AMLA/GwG) (articles in refs), GwG Art. 7 Abs. 1 (records of transactions and clarifications)

  “Der Finanzintermediär muss über die getätigten Transaktionen und über die nach diesem Gesetz erforderlichen Abklärungen Belege so erstellen, dass fachkundige Dritte sich ein zuverlässiges Urteil über die Transaktionen und Geschäftsbeziehungen sowie über die Einhaltung der Bestimmungen dieses Gesetzes bilden können.”

• Anti-Money Laundering Act (AMLA/GwG) (articles in refs), Art. 7 Abs. 3 (kept at least ten years)

  “Nach Beendigung der Geschäftsbeziehung oder nach Abschluss der Transaktion be- wahrt er die Belege mindestens während zehn Jahren auf.”

• Anti-Money Laundering Act (AMLA/GwG) (articles in refs), Art. 2 Abs. 2 Bst. a (banks are financial intermediaries)

  “Finanzintermediäre sind: a.10 die Banken nach Artikel 1a des Bankengesetzes”