Zimbabwe [state buyer/exporter (FGR) or gold dealing licensee] → United Arab Emirates → India (refine) → South Africa (refine) · Sale of refined gold and receipt of proceeds
Public law and official guidance, published as research. Not legal, tax or financial advice.
Ask the research
The route, leg by leg
Each step, tax and control as the research records it, with its legal basis and how sure the research is.
Zimbabwe (Doré bar - unstamped → Pre-refined 995 bar (e.g. 'Dubai 995')) ⟶ United Arab Emirates (Pre-refined 995 bar (e.g. 'Dubai 995')) ⟶ India (Pre-refined 995 bar (e.g. 'Dubai 995') → 999.9 kilobar) ⟶ South Africa (999.9 kilobar → LBMA Good Delivery 400oz bar)
Not researched: India → South Africa
Leg 1: Zimbabwe
Where the goods start
Doré bar - unstamped → Pre-refined 995 bar (e.g. 'Dubai 995')
- 1
Register as an exporter in CEPECS through the authorised dealer
- Who
- Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
- Issues
- CEPECS exporter registration
Official guidanceRBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.1
- 2
Obtain the Gold Export Certificate for the lot
- Who
- Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
- Issues
- Gold Export Certificate
Official guidance[unconfirmed] Issuer and form of the 'Gold Export Certificate' are stated in no text held (FX Guidelines, Gold Trade Act and Regulations, Exchange Control Regulations and General Order all read); requested (zw.gap-gec).
- 3
Prepare assays and a pro-forma invoice showing the quantity, price and total value of the gold
- Who
- Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
- Needs
- FGR bar list for the export lot
- Issues
- Assays supporting the RBZ export application; Pro-forma invoice: quantity, price and total value of gold to be exported (FXG 3.2.30)
Official guidanceRBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.30
- 4
Submit the export application on the RBZ Document Management System with the Gold Export Certificate, Gold Dealership Licence, assays and pro-forma invoice
- Who
- Authorised dealer bank
- Needs
- Gold Export Certificate; Gold dealing licence ('Gold Dealership Licence'); Assays supporting the RBZ export application; Pro-forma invoice: quantity, price and total value of gold to be exported (FXG 3.2.30); CEPECS exporter registration
Primary lawExchange Control Regulations SI 109/1996; RBZ Foreign Exchange Guidelines FXD5/2026, Regulations s.20(1)(e) (no export of gold unless authorised by an exchange control authority); Guidelines para 3.2.30 ('All exports of Gold require prior Reserve Bank approval')
- 5
Approve the gold export within 24 working hours and issue an approval reference number
- Who
- Reserve Bank of Zimbabwe
- Issues
- RBZ gold export approval (approval reference number on the Document Management System)
Official guidanceRBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.30
- 6
Raise the CEPECS Form CD1 quoting the RBZ approval reference
- Who
- Authorised dealer bank
- Needs
- RBZ gold export approval (approval reference number on the Document Management System)
- Issues
- CEPECS Form CD1 (exchange control export form)
Official guidanceRBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), paras 3.2.5, 3.2.30
- 7
Issue the commercial invoice to the foreign buyer/refiner (attached to the export entry)
- Who
- Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
- Issues
- Commercial invoice
Official guidanceZIMRA lists 'Suppliers' invoices' for the export entry; the pro-forma invoice goes to the RBZ (3.2.30). [blocked] ZIMRA page via WebFetch only.
- 8
Lodge the export bill of entry (Form 21) through a registered clearing agent in ASYCUDA World before the gold leaves, with the CEPECS Form CD1, the invoice and the RBZ approval; pay the clearance fee - 'No duties are payable on export'
- Who
- Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
- Needs
- CEPECS Form CD1 (exchange control export form); RBZ gold export approval (approval reference number on the Document Management System); Commercial invoice
- Issues
- Customs export bill of entry (Form 21, lodged in ASYCUDA World)
Primary law[blocked] The ZIMRA clearance page was read only through WebFetch. [unconfirmed] Any gold-specific customs examination is not described.
Customs and Excise Act [Chapter 23:02]; Customs and Excise (General) Regulations 2001, Act s.54(1), s.61; Regulations s.62(1)(a); Exchange Control Regulations s.21
- 9
Where the buyer or the importing country's customs requires one (e.g. the UAE import declaration, ae.st-18), obtain a certificate of origin from the Zimbabwe National Chamber of Commerce on its form: the exporter declares 'that all the goods are of ZIMBABWE ORIGIN' and the chamber certifies it; the form carries the invoice, consignee and destination, transport, tariff number, description, net weight and the bill of entry number
- Who
- Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
- Needs
- Commercial invoice; Customs export bill of entry (Form 21, lodged in ASYCUDA World)
- Issues
- ZNCC certificate of origin for the gold consignment
SecondaryZNCC's own form read in full (a chamber, not a regulator). [unconfirmed] Whether FGR or other gold exporters obtain one in practice, its fee and turnaround were not found (requested from ZNCC). [inferred] Treated as optional: no Zimbabwean export rule requires it. [blocked] ZIMRA origin page via WebFetch only.
Customs and Excise Act [Chapter 23:02]; Customs and Excise (General) Regulations 2001, Act s.89(1)(a) ('wholly grown or produced' test for unmanufactured goods); Regulations s.25 (certificates of origin for lower duty - imports)
- 10
An officer authorises loading by stamping the consignment note or air waybill; the airline accepts the sealed consignment as valuable cargo under the air waybill and the gold must leave Zimbabwe within ten days of the authority
- Who
- Secure logistics provider / airline
- Needs
- Customs export bill of entry (Form 21, lodged in ASYCUDA World)
- Issues
- Air waybill
Primary law[inferred] Air freight from Harare is assumed; no Zimbabwe source names the route or carriers.
Customs and Excise (General) Regulations 2001; Customs and Excise Act, Regulations s.63(1), (3); Act s.55(1)
Taxes and fees
Export duty and customs clearance fee
none on export ('No duties are payable on export'); clearance fee per Form 21
Official guidanceAmount not confirmedCustoms and Excise (General) Regulations 2001, s.62(1)(a)(ii); s.175 (clearance fee)
Gold dealing licence fee
US$200,000 per year
Primary lawAmount not confirmedGold Trade (Licence Fees) Notice 1978, Schedule 2, as replaced by SI 32 of 2023
Presumptive tax on small-scale miners
0% of the purchase price of precious metals Precious metals bought from small-scale miners
Primary lawAmount not confirmedFinance Act [Chapter 23:04] s.22C(1)(b) as substituted by Finance Act 2024 s.6, s.22C(1)(b)
Gold royalty, artisanal and small-scale miners
2% (reported, 2025-2026); previously 1% Gold sold by artisanal and small-scale miners
SecondaryAmount not confirmedMines and Minerals Act s.244-245; Finance Act [Chapter 23:04] Schedule to Chapter VII; Income Tax Act 37th Schedule, MMA ss.244-245; 37th Schedule paras 2-3, 7
Gold royalty, 'gold produced by other miners' (price-banded, from 1 January 2026)
3% (sold 'at a time when its price is US$1 200 per ounce'); 5% (above US$1,200 but below US$5,000 per ounce); 10% (above US$5,000 per ounce) 'Gold produced by other miners' (the Schedule item replaced by the Finance Act 2025; the item for small-scale miners is separate and not held)
Primary lawAmount not confirmedFinance Act 2025 s.61 (Schedule to Chapter VII of the Finance Act [Chapter 23:04]); Income Tax Act 37th Schedule, s.61; 37th Schedule paras 2, 3, 7
Gold royalty, large-scale producers (before Finance Act 2025)
3% below US$1,200/oz; 5% above US$1,200/oz
SecondaryAmount not confirmedImplicit cost: 10% ZiG payment to small-scale miners and FGR discount to spot
~5% below spot (best FGR tier) plus 10% of value paid in ZiG (ASM) / 30% (LSM)
SecondaryAmount not confirmed
Controls
Exporters surrender 30% of gross proceeds to the RBZ at the interbank rate and retain 70% indefinitely (retention cut from 75% to 70% in the February 2025 MPS); 50% surrender on overdue proceeds; proceeds due within 90 days.
30% of gross export receipts
Official guidanceAmount not confirmedExchange Control Regulations SI 109/1996; RBZ FX Guidelines FXD5/2026, Regulations ss.5, 35(1)(c); Guidelines paras 3.2.2, 3.2.3; Directive FXD5/2026 para 2
Gold Trade Act licensees and permit holders are 'precious metals dealers' (MLPC Act s.13): identify and verify customers who pay 'in currency equal to or exceeding fifteen thousand United States dollars' (s.15(2)(d)) and whenever ML/TF is suspected, and the beneficial owner (s.15(3)); EDD for PEPs (…
US$15,000 CDD threshold for occasional transactions
Primary lawAmount not confirmedMLPC Act [9:24]; FIU DPMS Guidance (2026), MLPC Act ss.13, 15(2)(d), 15(3), 20, 24, 30, 31; Guidance paras 155, 172
Authorised gold bars are FGR-produced 99.5% bars of gazetted weights and dimensions bearing the FGR hallmark; defacing, altering, counterfeiting or smelting them is an offence (level 14 fine or up to 15 years).
Primary lawGold Trade Act [Chapter 21:03] as amended by Finance Act 2025, ss.2, 3, 12A
A traveller may take out at most 'US$2,000 or its equivalent in any other currency, combination of currencies or gold coins' in foreign cash, and ZiG cash equivalent to US$2,000 (FX Guidelines 3.2.33-3.2.34). Personal-use gold articles in baggage are exempt from the export prohibition (Exchange Cont…
US$2,000
Official guidanceAmount not confirmedRBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), paras 3.2.33-3.2.34
All gold won must be delivered 'not later than the 10th of every month' to the holder of a gold dealing licence (GTA s.6(1)), who 'shall deal with such gold in accordance with directions issued to him by the Minister responsible for finance' (s.6(3)). Only licence or permit holders, location holders…
All gold, any quantity
Primary lawGold Trade Act [Chapter 21:03], ss.3(1), 4, 5, 6(1), 6(3)
Gold Trade Enforcement Unit (FGR staff plus police) may inspect mining locations and premises, examine documents and devices, and seize gold; obstruction is an offence.
Primary lawGold Trade Act [Chapter 21:03] Part IIIA, ss.22B-22E
Payment for gold delivered to refineries: ASGM not more than 90% foreign currency / not less than 10% ZiG; LSGM 70% / 30% (from 1 March 2026).
Official guidanceRBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.29
'No person shall dispatch by post any postal article containing gold unless he is authorized to do so by any regulation' (GTA s.10(1)); authorised: licence holders, permit holders, location holders or tributors and their employees or agents (GT Regulations reg 8); suspect articles may be detained an…
Primary lawGold Trade Act [Chapter 21:03]; Gold Trade Regulations 1978, s.10; reg 8
No person may export gold unless authorised by an exchange control authority (Exchange Control Regulations s.20(1)(e)); 'All exports of Gold require prior Reserve Bank approval', applied for by the authorised dealer on the Document Management System with 'The Gold Export Certificate', 'Gold Dealersh…
Primary lawExchange Control Regulations SI 109/1996; Exchange Control Act; RBZ FX Guidelines FXD5/2026, Regulations s.20(1)(e); Act s.5(4c); Guidelines para 3.2.30
“a fine of three times the value of the item”
'No person shall smelt or change the form of any manufactured article containing gold unless he has received the permission of the Minister' (GTA s.12(1)); fine up to level nine or two years (s.12(2)).
Primary lawGold Trade Act [Chapter 21:03], s.12
Contravening s.3(1): without special circumstances 'imprisonment for a period of not less than five years or more than ten years', not suspendable (s.3(3)(a), (4)); with special circumstances up to five years or a fine up to level nine or twice the value of the gold (s.3(3)(b)); the same for ss.4, 5…
Primary lawGold Trade Act [Chapter 21:03], ss.3(3)-(4), 24, 30
On 4 March 2024 the US ended the Zimbabwe sanctions programme and designated President Mnangagwa and 10 other individuals plus Sakunda Holdings, Fossil Agro and Fossil Contracting under Global Magnitsky, citing involvement in gold and diamond smuggling networks. FGR is not named. US persons must scr…
Official guidance
Leg 2: United Arab Emirates
On the way
- 11
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)
- 12
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 guidanceNo 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)
- 13
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 lawInvestment 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)
- 14
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)
- 15
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 guidanceDMCC: 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.
- 16
Obtain a Certificate of Origin from Dubai Chambers: a non-preferential certificate for UAE-origin goods (goods produced in the UAE by a licensed exporter; copy of the industrial licence and the factory's invoice) or a certificate for foreign goods re-exported
- Who
- DMCC importer / trader
- Needs
- Refiner outturn/assay report
- Issues
- UAE Certificate of Origin / re-export documentation (Dubai Chambers)
Primary lawUnresolved: whether refining doré into bars confers UAE origin - both can sit in HS 7108.12 and no gold-specific rule was found; CR 43/2022 Art. 4 also allows "specific manufacturing operations". India's Noida SEZ SOP treats gold bars sourced from the UAE as not UAE-originating (see ae-in). Fee AED 100, two hours (Dubai Chambers service page; the Resolution sets no amount). [summary][blocked] FL 11/2019 and CR 43/2022 read through WebFetch only (downloads Cloudflare-challenged).
Federal Law 11/2019; Cabinet Resolution 43/2022; Dubai Chambers Resolution 7/2024, FL 11/2019 Art. 4 (minimal operations do not confer origin), Art. 6 (issue of certificates; the Chamber issues certificates for re-exported foreign commodities); CR 43/2022 Art. 4 (last major operation, incl. "a change in the customs item or ... specific manufacturing operations"); DC Res. 7/2024 Art. 2 (types), Art. 3(a) (conditions), Art. 3(b) (UAE-origin certificate only for goods produced in the UAE by an exporter licensed by the Competent Entity), Art. 4 (electronic application), Art. 6 (valid six months), Art. 7 (register kept 3 years)
- 17
File Dubai Customs export/re-export declaration; VAT zero-rated on export
- Who
- DMCC importer / trader
- Needs
- UAE Certificate of Origin / re-export documentation (Dubai Chambers)
- Issues
- Dubai Customs export/re-export declaration
Primary lawFederal Decree-Law 8/2017 on VAT; VAT Executive Regulation; Cabinet Decision 127/2024; Dubai Customs Customer Guide v3.03, DL 8/2017 Art. 45(1) (exports zero-rated); ER Art. 30 (export within 90 days, with customs declaration and commercial evidence); CD 127/2024 Art. 2(2) (no reverse charge on zero-rated supplies); Customer Guide s.15.12.3 (FZ Transit Out; penalty 10% of value without proof of export), s.16 (proof of export by air)
- 18
Book air cargo as valuable/secure freight (specialist carrier), security clearance, sealed/inspected shipment at DXB/DWC
- Who
- Secure logistics provider (UAE/air legs)
- Needs
- Dubai Customs export/re-export declaration
- Issues
- Air waybill, Dubai -> Zurich/Geneva
Industry practiceCAR VII has nothing gold-specific; booking as valuable/secure freight with a specialist carrier is practice. [inferred] Road leg to the airport in Dubai needs a SIRA Money and Valuables Transport licence.
GCAA CAR Part VII Ed. 05; SIRA Resolution 1/2018, CAR VII 4.6.1 (security controls on cargo), 4.6.6 (operators accept cargo only with security controls confirmed), 4.6.7 (security status accompanies cargo); SIRA Res. Art. 3(a)(6)
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 confirmedDubai 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 lawCabinet 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 guidanceCabinet 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 confirmedFederal 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 confirmedFederal 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 lawCabinet 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 lawMinisterial Decree 68/2024; MoE Due Diligence Regulations v1 (2022), Decree Art. 1(A), 1(B), Art. 3 (penalties under the AML law)
Leg 3: India
On the way
Pre-refined 995 bar (e.g. 'Dubai 995') → 999.9 kilobar
- 19
Declare jewellery beyond the special allowance (40 g female / 20 g other passengers, residents or tourists of Indian origin abroad more than one year) and any gold other than ornaments electronically in CBD-I before the green channel, and pay duty (eligible passengers may import up to 1 kg of gold at the concessional rate of 45/2025 S. No. 194, duty in convertible foreign currency)
- Who
- International passenger
- Issues
- Baggage declaration
Primary lawBaggage Rules 2026 r.6 and Annexure-I; Customs Baggage (Declaration and Processing) Regulations 2026 reg. 3; 45/2025 S. No. 194, condition 23, r.6; reg. 3
- 20
Import dore as actual user under 45/2025 S. No. 192 (conditions 3 and 22: direct shipment from the producing country, bars of 5 kg or more, mining-company packing list and assay certificate, refining to 99.5% or more); file Bill of Entry; pay BCD 10% from 13 May 2026 (5% before) plus AIDC, and IGST 3%
- Who
- Domestic gold refinery (dore importer under actual-user condition)
- Needs
- Origin country's export authorisation for the gold (permit, licence or clearance issued by the mining or trade authority); Export customs declaration accepted by the dispatching country's customs; Assay certificate (fineness and fine weight); Packing list; Air waybill
- Issues
- Bill of Entry for gold dore (actual-user); Duty and IGST payment on dore
Primary law[unconfirmed] AIDC serial for dore not identified (see in.tax-dore-2026). The origin-country documents (export authorisation, export declaration) are what the exporting country issues; Indian law read here asks for the mining-company packing list and assay certificate.
45/2025-Customs S. No. 192, conditions 3 and 22, as amended by 15/2026; IGCR Rules 2022, TABLE I S. No. 192; condition 22
- 21
Refine dore to 995/999.9 bars and issue outturn assay
- Who
- Domestic gold refinery (dore importer under actual-user condition)
- Needs
- Bill of Entry for gold dore (actual-user)
- Issues
- Refinery outturn assay; List of refined bars produced
- Form
- Doré bar - stamped/exporter-sealed → 999.9 kilobar
UnverifiedNo Indian legal text prescribes the refinery process or outturn documents; industry-standard step. Condition 22(d) of 45/2025 requires refining into bars of 99.5% or more.
- 22
Sell refined bars to jewellers/dealers with GST invoice at 3%
- Who
- Domestic gold refinery (dore importer under actual-user condition)
- Issues
- GST invoice on sale of refined bars
Primary lawIGST rate (inter-State) 3% read; CGST/SGST rate notifications for intra-State sales not read.
- 23
Issue Advance Authorisation for gold (max 100 kg); first-time applicants get a physical facility inspection; further gold AAs only after 50% of the export obligation of earlier AAs is met
- Who
- DGFT (licensing authority)
- Issues
- Advance Authorisation (gold); Facility inspection report
Secondary[transcription] PN 11/2026-27 read only as reproduced by TaxGuru (DGFT blocked). The earlier note "PN amends FTP paras 1.03 and 2.04" was not seen in any text read and was removed.
DGFT Public Notice 11/2026-27 (notes under SIONs M-1 to M-8); FTP 2023 para 4.36, notes under SION M-1 to M-8
- 24
Import gold of fineness 0.995 or more duty-free (IGST payable) against the Advance Authorisation with actual-user condition, directly, from a nominated agency (HBP 4.84(c)), or through IIBX as a QJ notified on the AA route (only the ITC(HS) codes in the AA and only for its exports), and clear it on a Bill of Entry
- Who
- Jewellery manufacturer-exporter (Advance Authorisation holder, SEZ/EOU unit)
- Needs
- Advance Authorisation (gold); Refiner's certificate for the bars it produced (serials, fineness, weights, year)
- Issues
- Bill of Entry for gold imported against AA
Primary lawThe customs exemption notification for AA imports was not read; FTP/HBP held as issued 2023.
FTP 2023 para 4.36(a); HBP 4.84; IFSCA consolidated circular cls. 3(e), 18A-18B, FTP 4.36(a); IFSCA cl. 18B
- 25
Manufacture and export jewellery on a Shipping Bill against the export obligation
- Who
- Jewellery manufacturer-exporter (Advance Authorisation holder, SEZ/EOU unit)
- Needs
- Bill of Entry for gold imported against AA
- Issues
- Shipping Bill for jewellery export
Official guidanceShipping Bill procedure under the Customs Act not read (Act not held).
HBP 2023 para 4.84; FTP 2023 paras 4.36-4.37, HBP 4.84(b)
- 26
File fortnightly CA-certified performance reports to the Regional Authority (which reports monthly to DGFT HQ)
- Who
- Jewellery manufacturer-exporter (Advance Authorisation holder, SEZ/EOU unit)
- Issues
- Fortnightly AA performance report (CA-certified)
Secondary
Taxes and fees
Duty-free special allowance for jewellery (Baggage Rules 2026 r.6)
Duty-free jewellery up to 40 g (female passenger) or 20 g (other passengers) Residents or tourists of Indian origin residing abroad for more than one year, in bona fide baggage; gold or silver in any form other than ornaments is excluded from the general free allowance (Annexure-I item 5)
Primary lawAmount not confirmedBaggage Rules 2026, r.6; r.5 and Annexure-I item 5
India-UAE CEPA tariff rate quota for gold (22/2022-Customs TABLE III S. No. 12)
In-quota BCD 10% + AIDC 4% (14%) from 13 May 2026 (18/2026); 4% + 1% (5%) from 24 Jul 2024 (31/2024); 6.6% + 2.5% as notified in 2022 Gold of 71081100, 71081210, 71081290, 71081310, 71081390 (all goods) of UAE origin within the TRQ quantity: 200 tonnes from 1 Apr 2026 (09/2026); 180 tonnes FY 2025-26 (21/2025); 120 tonnes "other than Gold Dore Bar" in 2022
Primary lawAmount not confirmedNotification 22/2022-Customs TABLE III S. No. 12, conditions 1 and 2, as substituted/amended by 31/2024, 21/2025, 09/2026 and 18/2026
BCD and AIDC on other chapter 71 goods from 13 May 2026 (7107, 7109, 7110, 7111, 7112, 7118; findings; spent catalyst)
BCD 10% (45/2025 S. No. 202 as substituted and S. No. 203 findings, by 15/2026); AIDC: findings of gold or silver 5%, platinum findings 5.4% (15F), 7107 and 7109 5%, 7111 5.4%, 7118 5%, 7112 other than spent catalyst 5% (16/2026); spent catalyst or ash BCD 10% (S. No. 200A, to 31 Mar 2027), AIDC 4.35% (15E) Headings 7107, 7109, 7110, 7111, 7112, 7118
Primary lawAmount not confirmedCustoms duty on gold dore
5.35% combined (BCD 5% + AIDC 0.35%) Gold dore bars with gold content not over 95% imported by actual users for refining (45/2025 S. No. 192, conditions 3 and 22)
Primary lawAmount not confirmed30/2024 (BCD); 32/2024 (AIDC); from 1 Nov 2025 45/2025 S. No. 192
Customs duty on gold dore from 13 May 2026: BCD 10% + AIDC
BCD 10% + AIDC 4.35% (11/2021 Sl. No. 15B, gold dore bar) = 14.35% Gold dore bar with gold content not over 95% (45/2025 S. No. 192), subject to conditions 3 (IGCR Rules 2022) and 22 (see in.cr-refinery-au)
Primary lawAmount not confirmed45/2025-Customs S. No. 192 as amended by 15/2026; 11/2021 Sl. No. 15B (inserted by 03/2023, rate 4.35% set by 16/2026)
Customs duty on gold bars (BCD + AIDC), July 2022 - July 2024
15% (dore 14.35%) HS 7108 bars; dore
Official guidanceAmount not confirmedCustoms duty on gold bars: BCD 5% + AIDC 1% (24 Jul 2024 - 12 May 2026)
6% combined (BCD 5%, AIDC 1%, SWS exempt) Gold bars (HS 7108)
Primary lawAmount not confirmedNotification 30/2024-Customs (BCD, amending 50/2017; carried at 5% into 45/2025 S. No. 196 from 1 Nov 2025); 32/2024-Customs (AIDC Sl. No. 15D 1%)
Customs duty on gold bars from 13 May 2026: BCD 10% + AIDC 5% (SWS exempt)
15% combined (BCD 10%, AIDC 5%) All goods of heading 7108 other than dore (45/2025 TABLE I S. No. 196); silver 7106 likewise (S. No. 197)
Primary lawAmount not confirmed45/2025-Customs S. No. 196 as amended by 15/2026 (BCD "5%" -> "10%"); 11/2021-Customs Sl. No. 15D as amended by 16/2026 (AIDC "5%"); 11/2018-Customs Sl. No. 1 (SWS exemption includes 7108)
IGST on gold (Schedule IV, 3%)
3% Heading 7108 gold (Schedule IV S. No. 5) and 7113 jewellery (S. No. 10), among other chapter 71 goods
Primary lawAmount not confirmedNotification 9/2025-Integrated Tax (Rate), para 1(iv) and Schedule IV, Schedule IV S. Nos. 5 and 10
IGST exemption on gold imported by listed banks and agencies
IGST nil Gold or silver imported by the banks in List 13, gold by the banks in List 14 (incl. SBER Bank from 25 Jun 2025, domestic consumption only), gold/silver/platinum by the entities in List 15 (HHEC, MSTC, Diamond India) of 45/2025
Primary law45/2025-Customs TABLE I S. No. 198, column (5); Lists 13-15; 06/2026
Concessional duty on gold bars/coins brought by an eligible passenger
BCD 10% from 13 May 2026 (5% before); AIDC 4.35% (11/2021 Sl. No. 15C as substituted by 44/2025 and amended by 16/2026) Gold bars (non-tola) with engraved serial number and metric weight, gold coins of 99.5% or more, and other gold except studded ornaments, up to 1 kg per eligible passenger (Indian-origin passenger or passport holder after six months abroad), duty paid in convertible foreign currency (condition 23)
Primary lawAmount not confirmed45/2025-Customs S. No. 194 and condition 23, as amended by 15/2026; 11/2021 Sl. No. 15C (44/2025, 16/2026)
BIS hallmarking fee
Rs 45 per gold article, minimum Rs 200 per consignment, payable by the jeweller to the AHC; BIS levies Rs 4.50 per article (minimum Rs 20) from the AHC; applicable taxes extra
Primary lawAmount not confirmedBIS (Hallmarking) Regulations 2018, Schedule IV as substituted by the Amendment Regulations 2022, Schedule IV, paras 1(a)-(b)
Controls
No person may receive Rs 200000 or more in cash (in aggregate from a person in a day, in a single transaction, or for transactions relating to one event or occasion from a person); only account payee cheque or draft, ECS through a bank account or prescribed electronic modes. Penalty equal to the sum…
Rs 200000
Primary lawAmount not confirmedIncome-tax Act, 2025, ss.186, 451
Gold Advance Authorisations capped at 100 kg; physical inspection for first-time applicants; next AA only after 50% of prior export obligation; fortnightly CA-certified reporting.
100 kg per AA
SecondaryAmount not confirmedPassengers carrying dutiable or prohibited goods must declare their accompanied baggage electronically in Customs Baggage Declaration CBD-I, with supporting documents, before entering the green channel; gold or silver other than ornaments is outside the free allowances.
Primary lawCustoms Baggage (Declaration and Processing) Regulations 2026; Baggage Rules 2026, reg. 3(1); r.5 and Annexure-I item 5
Trade credit (supplier's or buyer's credit incl. LC usance) for gold in any form max 90 days from shipment (C.11.2); QJs and TRQ holders may remit advances for IIBX purchases for eleven days, unused advance returned to the same AD bank within eleven days, Bill of Entry submitted to the remitting ban…
Official guidanceRBI Master Direction - Import of Goods and Services, paras C.7, C.11.1-C.11.4
Gold of heading 7108 is "Restricted": imported only by nominated banks and nominated agencies (consignment basis), and by IFSCA-notified Qualified Jewellers and valid India-UAE CEPA TRQ holders through IIBX under specific ITC(HS) codes (71081210, 71081290); all domestic sale of gold is against upfro…
Official guidanceITC(HS) Schedule I policy conditions (DGFT notifications 49/2015-2020, 35/2023, 08/2025-26); RBI Master Direction C.11.1(ii); 45/2025-Customs condition 22, RBI MD para C.11.1(ii)
Gold jewellery and artefacts may be sold only by BIS-registered jewellers and must bear a hallmark to IS 1417 (cl. 2); the Order applies only to the districts in its Annexure (cl. 1A) - 385 districts in 26 States/UTs since S.O. 2117(E) of 28 Apr 2026. Exempt (cl. 2(3)): articles for export to buyer …
Primary lawHallmarking Order 2020 as amended (S.O. 2481(E) 2021; S.O. 1594(E) 2022; S.O. 2117(E) 2026), cls. 1A, 2
IIBX accepts only bars from LBMA Good Delivery or UAE Good Delivery refiners (spot: LBMA 995 1 kg, UAEGD 999 100 g).
Official guidanceGold, silver and platinum jewellery (CTH 7113) moved from Free to Restricted from 1 Apr 2026, and articles, clad items and non-legal-tender coins from 2 Apr 2026; no transitional relief; exemptions for EOU/SEZ (no DTA sale), FTP export schemes and CEPA TRQ lines.
SecondaryDealers in precious metals and stones that engage in cash transactions with a customer of Rs 10 lakh or more (single or apparently linked) are persons carrying on a designated business or profession and so reporting entities; CBIC (DGA) is their regulator. They must register with FIU-IND (FINGate 2.…
Rs 10 lakh cash
Primary lawAmount not confirmedPMLA s.2(1)(sa)(iv), ss.11A, 12, 12AA; PMLR rr.3, 8, 9; G.S.R. 799(E) and 800(E) of 28 Dec 2020; DGA guidelines 2023, PMLA ss.2(1)(sa)(iv), 12, 12AA; PMLR r.8
CEPA preference on gold requires UAE origin: the product-specific rule for 710812 is "Certified UAE/ India good delivery gold bars in different denomination"; goods must be transported directly (art. 3.12) and origin proved under the Customs (Administration of Rules of Origin under Trade Agreements)…
Primary lawCEPA Annex 3B (PSR 710812), arts 3.12-3.14; Notification 22/2022-Customs proviso to para 1
Leg 4: South Africa
Where the goods arrive
999.9 kilobar → LBMA Good Delivery 400oz bar
- 27
Onboard the foreign depositor: KYC pack, mined-material questionnaire, refining agreement; apply LBMA Responsible Gold Guidance / OECD due diligence
- Who
- Refining-licence holder (refinery)
- Issues
- Refiner KYC pack on foreign depositor; KYC questionnaire for mined material; Refining agreement with depositor
Industry practiceRand Refinery states KYC and conflict-free sourcing policies; its depositor requirements and the RGG text were not read in this pass.
- 28
Hold a current SADPMR permit to import unwrought precious metal (Form PMI: quantity, fineness, form, value, period, ports, countries of origin, purpose)
- Who
- Refining-licence holder (refinery)
- Needs
- SADPMR refining licence; SAPS police clearance certificate
- Issues
- SADPMR permit to import precious metals
Primary lawPrecious Metals Act; Precious Metals Regulations, s.10(1)-(2); regs 21-22
- 29
Ship dore by air to Johannesburg with the origin country's export authorisation, export declaration and assay
- Who
- Foreign mine or exporter depositing doré
- Needs
- Origin country's export authorisation for the gold (permit, licence or clearance issued by the mining or trade authority); Export customs declaration accepted by the dispatching country's customs; Assay certificate (fineness and fine weight); Air waybill
- Issues
- Air waybill, origin to Johannesburg (OR Tambo)
Unverified[unconfirmed] PMA s.10(2)(b) requires the importer to declare and prove the origin of the metal in the permit application, and s.10(4) says the permit states the origin; which origin-country documents must accompany each shipment is not stated in any text read. The listed hand-off kinds are the model's route logic.
- 30
Enter the doré for customs with SARS on a bill of entry for import (the metal must be duly entered for customs under reg 21(4)(b)); entry may be refused if the Regulator considers it of dubious origin or incorrectly declared (reg 21(5))
- Who
- Refining-licence holder (refinery)
- Needs
- SADPMR permit to import precious metals; Air waybill, origin to Johannesburg (OR Tambo)
- Issues
- SARS import declaration for dore
Primary law[not-read] Customs and Excise Act procedure, tariff heading 7108 and import VAT on doré not read (Act not held). Manual C(G): gold import applications are referred to SADPMR.
Precious Metals Regulations; Customs and Excise Act 1964, reg 21(4)(b), 21(5)
“A precious metal may be refused entry into the South Africa if - (a) that precious metal is in the opinion of the Regulator of dubious origin; or (b) that precious metal has been incorrectly described or declared.”
- 31
Carry the dore from the airport to the refinery with the reg 26 waybill; SADPMR or SAPS may inspect imported metal
- Who
- Secure carrier of precious metal
- Issues
- Waybill, port of entry to refinery
Primary lawPrecious Metals Act, s.10(3), s.13; reg 26
- 32
Submit specimens of the imported metal to the SAPS Forensic Science Laboratory
- Who
- Refining-licence holder (refinery)
- Issues
- Specimen submission (importer)
Primary lawPrecious Metals Act, s.22(1)
“Any producer or any person who imports precious metal must submit to the Forensic Science Laboratory of the South African Police Service such specimens of any precious metals produced or imported by him or her as may be prescribed.”
- 33
Weigh, melt, sample and assay each lot on receipt; issue outturn (final assay and fine weight) to the depositor
- Who
- Refining-licence holder (refinery)
- Needs
- Refining agreement with depositor
- Issues
- Refiner outturn / assay report
Industry practice - 34
Refine at the licensed premises and cast 400 oz Good Delivery bars, kilobars (995-999.9), minted bars (10/50/100 g, 999.9) or grain
- Who
- Refining-licence holder (refinery)
- Issues
- Refiner bar list for bars produced
- Form
- Doré bar - unstamped → LBMA Good Delivery 400oz bar
Primary lawPrecious Metals Act; Precious Metals Regulations, s.7(1), 7(5); reg 28 (minted bars)
- 35
Record receipts and outputs in the PMR2 register within 24 hours
- Who
- Refining-licence holder (refinery)
- Issues
- PMR2 refinery register entry / quarterly copy
Primary lawPrecious Metals Act, s.15(1); reg 33
- 36
Publish annual responsible-gold / LBMA compliance report
- Who
- Refining-licence holder (refinery)
- Issues
- Refiner responsible gold / LBMA compliance report
Industry practice - 37
Credit fine gold to the depositor's metal account and hold the bars in the refinery vault pending sale or export
- Who
- Refining-licence holder (refinery)
- Needs
- Refiner outturn / assay report; Refiner bar list for bars produced
- Issues
- Metal account credit / settlement confirmation
Industry practiceRand Refinery lists vault and logistics services; account terms not seen.
- 38
Domestic sale: supply bars to a registered bank, the SARB or the SA Mint on a tax invoice, zero-rated only if the gold has not undergone a prior manufacturing process other than refining; otherwise 15% VAT
- Who
- Refining-licence holder (refinery)
- Issues
- Tax invoice to bank/SARB/Mint (zero-rated s.11(1)(f) or standard-rated)
Primary law[transcription] s.11(1)(f) wording from Lueven para [1]; VAT Act not held.
Value-Added Tax Act 1991, s.11(1)(f)
- 39
Export sale: the Authorised Dealer reports the export proceeds with the SARS customs declaration details (customs client number, unique consignment reference); FinSurv monitors receipt electronically
- Who
- Authorised dealer in foreign exchange (commercial bank)
- Needs
- SARS customs declaration / bill of entry for export
Official guidanceCurrency and Exchanges Manual, B.18(D)
- 40
Receive the full export proceeds not later than six months from the date of shipment (an Authorised Dealer may allow credit of up to 12 months), in foreign currency or rand from a non-resident account; offer the proceeds for sale to an Authorised Dealer within 30 days or deal with them under the CFC account rules
- Who
- Authorised dealer in foreign exchange (commercial bank)
- Needs
- SWIFT MT103 payment confirmation (bank-to-bank, authenticated)
- Issues
- Inbound payment of export proceeds
Official guidanceExchange Control Regulations; Currency and Exchanges Manual, Regs 6, 10, 11; B.18(B); C(F)(ii)
Taxes and fees
VAT on other domestic supplies of gold
15% Domestic gold supplies not zero-rated (e.g. recycled gold to banks; sales to traders)
Primary lawAmount not confirmedValue-Added Tax Act 1991
VAT zero-rating of gold supplied to the SARB, SA Mint and banks
0% Refined primary gold sold to the SARB, the SA Mint or a registered bank; recycled gold excluded (Lueven Metals, ZACC 23 June 2026)
Primary lawAmount not confirmedValue-Added Tax Act 1991, s.11(1)(f)
SADPMR licence and permit fees
Refining licence R20,000; beneficiation licence R5,000; jeweller's permit R500; import permit R1,000; certificate R1,000; special permit R5,000; appeal R500 (Annexure A, 2014) Applications and renewals
Primary lawAmount not confirmedPrecious Metals Regulations, Annexure A as substituted by GN R737 (GG 38014, 22 Sept 2014)
Controls
A business dealing in high-value goods (items valued in that business at R100,000 or more) is an accountable institution for transactions in which it receives payment of R100,000 or more (Schedule 1 item 20, from 19 Dec 2022): FIC registration (s.43B), risk management and compliance programme (s.42)…
Payment of R100,000 or more in a transaction; goods valued at R100,000 or more
Primary lawAmount not confirmedFICA 38 of 2001, Schedule 1 item 20; ss.20A-21H, 22-23, 28, 29, 42, 43B
A UN Security Council Chapter VII resolution identifying persons or entities 'has immediate effect for the purposes of this Act upon its adoption' (FICA s.26A(1)); the FIC Director must give notice of it (s.26A(3)). No person may, directly or indirectly, acquire, collect, use, possess or own propert…
Primary lawFICA 38 of 2001, ss.26A-26C
“A resolution adopted by the Security Council of the United Nations when acting under Chapter VII of the Charter of the United Nations, providing for financial sanctions which entail the identification of persons or entities against whom member states of the United Nations must take the actions specified in the resolution, has immediate effect for the purposes of this Act upon its adoption by the Security Council of the United Nations.”
Contravening s.5(4) (as enacted; replaced by s.5A from 7 June 2013), 19, 20(2) or 28 is an offence with a fine up to R100 000 or up to two years' imprisonment, or both (s.99(1)(a)); failing to notify the Minister before beneficiating abroad (s.26(3)) carries up to R500 000 for each day (s.99(1)(f)).
Primary lawMPRDA 2002, ss.98, 99(1)(a), 99(1)(f)
Goods exported for sale must be sold, and the full proceeds received, not later than six months from shipment; an Authorised Dealer may allow credit of up to 12 months. Proceeds must be offered for sale to an Authorised Dealer within 30 days or dealt with under the CFC rules. The Authorised Dealer r…
Official guidanceExchange Control Regulations; Currency and Exchanges Manual, Regs 6, 10, 11; B.18(B), (D)
No export of unwrought or semi-fabricated gold except with the approval of the National Treasury under the Exchange Control Regulations, granted with the Minister's concurrence (PMA s.12(1)); no gold may be exported without Treasury permission (Reg 3); applications to export gold in any form are ref…
Primary lawPrecious Metals Act; Exchange Control Regulations, PMA s.12(1); Reg 3
Producers submit gold specimens (nuggets, concentrate, dore) to the SAPS Forensic Science Laboratory every six months, and importers submit specimens of imported metal, building a forensic database to trace seized gold to its source.
Primary lawPrecious Metals Act; Precious Metals Regulations, s.22(1); reg 29
“Any producer or any person who imports precious metal must submit to the Forensic Science Laboratory of the South African Police Service such specimens of any precious metals produced or imported by him or her as may be prescribed.”
Except with Treasury permission, only authorised dealers may buy, borrow, sell or lend gold other than wrought gold (Reg 2). A resident entitled to sell gold must offer it for sale to the Treasury within 30 days unless exempted (Reg 5). Producers exempted by FinSurv from Reg 5 may sell their total o…
Primary lawExchange Control Regulations 1961, Regs 2, 5, 22
No import of unwrought or semi-fabricated precious metal without an SADPMR import permit (valid up to one year), issued after consulting the National Commissioner and the National Treasury, on documentary proof of origin (s.10(2)); the Regulator or SAPS may inspect and sample imported metal (s.10(3)…
Primary lawPrecious Metals Act, s.10, s.22(1)
“must state the origin of the precious metal in question, the purpose of the import”
Export approval requires projections of monthly production against sales showing the applicant contributes to local demand; approval only where provision has been made to meet local demand for beneficiation.
Primary lawPrecious Metals Regulations; Precious Metals Act, reg 23(3)(a) as substituted by GN R387
Minted gold bars must be 10, 50 or 100 g, of prescribed dimensions and at least 999.9 fine (reg 28, Annexure B Table 1); only approved manufacturers may make them and no more than 500 000 troy ounces a year may be manufactured (reg 27B).
Primary lawPrecious Metals Regulations, regs 27B, 28; Annexure B
“The quantity of minted bars that maybe manufactured in the Republic may not exceed 500 000 troy ounces in a calendar year”
Only a refining-licence holder, an authorised dealer, a producer (for gold it won or recovered), an SADPMR certificate holder, a holder of a special permit (metal not exceeding a prescribed mass, for scientific or beneficiation purposes or jewellery) or a beneficiation-licence holder may acquire, po…
Primary lawPrecious Metals Act, s.4(1), s.20(1)
Rand Refinery, as an LBMA Good Delivery refiner, applies KYC and conflict-free sourcing policies to depositors and publishes responsible-gold and LBMA compliance reports.
Industry practiceLBMA Responsible Gold Guidance
Unwrought or semi-fabricated gold may not be carried outside a mine or refinery boundary without the prescribed waybill.
Primary lawPrecious Metals Act; Precious Metals Regulations, s.13; reg 26
Leg 5: Zimbabwe
Back in the origin country: the proceeds of the export
- 41
Receive payment within three months (90 days) from export or when contractually due
- Who
- Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
- Issues
- Receipt of export proceeds
Primary lawExchange Control Regulations SI 109/1996; Exchange Control (General) Order SI 110/1996; RBZ FX Guidelines FXD5/2026, Regulations ss.5, 21; General Order s.13(2) ('within three months from the date of export'); Guidelines para 3.2.2
- 42
Pre-acquit the Form CD1 within 48 hours of receiving the proceeds
- Who
- Authorised dealer bank
- Issues
- CD1 acquittal (proceeds received)
Official guidanceRBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.7
- 43
Sell 30% of gross proceeds to the RBZ at the weighted-average willing-buyer willing-seller interbank rate; the exporter keeps 70% indefinitely (50% surrender where proceeds were overdue)
- Who
- Authorised dealer bank
- Issues
- Sale of 30% surrender portion to RBZ at the WBWS interbank rate
Official guidance[unconfirmed] Whether the general 30% surrender applies to FGR's own gold export proceeds is not stated. The February 2026 MPS (para 233) keeps 70% retention for all sectors 'with the exception of small-scale gold producers, whose retention shall be 90%'.
RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026); FXD5/2026, FXG para 3.2.3; FXD5 para 2.2
Crossings between countries
Zimbabwe → United Arab Emirates Researched
Papers that cross: CEPECS exporter registration; Gold Export Certificate; Assays supporting the RBZ export application; Pro-forma invoice: quantity, price and total value of gold to be exported (FXG 3.2.30); RBZ gold export approval (approval reference number on the Document Management System); CEPECS Form CD1 (exchange control export form); Customs export bill of entry (Form 21, lodged in ASYCUDA World); ZNCC certificate of origin for the gold consignment; Air waybill
United Arab Emirates → India Researched
Papers that cross: Dubai Customs declaration filed online (for goods entering a free zone: "FZ Transit In"); Disclosure of precious metals crossing the UAE border (cargo included); UAE Certificate of Origin / re-export documentation (Dubai Chambers); Dubai Customs export/re-export declaration; Air waybill, Dubai -> Zurich/Geneva
India → South Africa Not researched
Papers that cross: Baggage declaration; Bill of Entry for gold dore (actual-user); Duty and IGST payment on dore; Refinery outturn assay; List of refined bars produced; Advance Authorisation (gold); Facility inspection report; Bill of Entry for gold imported against AA; Shipping Bill for jewellery export
Paperwork gaps
ae.st-18 expects Packing list; the earlier legs don't model this paper
in.st-30 expects Packing list; the earlier legs don't model this paper
za.st-42 expects SWIFT MT103 payment confirmation (bank-to-bank, authenticated); the earlier legs don't model this paper