Kazakhstan [private export after NBK refusal] → South Africa (refine) → United Kingdom · Loco London OTC sale and settlement

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

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Kazakhstan (Doré bar - unstamped → 999.9 kilobar) ⟶ South Africa (999.9 kilobar → LBMA Good Delivery 400oz bar) ⟶ United Kingdom (LBMA Good Delivery 400oz bar)

Not researched: Kazakhstan → South Africa

Leg 1: Kazakhstan

Where the goods start

Doré bar - unstamped → 999.9 kilobar

1
Identify the customer and report purchases/sales of precious metals of 50,000,000 KZT or more (cash or non-cash) to the AFM; jewellery threshold 5,000,000 KZT; pawnshops 3,000,000 KZT
Who
Individual entrepreneur or company trading precious metals domestically
Issues
Report to the AFM on an operation subject to financial monitoring
Primary lawUnder review
- Law 191-IV, art. 4
2
Extract gold ore within the licensed plot under a mining licence
Who
Holder of a mining licence for solid minerals (industrial gold miner)
Needs
Mining licence for solid minerals
Form
Ore (in situ / run-of-mine) → Concentrate / black sand
Primary law
[unconfirmed] The held Subsoil Code text is the FAOLEX consolidation (Russian), older than the text in force; amendments made since then are not checked, because the official Adilet text is a wall.
- Code of the Republic of Kazakhstan on subsoil and subsoil use (articles in refs), Subsoil Code art. 202
  “По лицензии на добычу твердых полезных ископаемых ее обладатель имеет исключительное право пользоваться участком недр в целях проведения следующих операций”
- Code of the Republic of Kazakhstan on subsoil and subsoil use (articles in refs), art. 202(1)
  “добыча твердых полезных ископаемых (извлечение)”
3
Process on site (gravity, leaching, smelting) into doré, cathode metal or zinc precipitate; the mining licence covers use of the subsoil space for mining and mine-processing production, and mining includes leaching and the collection, storage, crushing and sorting of the extracted minerals on the mining plot
Who
Holder of a mining licence for solid minerals (industrial gold miner)
Form
Concentrate / black sand → Doré bar - unstamped
Primary law
Technology is industry practice. [unconfirmed] The held Subsoil Code text is the FAOLEX consolidation (Russian), older than the text in force; amendments made since then are not checked, because the official Adilet text is a wall.
- Code of the Republic of Kazakhstan on subsoil and subsoil use (articles in refs), Subsoil Code art. 202
  “По лицензии на добычу твердых полезных ископаемых ее обладатель имеет исключительное право пользоваться участком недр в целях проведения следующих операций”
- Code of the Republic of Kazakhstan on subsoil and subsoil use (articles in refs), art. 202(2)
  “использование пространства недр в целях проведения горных работ, размещения горнодобывающего и (или) горно-перерабатывающего производств”
- Code of the Republic of Kazakhstan on subsoil and subsoil use (articles in refs), art. 202, definition of mining
  “химическому и бактериальному выщелачиванию”
4
Contract with a producer on the authorised body's list for refining (tolling) or sale; mined gold and raw materials must go to Kazakh producers for processing/refining (nuggets not subject to refining excepted)
Who
Holder of a mining licence for solid minerals (industrial gold miner)
Issues
Refining (tolling) or purchase agreement with a listed Kazakh refiner
Primary lawUnder review
- Law 444-V 'On precious metals and precious stones', art. 8(1)
5
Record the transfer of ownership (or pledge) of raw materials before refining under the authorised body's rules on recording such transactions
Who
Holder of a mining licence for solid minerals (industrial gold miner)
Issues
Record of a transaction transferring ownership of (or pledging) mineral raw materials before refining
Primary lawUnder review
Only art. 4(10-1) delegating the rules was read; how and by whom the record is made is not confirmed.
- Law 444-V 'On precious metals and precious stones', art. 4(10-1)
6
Move doré under secure escort from the mine to the refinery
Who
Secure carrier (cash-in-transit / valuables logistics)
Industry practice
7
Weigh, sample and assay the incoming doré; agree the outturn
Who
Subject of production of precious metals on the authorised body's list (refinery)
Industry practice
8
Refine to 99.99% gold (standard 12 kg bars, 100 g-1 kg bars or granules); LBMA Good Delivery-listed refiners stamp bars of international standard
Who
Subject of production of precious metals on the authorised body's list (refinery)
Issues
Refiner's quality certificate / bar list for refined gold (999.9)
Form
Doré bar - unstamped → 999.9 kilobar
Industry practiceUnder review
- Law 444-V 'On precious metals and precious stones', art. 8(1)
9
Sign the foreign-trade contract with a specification (full assortment, quantity, mass) and issue the invoice or value-confirmation document with the precious-metal content calculation
Who
Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)
Issues
Foreign-trade contract with specification (submitted for licence and state control act); Invoice or value-confirmation document
Primary lawUnder review
- Order of the Minister of Industry and Construction No. 375 of 29.10.2024, para. 18
10
Obtain the document confirming the NBK's refusal to exercise the priority right on the refined gold
Who
Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)
Needs
Document confirming NBK refusal to exercise the priority right on refined gold
Issues
Document confirming NBK refusal to exercise the priority right on refined gold
Primary lawUnder review
- Order of the Minister of Industry and Construction No. 375 of 29.10.2024, para. 19
11
Obtain a laboratory document on precious-metal content from an accredited testing laboratory
Who
Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)
Issues
Accredited testing laboratory document on precious-metal content
Primary lawUnder review
- Order of the Minister of Industry and Construction No. 375 of 29.10.2024, para. 18
12
Obtain an export licence for the foreign-trade contract from the authorised body
Who
Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)
Needs
Notification of start/cessation of activity with precious metals (import/export); Foreign-trade contract with specification (submitted for licence and state control act)
Issues
Export licence for precious metals / raw materials (per foreign-trade contract)
Primary lawUnder review
Issuing procedure and EAEU basis (EEC Decision 30) not read.
- Order of the Minister of Industry and Construction No. 375 of 29.10.2024, paras 17-18
13
Assign a registration number to the currency contract where it meets the NBK monitoring criteria
Who
Kazakh commercial bank servicing the currency contract
Issues
Registration (accounting) number of a currency contract
Primary lawUnder review
Threshold is set in NBK rules, not read.
- Law 167-VI, arts 13-14
14
Apply through the e-government portal for the act of state control, presenting the whole batch and the licence, contract, specification, invoice, content calculation, notification, ownership documents and laboratory document
Who
Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)
Needs
Export licence for precious metals / raw materials (per foreign-trade contract); Foreign-trade contract with specification (submitted for licence and state control act); Invoice or value-confirmation document; Accredited testing laboratory document on precious-metal content; Notification of start/cessation of activity with precious metals (import/export); Document confirming NBK refusal to exercise the priority right on refined gold
Primary lawUnder review
- Order of the Minister of Industry and Construction No. 375 of 29.10.2024, paras 9, 18, 19, 21
15
Carry out control testing of samples when the content documents do not match the contract or technical documentation
Who
National Bank of Kazakhstan (state buyer, priority right)
Issues
NBK control test result on samples (Cash Operations and Valuables Storage Centre)
Primary lawUnder review
- Law 444-V 'On precious metals and precious stones', art. 7(1)
16
Issue the act of state control for the shipment (content, source, market valuation, compliance with contract); refuse if documents incomplete or price below metal value
Who
Authorised body for precious metals (Ministry of Industry and Construction)
Issues
Act of state control of precious metals, issued per shipment
Primary lawUnder review
- Order of the Minister of Industry and Construction No. 375 of 29.10.2024, para. 10
17
Obtain a certificate of origin if the buyer or destination requires it
Who
Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)
Issues
Certificate of origin (general form) for exported goods
Unverified
Not researched; included because hand-off checks may ask for it.
18
Lodge the export goods declaration with the state control act and export licence; customs releases the goods
Who
Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)
Needs
Act of state control of precious metals, issued per shipment; Export licence for precious metals / raw materials (per foreign-trade contract)
Issues
EAEU goods declaration for export (ДТ)
Primary lawUnder review
- Order of the Minister of Industry and Construction No. 375 of 29.10.2024, para. 17
19
Ship the bars to the foreign buyer
Who
Secure carrier (cash-in-transit / valuables logistics)
Needs
EAEU goods declaration for export (ДТ)
Issues
Air waybill for export shipment
Industry practiceUnder review
Order 375 governs release; carriage arrangements are industry practice.

Taxes and fees

Export customs duty on gold
None identified
UnverifiedAmount not confirmed
Mineral extraction tax on gold (Tax Code 2017)
7.5%
SecondaryAmount not confirmed
- Tax Code 120-VI (2017)
Mineral extraction tax (НДПИ) on gold, price-banded
7.5% at average price up to USD 2,800/oz; 8% to 3,000; 8.5% to 3,200; 9% to 3,400; 9.5% to 3,600; 10% to 3,800; 11% above 3,800 Gold extracted (all forms)
Primary lawUnder reviewAmount not confirmed
- Tax Code 214-VIII (18.07.2025), arts 780-781

Controls

Cross-border carriage of cash and goods by individuals follows the EAEU Customs Code (written declaration above USD 10,000 cash equivalent).
USD 10,000 (cash)
UnverifiedAmount not confirmed
On import from or export to non-EAEU countries, if documents on precious-metal content do not match the contract, samples are control-tested by the NBK.
Primary lawUnder review
- Law 444-V 'On precious metals and precious stones', art. 7(1); art. 5(3)
Resident exporters must repatriate proceeds under export currency contracts within the contract term; contracts meeting NBK criteria receive registration numbers. No mandatory sale of FX proceeds found in the law.
Primary lawUnder review
- Law 167-VI, arts 9, 13-14
Dealers in precious metals and stones are subjects of financial monitoring; purchase/sale of precious metals and stones of 50,000,000 KZT or more is reportable; jewellery 5,000,000 KZT; pawnshop operations 3,000,000 KZT. Retail jewellery purchases by individuals up to 500,000 KZT have simplified CDD…
50,000,000 KZT (precious metals)
Primary lawUnder reviewAmount not confirmed
- Law 191-IV, arts 3, 4, 5
Export of precious metals and raw materials to non-EAEU countries needs an export licence and a per-shipment act of state control from the authorised body; refined gold also needs proof of NBK refusal.
Primary lawUnder review
- Order of the Minister of Industry and Construction No. 375 of 29.10.2024, paras 10, 17-19
Mined gold and raw materials (doré, cathode metal, zinc precipitate, scrap, ores and concentrates) must go to Kazakh precious-metal producers for processing/refining. Export of raw materials requires refusals from all listed producers and a conclusion that domestic extraction is not feasible.
Primary lawUnder review
- Law 444-V 'On precious metals and precious stones'; Order of the Minister of Industry and Construction No. 375 of 29.10.2024, art. 8(1)-(2); Order 375 para. 20
The state has a priority right to buy refined gold for NBK assets. Producers and owners of refined gold after processing must sell refined gold, produced in Kazakhstan or abroad, to the NBK first, within half-yearly limits set from their forecasts; only gold the NBK refuses may go to third parties. …
Primary lawUnder review
- Law 444-V 'On precious metals and precious stones', art. 9
Individual entrepreneurs and companies must notify the authorised body before starting import/export of refined and other precious metals and raw materials (the NBK is exempt).
Primary lawUnder review
- Law 444-V 'On precious metals and precious stones', art. 7(4)

Leg 2: South Africa

On the way

999.9 kilobar → LBMA Good Delivery 400oz bar

20
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 practice
Rand Refinery states KYC and conflict-free sourcing policies; its depositor requirements and the RGG text were not read in this pass.
21
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 law
- Precious Metals Act; Precious Metals Regulations, s.10(1)-(2); regs 21-22
22
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.
23
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.”
24
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 law
- Precious Metals Act, s.10(3), s.13; reg 26
25
Submit specimens of the imported metal to the SAPS Forensic Science Laboratory
Who
Refining-licence holder (refinery)
Issues
Specimen submission (importer)
Primary law
- Precious 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.”
26
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
27
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 law
- Precious Metals Act; Precious Metals Regulations, s.7(1), 7(5); reg 28 (minted bars)
28
Record receipts and outputs in the PMR2 register within 24 hours
Who
Refining-licence holder (refinery)
Issues
PMR2 refinery register entry / quarterly copy
Primary law
- Precious Metals Act, s.15(1); reg 33
29
Publish annual responsible-gold / LBMA compliance report
Who
Refining-licence holder (refinery)
Issues
Refiner responsible gold / LBMA compliance report
Industry practice
30
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 practice
Rand Refinery lists vault and logistics services; account terms not seen.
31
Obtain Treasury permission and, for any unwrought or semi-fabricated output, SADPMR export approval; file the customs export declaration for the refined bars
Who
Refining-licence holder (refinery)
Needs
Refiner bar list for bars produced; SADPMR export approval for gold (PMA s.12); National Treasury approval to export gold (Exchange Control Reg 3; PMA s.12(1))
Issues
SARS customs declaration / bill of entry for export
Primary law
[unconfirmed] No SADPMR or SARB text specific to re-export of refined foreign-origin gold was found; Reg 3, Manual C(B) and PMA s.12 are applied as written.
- Exchange Control Regulations; Precious Metals Act, Reg 3; s.12(1)
32
Ship the bars to the depositor's buyer or vault abroad
Who
Secure carrier of precious metal
Issues
Waybill, refinery/exporter to port of export; Air waybill, Johannesburg to destination
Primary law
- Precious Metals Act, s.13; reg 26

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 confirmed
- Value-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 confirmed
- Value-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 confirmed
- Precious 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 confirmed
- FICA 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 law
- FICA 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 law
- MPRDA 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 guidance
- Exchange 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 law
- Precious 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 law
- Precious 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 law
- Exchange 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 law
- Precious 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 law
- Precious 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 law
- Precious 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 law
- Precious 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 practice
- LBMA Responsible Gold Guidance
Unwrought or semi-fabricated gold may not be carried outside a mine or refinery boundary without the prescribed waybill.
Primary law
- Precious Metals Act; Precious Metals Regulations, s.13; reg 26

Leg 3: United Kingdom

Where the goods arrive

33
Apply customer due diligence to the foreign seller before buying (identity, beneficial owner, purpose, risk assessment, sanctions/PEP screening)
Who
Bullion dealer / trader (importer of record, usually an LBMA member)
Issues
Supplier KYC pack received by the UK buyer; MLR customer due diligence file
Primary law
[unconfirmed] Whether a non-bank wholesale bullion trader paid by wire is within the MLR at all (e.g. as a financial institution under reg 10) - consolidated MLR not held. [not-read] Reg 27 quoted via WebFetch; MLR not held.
- Money Laundering Regulations 2017, reg 27
34
Establish that the gold is not Russian-origin gold exported from Russia on or after 21 Jul 2022, not relevant processed gold incorporating such gold, and not Russian gold jewellery exported on or after 29 Oct 2022; check where the goods were originally consigned or exported from; if Russian origin is possible, apply to DBT's Import Sanctions Team for a licence or contact it; declare document code 9022 (not subject to / exempt from sanctions) or 9011 (licence) on CDS and keep the evidence to produce on demand
Who
Bullion dealer / trader (importer of record, usually an LBMA member)
Needs
Export customs declaration accepted by the dispatching country's customs
Issues
Importer's Russia-sanctions origin evidence file
Primary law
[inferred] The guidance and tariff do not list specific evidence documents; the required kinds are this module's inference.
- Russia (Sanctions) (EU Exit) Regulations 2019 as amended by SI 2022/850 and SI 2022/1110, regs 46Z11, 46Z16B, 46Z16C
35
Fly the bars into the UK as valuable cargo (typically Heathrow) under an air waybill
Who
Secure valuables carrier
Issues
Air waybill, inbound valuables consignment
Unverified
UK valuables-cargo handling not researched in this pass.
36
Submit a full import declaration on CDS (procedure code, commodity code 7108 12 00 00 for unwrought gold, DUCR, consignor/consignee, value, licences; EORI); declare sanctions document code 9022 or 9011; claim the investment-gold VAT exemption with additional code VATE where the bars are 995+ of a weight accepted by the bullion markets
Who
Customs agent / declarant using CDS software
Needs
EORI number of importer/exporter; Importer's Russia-sanctions origin evidence file; Air waybill, inbound valuables consignment; Air waybill; Commercial invoice; Bar list (serials, weights, fineness)
Issues
CDS full import declaration
Official guidance
[conflict] gb.div-cpc-chief - VAT Notice 701/21 s.8.1 still gives CHIEF CPC 40 00 073; the tariff (28 Sep 2026) shows the exemption as additional code VATE. [not-read] The CDS procedure code and DE 1/10-1/11 entries for investment gold not read (UK Trade Tariff Vol. 3 listed in gb-fetch.tsv).
37
Account for import VAT: exempt for investment gold (additional code VATE); 20% standard rate (code 03020) on non-investment gold (dore, grain, scrap, sub-995 bars, non-qualifying coins); customs duty 0.00% (third-country rate on 7108 12, S.I. 2020/1430)
Who
Bullion dealer / trader (importer of record, usually an LBMA member)
Needs
CDS full import declaration
Official guidance
- VAT Act 1994 Sch 9 Group 15; VAT Notice 701/21, Notice s8.1, s10.7
38
Clear the goods (CDS message when cleared), or ask for supporting documents for a customs check; for 7108 the Russia/Belarus measures read "Import allowed after control"; HMRC enforces trade sanctions at the border
Who
HMRC (customs and VAT authority)
Needs
CDS full import declaration
Issues
CDS clearance notification (goods released)
Official guidance
39
Give the custodian written notice of the deposit (amount, Availability Date, and the carrier and packing for physical delivery, or the source account for book-entry); advise the vault manager of the vehicle registration and driver's identity
Who
Bullion dealer / trader (importer of record, usually an LBMA member)
Needs
CDS clearance notification (goods released)
Issues
Deposit notice to London custodian
Standard
- LPMCL Allocated Account Agreement; LBMA Good Delivery Rules, Allocated cl. 3.3 (Unallocated cl. 3.2); GD Rules Annex B s.2
40
Weigh the bars under the London weighing procedures (the receiving party may charge for weighing if not weighed by an Approved Weigher) and produce the machine-readable, dated weight list stating whether an Approved Weigher weighed the metal; a copy travels with the bars
Who
LBMA Approved Weigher
Issues
Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)
Standard
- LBMA Good Delivery Rules, Annex B
41
Receive bars on pallets; before crediting, verify compliance with the Rules and weigh them per LBMA practice against the notified amount; the vault manager may refuse bars not meeting Good Delivery standards and may ask LBMA to appoint independent inspectors
Who
London commercial vault / custodian (typically a clearing or custodian bank)
Needs
Deposit notice to London custodian; Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)
Standard
- LPMCL Allocated/Unallocated Account Agreements; LBMA Good Delivery Rules, Allocated cl. 3.1(b), 3.4, 3.5; Unallocated cl. 3.1(b), 3.3, 3.4; GD Rules 2.4 and Annex B
42
For bars of the six suspended Russian refiners: accept only bars produced while the refiner was listed and already in the loco London/Swiss markets before 7 Mar 2022; clearing banks attest conformity
Who
London commercial vault / custodian (typically a clearing or custodian bank)
Needs
Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)
Standard
Separately, UK law bans import of Russian gold exported from Russia on or after 21 Jul 2022. [unconfirmed] GD Rules 2026 s.1.4 says bars of a refiner moved to the Former List for sanctions reasons may lose Good Delivery status; LBMA's specific Russian-bars page keeps pre-7 Mar 2022 loco London/Swiss stocks as Good Delivery - the model follows the specific page.
- LBMA Good Delivery List suspension notice (7 Mar 2022)
43
Credit the client: an allocated account (specific bars, title stays with client, weight list issued) or an unallocated account (a metal debt claim on the custodian); statements at least annually
Who
London commercial vault / custodian (typically a clearing or custodian bank)
Needs
Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)
Issues
Allocated weight list (bar number, gross weight, fineness, fine weight, brand) or unallocated balance statement
Standard
- LPMCL Account Agreements, Allocated cl. 2.3, 7.3 and Schedule (bar numbers, purity, gross and fine weight, brand); Unallocated cl. 1.1, 2.3, 3.3
44
Central-bank channel: hold Good Delivery bars in an allocated account at the Bank of England (off the Bank's balance sheet)
Who
Bank of England (gold custodian)
Form
LBMA Good Delivery 400oz bar → Monetary gold (central bank reserve)
Official guidance
Monetary state applies when held as reserves by a monetary authority.
45
Report month-end holdings to LBMA (London vault data) and, from Dec 2026, aggregated vault data into the Gold Bar Integrity database (bar-level reporting planned from 2027)
Who
London commercial vault / custodian (typically a clearing or custodian bank)
Issues
Custodian holdings return to LBMA (London vault data / GBI)
Standard
46
Onboard the counterparty: MLR customer due diligence and sanctions representations in the account agreement
Who
LPMCL clearing member bank
Issues
MLR customer due diligence file
Primary law
[not-read] MLR reg 27 quoted via WebFetch; MLR not held.
- MLR 2017; LPMCL account agreements, MLR reg 27; LPMCL Allocated cl. 10 / Unallocated cl. 8
47
Agree the OTC trade (spot/forward) under the 1994 International Bullion Master Agreement (IBMA) or an ISDA Master Agreement with the 1997 ISDA Bullion Definitions; LBMA Members must comply with the Global Precious Metals Code
Who
Bullion dealer / trader (importer of record, usually an LBMA member)
Needs
MLR customer due diligence file
Issues
OTC bullion trade confirmation (IBMA 1994 / ISDA Bullion Definitions 1997)
Standard
48
Apply the VAT treatment: investment gold between LBMA members is zero-rated (TMO); gold held in the UK between central banks, or between a central bank and an LBM member, is zero-rated (VATA Sch 8 Group 10); investment gold between an LBMA member and a taxable non-member is standard-rated under the special accounting scheme (the buyer accounts for the VAT); to private individuals it is exempt; other investment gold is exempt unless the supplier has opted to tax; standard-rated gold (fine gold, grain, scrap, opted investment gold) between VAT-registered traders goes under the compulsory special accounting scheme
Who
Bullion dealer / trader (importer of record, usually an LBMA member)
Needs
OTC bullion trade confirmation (IBMA 1994 / ISDA Bullion Definitions 1997)
Official guidance
[conflict] gb.div-tmo-member-category. [not-read] TMO arts 3-7 and VATA s.55 not held; the member/non-member rule is from VGOLD1600 ("Supplies of investment gold between members and non-members who are taxable persons are now standard-rated") and Notice 701/21 ss. 11.2, 11.5.
- VAT (Terminal Markets) Order 1973; VATA 1994 s.55, Sch 8 Group 10, Sch 9 Group 15
49
Settle loco London: book transfer between unallocated accounts through LPMCL members (client instructions by 16:00, inter-member by 16:30 London), or transfer of specific allocated bars
Who
LPMCL clearing member bank
Needs
OTC bullion trade confirmation (IBMA 1994 / ISDA Bullion Definitions 1997); Allocated weight list (bar number, gross weight, fineness, fine weight, brand) or unallocated balance statement
Issues
Loco London settlement: transfer between unallocated accounts via LPMCL members, or allocated bar transfer
Standard
Cut-offs (client instructions until 4.00pm, LPMCL members until 4.30pm London time) confirmed in the held 2017 OTC Guide; the current web section not held.
50
Pay the cash leg against metal settlement
Who
LPMCL clearing member bank
Needs
Loco London settlement: transfer between unallocated accounts via LPMCL members, or allocated bar transfer
Issues
Cash-leg payment for the metal
Unverified
Cash-leg timing and DvP arrangements not documented in the sources read.
51
For exempt investment gold: issue an invoice with a unique number and the prescribed details for each sale over GBP 5,000 (or smaller sales once a customer passes GBP 10,000 in 12 months); keep the accounting and customer records (identity from one List 1 and one List 2 document) for at least 6 years; notify HMRC in writing within 28 days of the first exempt supply over GBP 5,000 or when supplies to one customer exceed GBP 10,000 in 12 months; failures attract a penalty normally of 17.5% of the transactions' value
Who
Bullion dealer / trader (importer of record, usually an LBMA member)
Needs
Loco London settlement: transfer between unallocated accounts via LPMCL members, or allocated bar transfer
Issues
Investment gold invoice (VAT tertiary legislation s.3 / VAT Regs reg 31A); Investment gold customer records and identity evidence; Notification to HMRC of exempt investment gold dealing (within 28 days)
Primary law
Tertiary legislation (force of law, held). [unconfirmed] The general 6-year retention and the 17.5% penalty are in Notice 701/21 ss. 7.7 and 9.4, outside the passages marked as having force of law.
- VAT Regulations 1995; VAT tertiary legislation (gold), reg 31A
52
Keep MLR records 5 years; nominated officer files a suspicious activity report where there is suspicion
Who
LPMCL clearing member bank
Needs
MLR customer due diligence file
Issues
Suspicious activity report to the National Crime Agency
Official guidance
MLR record-keeping regulation not held; 5 years from the end of the relationship or completion of the transaction per HMRC guidance.

Taxes and fees

Customs duty on gold (UK Global Tariff)
0.00% (third-country duty on 7108 12 00 00; preferential rates also 0.00%) HS 7108 12 00 00 non-monetary gold, other unwrought forms (read); 7108 13 and 7112 91 not held
Official guidanceAmount not confirmed
- Customs Tariff (Establishment) (EU Exit) Regulations 2020 (S.I. 2020/1430), as shown on the tariff
Import VAT on investment gold
Exempt Bars/wafers 995+ of a weight accepted by the bullion markets; qualifying coins
Official guidanceAmount not confirmed
- VAT Act 1994 Sch 9 Group 15; VAT Notice 701/21 s.8.1; UK tariff additional code VATE
Import VAT on non-investment gold
20% (standard rate; tariff code 03020) Doré, grain, scrap, bars below 995, non-qualifying coins
Official guidanceAmount not confirmed
- VAT Notice 701/21, s10.7
VAT exemption for supplies of investment gold (with option to tax)
Exempt Supplies of investment gold (incl. rights to it, unallocated gold, loans, swaps, forwards and futures; not options) and agents' services for them; not between an LBMA member and a taxable non-member (standard-rated, SAS)
Official guidanceAmount not confirmed
- VAT Act 1994 Sch 9 Group 15; VAT (Investment Gold) Order 1999
Special accounting scheme (reverse charge) for gold
20%, accounted for by the buyer Standard-rated B2B supplies between VAT-registered (or liable) persons: fine gold, gold grain, gold coins (not margin-scheme), gold-containing goods priced at no more than a negligible amount above the gold value, investment gold on which the option to tax is exercised or supplied between an LBMA member and a non-member, and treatment/processing services producing such gold (Notice 701/21 s.11.2)
Official guidanceAmount not confirmed
- VAT Act 1994 s.55 (named in VGOLD1700; statute not held)
Zero rate for London Bullion Market and central-bank gold transactions
0% Investment gold (incl. futures and options) between taxable LBMA members (TMO; Notice 701/9 s.3.2.4); gold, rights to or part interests in gold held in the UK between central banks or between a central bank and an LBM member (VATA Sch 8 Group 10; Notice 701/21 s.10.4). Not zero-rated: investment gold between an LBMA member and a taxable non-member (standard-rated, special accounting scheme); a futures contract between a member and a non-member that leads to physical delivery (Notice 701/9 s.3.3.2).
Official guidanceAmount not confirmed
- VAT (Terminal Markets) Order 1973 art. 2(2), (4) and arts 4-7; VATA 1994 s.50, Sch 8 Group 10
HMRC MLR registration and annual supervision fee
Not read
Official guidance

Controls

The UK tariff attaches to 7108 12 00 00 a "Restriction on entry into free circulation for Belarus" (from 30 Sep 2023; legal base SI 2023/616) and a "Restriction on export for Belarus" (legal base SI 2022/748): allowed with document code 9011 (DBT licence, GBSAN reference) or 9022 (not subject to / e…
Official guidance
- Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 as amended
A trader accepting or making a cash payment of GBP 10,000 or more for goods (single or linked) is a high value dealer: must register with HMRC first and apply CDD. Threshold changed from EUR 10,000 to GBP 10,000 with effect from 30 Jun 2026.
GBP 10,000 cash (EUR 10,000 before 30 Jun 2026)
Primary lawAmount not confirmed
- MLR 2017 as amended by SI 2026/621, regs 14, 27(3); SI 2026/621 reg 9
Regulated firms apply CDD on a business relationship, a transfer of funds over GBP 800, an occasional transaction of GBP 12,000+ (HVDs: cash GBP 10,000+), suspicion or doubt; EDD for PEPs, non-face-to-face and FATF call-for-action countries (reg 33 as amended 30 Jun 2026); keep records 5 years; nomi…
Occasional transactions GBP 12,000 (general); GBP 10,000 cash (HVD); transfer of funds GBP 800 (from 30 Jun 2026; previously 15,000 / 10,000 / 1,000 euros)
Primary lawAmount not confirmed
- MLR 2017, reg 27
The import into the United Kingdom of gold originating from Russia is prohibited where it was exported from Russia on or after the relevant day. The ban goes by origin, so it applies whichever country the gold is shipped from.
Primary law
- The Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022, inserting reg 46Z11 into SI 2019/855, reg 46Z11(1)
  “The import of gold originating from Russia is prohibited, where that gold has been exported from Russia on or after the relevant day.”
No Great Britain statute imposing CAHRA/OECD due diligence on gold importers was found. Responsible-sourcing duties in London come from the LBMA (RGG mandatory for Good Delivery refiners since 2012; annual audit; Incident Review Process) and the GBI country-of-origin reporting (monthly, mandatory fr…
Standard
- LBMA Responsible Gold Guidance / Good Delivery Rules
UK persons may not provide financial services for foreign exchange reserve and asset management to the Central Bank of Russia, the National Wealth Fund or the Russian Ministry of Finance (or persons owned, controlled or acting for them); the reserves include bullion such as gold - "it is prohibited …
Official guidance
- Russia (Sanctions) (EU Exit) Regulations 2019, reg 18A (as named in the statutory guidance)
Only Good Delivery bars settle loco London: 350-430 fine troy oz, minimum 995.0 fineness, marks = refiner stamp, assay mark, fineness, serial number (max 11 digits or characters), month and year of manufacture (MMYY, since Jan 2019); no laser engraving. Vault managers have complete discretion and an…
Standard
- LBMA Good Delivery Rules 2026; LPMCL account agreements, GD Rules 2.1.5, 2.1.7, 2.4
The Hallmarking Act 1973 regulates describing articles as gold; Schedule 1 Part II exempts "Any raw material (including any bar, plate, sheet, foil, rod, wire, strip or tube) or bullion" (para 7) and coins that are or were current coin of the UK or any other territory (para 3). Bullion bars and lega…
Primary law
- Hallmarking Act 1973
Dealers in exempt investment gold must identify customers (one List 1 and one List 2 document), issue invoices with prescribed details, keep records at least 6 years and notify HMRC within 28 days when an exempt supply first exceeds GBP 5,000 or supplies to one customer exceed GBP 10,000 in 12 month…
GBP 5,000 per supply / GBP 10,000 per customer per 12 months
Primary lawAmount not confirmed
- VAT Regulations 1995; VAT tertiary legislation, reg 31A
LBMA suspended six Russian refiners (Krastsvetmet, Novosibirsk, Uralelectromed, Moscow Special Alloys, Prioksky, Shyolkovsky) from the Good Delivery List on 7 Mar 2022; their bars made from that date are not Good Delivery; stocks already in loco London/Swiss before then remain Good Delivery.
Standard
- LBMA Good Delivery List
Import of gold originating in Russia that was exported from Russia on or after 21 Jul 2022 is prohibited (reg 46Z11); so are acquiring gold that originated in and is located in Russia with the intention that it enter the UK (46Z12), supplying or delivering gold that originated in Russia on or after …
none
Primary law
- Russia (Sanctions) (EU Exit) Regulations 2019 as amended by SI 2022/850, regs 46Z11-46Z16; Sch 3G
Import of relevant processed gold - gold processed (altered, transformed or otherwise operated on) in a third country that incorporates gold which on or after 21 Jul 2022 originated in and was exported from Russia - is prohibited (46Z16C), as is import of gold jewellery (Sch 3G Part 3) originating i…
Primary law
- SI 2022/1110 (Chapter 4JA), regs 46Z16B, 46Z16C, 46Z16D-46Z16I
All smuggled gold may be liable to forfeiture under the Customs and Excise Management Act 1979, even in the hands of an innocent buyer; HMRC advises buyers to check where the gold came from, whether it was declared at import with import VAT paid, and warning signs (below-market price, quick settleme…
Official guidance
- Customs and Excise Management Act 1979; VAT Notice 701/21 s.14

Leg 4: Kazakhstan

Back in the origin country: the proceeds of the export

53
Repatriate the proceeds to a Kazakh bank account within the term of the currency contract; the bank monitors the contract
Who
Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)
Issues
Receipt of export proceeds on the exporter's Kazakh bank account
Primary law
Threshold and exact deadline rules are in NBK export-import currency control rules (not read). No mandatory sale of FX proceeds found in the law.
- Law 167-VI, art. 9

Crossings between countries

Kazakhstan → South Africa Not researched
Papers that cross: Refiner's quality certificate / bar list for refined gold (999.9); Document confirming NBK refusal to exercise the priority right on refined gold; Accredited testing laboratory document on precious-metal content; Export licence for precious metals / raw materials (per foreign-trade contract); NBK control test result on samples (Cash Operations and Valuables Storage Centre); Act of state control of precious metals, issued per shipment; Certificate of origin (general form) for exported goods; EAEU goods declaration for export (ДТ); Air waybill for export shipment
South Africa → United Kingdom Researched
Papers that cross: SADPMR permit to import precious metals; Air waybill, origin to Johannesburg (OR Tambo); SARS import declaration for dore; Waybill, port of entry to refinery; Refiner outturn / assay report; Refiner bar list for bars produced; SARS customs declaration / bill of entry for export; Waybill, refinery/exporter to port of export; Air waybill, Johannesburg to destination