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.

Ask the research

Ask in your own words. The answer is the research itself: its records, word for word, with every source and how sure each one is.

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.

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

Leg 1: South Africa

Where the goods start

Doré bar - unstamped → LBMA Good Delivery 400oz bar

1
Apply to SADPMR on Form PMC for a certificate naming the unwrought gold to be acquired or disposed of and its source (police and tax clearance, business plan, fee R1,000)
Who
Precious-metals trader holding an SADPMR certificate
Needs
SAPS police clearance certificate; SARS tax compliance status / tax clearance
Issues
SADPMR certificate to acquire/dispose of unwrought precious metal
Primary law
- Precious Metals Act; Precious Metals Regulations, s.4(1)(d); regs 15-17
2
Buy the gold from the certificate holder after confirming the certificate; take and keep the certificate
Who
Authorised dealer in gold
Needs
SADPMR certificate to acquire/dispose of unwrought precious metal
Issues
Register kept by certificate holder (Form PMR 6) or authorised dealer (s.15(1))
Primary law
- Precious Metals Act, s.14(1)-(2)
3
Keep the transaction in the register immediately (date, parties, nature and mass, price)
Who
Authorised dealer in gold
Issues
Register kept by certificate holder (Form PMR 6) or authorised dealer (s.15(1))
Primary law
- Precious Metals Act, s.15(1)
  “immediately after the conclusion of each such transaction— (i) the date of the transaction; (ii) the names and addresses of the parties to the transaction; (iii) the nature and mass of the material ...”
4
Mine ore within the mining-right area after giving the landowner or lawful occupier at least 21 days' written notice (s.5A(c)) and, from 7 December 2014, holding an environmental authorisation (s.5A(a))
Who
Mining-right holder (industrial gold mine)
Needs
Mining right (MPRDA s.23)
Primary law
[inferred] 7 December 2014 start of s.5A(a) calculated (see za.law-nemaa-2008).
- MPRDA as amended by Act 49 of 2008, s.5A
5
Process ore on the mine (milling, leaching, electrowinning) and smelt to dore bars
Who
Mining-right holder (industrial gold mine)
Form
Ore (in situ / run-of-mine) → Doré bar - unstamped
Industry practice
Process description is general industry practice; Rand Refinery confirms it refines dore and concentrates.
6
Enter each production and disposal in the PMR1 producer register within 24 hours (date, parties, nature and mass, price)
Who
Mining-right holder (industrial gold mine)
Needs
SADPMR producer registration (PM REG1)
Issues
PMR1 producer register entry / quarterly copy
Primary law
- Precious Metals Act; Precious Metals Regulations, s.15(1); reg 33
  “immediately after the conclusion of each such transaction— (i) the date of the transaction; (ii) the names and addresses of the parties to the transaction; (iii) the nature and mass of the material ...”
7
Carry doré from the mine to the refinery with the prescribed waybill (sender, recipient, contact persons, owner, invoice numbers inside and outside the packaging)
Who
Secure carrier of precious metal
Issues
Waybill, mine to refinery
Primary law
- Precious Metals Act; Precious Metals Regulations, s.13; reg 26
8
Receive the dore from the producer after confirming the producer's right to dispose of it; record in the PMR2 register
Who
Refining-licence holder (refinery)
Needs
SADPMR refining licence; Waybill, mine to refinery
Issues
PMR2 refinery register entry / quarterly copy
Primary law
- Precious Metals Act, s.7(1), s.15(1), s.20(1)
9
Weigh, sample and fire-assay the dore; issue the outturn to the producer
Who
Refining-licence holder (refinery)
Issues
Refiner outturn / assay report
Industry practice
Rand Refinery advertises 24-hour assaying; outturn format not seen.
10
Mine within the permit area (max 5 ha) after environmental authorisation; recover gold by gravity/other processing and smelt to a button or bar
Who
Mining-permit holder (small-scale miner)
Needs
Mining permit (MPRDA s.27)
Form
Ore (in situ / run-of-mine) → Smelted button/bar
Primary law
- MPRDA as amended, s.5A, s.27
11
Record production in the PMR1 register
Who
Mining-permit holder (small-scale miner)
Needs
SADPMR producer registration (PM REG1)
Issues
PMR1 producer register entry / quarterly copy
Primary law
- Precious Metals Act, s.15(1); reg 33
12
Before buying: check the seller's mining permit (its right to dispose of the gold) and, where the buyer is a high-value goods dealer receiving payment of R100,000 or more, carry out FICA customer due diligence
Who
Precious-metals trader holding an SADPMR certificate
Needs
SADPMR certificate to acquire/dispose of unwrought precious metal
Issues
FICA customer due diligence record on seller
Primary law
- Precious Metals Act; FICA Schedule 1, PMA s.20(1)(b); FICA Sch.1 item 20, ss.20A-21H
13
Sell and deliver the gold to the buyer, carried with the reg 26 waybill; buyer records the purchase in its register
Who
Mining-permit holder (small-scale miner)
Issues
Waybill, mine to refinery; Register kept by certificate holder (Form PMR 6) or authorised dealer (s.15(1)); Seller's sale record naming buyer's licence/permit/certificate
Primary law
- Precious Metals Act, s.4(1), s.13, s.15(1)
14
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
15
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)
16
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
17
Publish annual responsible-gold / LBMA compliance report
Who
Refining-licence holder (refinery)
Issues
Refiner responsible gold / LBMA compliance report
Industry practice
18
Apply to SADPMR on Form PEA for export approval (contract extract, monthly production vs sales projections showing contribution to local demand, police clearance, proof of premises, fee)
Who
Holder of an SADPMR export approval
Needs
SAPS police clearance certificate
Issues
SADPMR export approval for gold (PMA s.12)
Primary law
[conflict] see za.div-pea-form-wording
- Precious Metals Act; Precious Metals Regulations, s.12(1); reg 23
19
National Treasury approval to export the gold (PMA s.12(1), Exchange Control Reg 3). Manual C(B) sends all applications to export gold in any form to SADPMR; producers exempted by FinSurv from Reg 5 may sell their total output to approved counterparties, with full proceeds received in South Africa (C(F))
Who
National Treasury (as approving authority)
Issues
National Treasury approval to export gold (Exchange Control Reg 3; PMA s.12(1))
Primary law
[unconfirmed] Whether Treasury issues a separate approval per consignment, or its approval is given through the SADPMR process and the FinSurv exemption, is not stated in any text read.
- Exchange Control Regulations 1961; Precious Metals Act, Reg 3; PMA s.12(1)
20
Sign the sale contract and fix the price against the LBMA Gold Price; issue commercial invoice
Who
Holder of an SADPMR export approval
Issues
LBMA Gold Price reference; Commercial invoice
Industry practice
Rand Refinery says it acts as agent for producers and sells through LBMA members; contract terms not seen.
21
File the SARS customs export declaration / bill of entry for export
Who
Holder of an SADPMR export approval
Needs
SADPMR export approval for gold (PMA s.12); National Treasury approval to export gold (Exchange Control Reg 3; PMA s.12(1)); Commercial invoice
Issues
SARS customs declaration / bill of entry for export
Primary law
[not-read] Customs and Excise Act procedure not held.
- Customs and Excise Act 1964; Precious Metals Regulations, reg 24(2) (as substituted by GN R387)
22
Carry the gold to OR Tambo with the reg 26 waybill; airline accepts as valuable cargo
Who
Secure carrier of precious metal
Needs
SARS customs declaration / bill of entry for export
Issues
Waybill, refinery/exporter to port of export; Air waybill, Johannesburg to destination
Primary law
- Precious Metals Act, s.13; reg 26
23
Keep a copy of the bill of entry for export with all supporting documents for each consignment for three years after export
Who
Holder of an SADPMR export approval
Needs
SARS customs declaration / bill of entry for export
Primary law
[conflict] Form PEA (2025) reprints reg 24(2) as 'The application must contain a copy of the Bill of Entry'; GN R387 (2008) substituted reg 24(2) with this three-year retention duty (za.div-pea-form-wording).
- Precious Metals Regulations, reg 24(2) as substituted by GN R387
  “The applicant must retain a copy of the Bill of Entry for Export issued in terms of the Customs and Excise Act, 1964 (Act 91 of 1964), together with all supporting documents in respect of each consignment of the precious metal exported in terms of the approval granted by the Minister for a period of three years after the date of export”

Taxes and fees

Mineral royalty - refined mineral resources (gold)
Y = 0.5 + [EBIT / (gross sales x 12.5)] x 100, minimum 0.5%, maximum 5% Transfer of gold won or recovered in South Africa; not imported dore
Primary lawAmount not confirmed
- Mineral and Petroleum Resources Royalty Act 2008, s.2, s.3(1), s.4(1), s.4(3)(a), s.6, Schedule 1
Mineral royalty - small business exemption
Exempt Small-scale producers
Primary lawAmount not confirmed
- Mineral and Petroleum Resources Royalty Act 2008, s.7
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 2: United Kingdom

Where the goods arrive

24
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
25
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
26
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.
27
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).
28
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
29
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
30
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
31
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
32
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
33
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)
34
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
35
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.
36
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
37
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
38
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
39
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
40
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.
41
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.
42
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
43
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 3: South Africa

Back in the origin country: the proceeds of the export

44
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)
45
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)
Official guidance
- Currency and Exchanges Manual, B.18(D)
46
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)
Issues
Inbound payment of export proceeds
Official guidance
- Exchange Control Regulations; Currency and Exchanges Manual, Regs 6, 10, 11; B.18(B); C(F)(ii)

Crossings between countries

South Africa → United Kingdom Researched
Papers that cross: SADPMR certificate to acquire/dispose of unwrought precious metal; Waybill, mine to refinery; Refiner outturn / assay report; 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)); SARS customs declaration / bill of entry for export; Waybill, refinery/exporter to port of export; Air waybill, Johannesburg to destination