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Switzerland → United States → Russian Federation → China (mainland) (refine) · Deposit, trade and withdrawal on the Shanghai Gold Exchange

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

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The route, leg by leg

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Switzerland (Doré bar - unstamped) ⟶ United States (Doré bar - unstamped) ⟶ Russia (Doré bar - unstamped) ⟶ China (Doré bar - unstamped → 999.9 kilobar)

Not researched: United States → Russia

Leg 1: Switzerland

Where the goods start

  1. 1

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

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

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

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

  2. 2

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

    Who
    Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)
    Issues
    Outbound weight list / bar list; Commercial invoice to the foreign buyer; Packing list
    Standard

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

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

  3. 3

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

    Who
    Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)
    Issues
    Passar export declaration (HS 7108)
    Official guidance

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

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

  4. 4

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

    Who
    Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)
    Issues
    Veranlagungsverfuegung Ausfuhr
    Official guidance

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

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

  5. 5

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

    Who
    Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)
    Needs
    Veranlagungsverfuegung Ausfuhr
    Primary law

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

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

  6. 6

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

    Who
    Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)
    Issues
    Air waybill (outbound)
    Unverified

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

Controls

  • Banks identify the contracting party and beneficial owner for precious-metals trading and for cash transactions over CHF 15,000 (CDB 20; Form A, Form K).

    CHF 15,000 cash

    StandardAmount not confirmed

    • CDB 20 (SBA), CDB Art. 4(2)(f)-(g), 7, 20-21, 27-28

  • Melt material imported from abroad for sale in Switzerland needs a formal import declaration; simplified and oral declarations are excluded in principle. A buyer or licensee who accepts melt material that has not been through customs breaches due diligence under the PMCA: fine up to CHF 2,000 per ca…

    Official guidance

    • BAZG Merkblatt 'Annahme von Schmelzgut aus dem Ausland' (Jan 2024)

  • Commercial production of melt products (bars, plates, rods, granules made by melting precious metal or melt material) requires a melt licence; acting without it is punishable by a fine (EMKG Art. 48). Every melt product must bear the licence holder's stamp; melt products for resale must be assayed b…

    Primary law

    • EMKG/PMCA (SR 941.31), Arts. 1(2), 24, 31(1), 32-33, 47, 48

  • Holders of a melter licence may accept melt material only from persons who can prove lawful acquisition, and must verify the customer's identity by a probative document such as a passport or identity card. Where origin is doubtful or the offer comes from unknown persons, origin must be clarified wit…

    Primary law

    • PMCO/EMKV (articles in refs), EMKV (SR 941.311, Stand 1 Jan 2024) Art. 168a Abs. 1 (parsed into section sch-2)

      “Der Inhaber einer Schmelzbewilligung darf Schmelzgut nur von Per-”

    • PMCO/EMKV (articles in refs), EMKV (SR 941.311, Stand 1 Jan 2024) Art. 168a Abs. 2 (parsed into section sch-2)

      “Es muss die Identität des Kunden anhand eines beweiskräftigen Do- kumentes wie Pass oder Identitätskarte überprüfen.”

    • PMCO/EMKV (articles in refs), EMKV (SR 941.311, Stand 1 Jan 2024) Art. 168a Abs. 3 (parsed into section sch-2)

      “Bestehen über die Herkunft der Ware Zweifel oder stammen die An- gebote von Unbekannten, so ist der Inhaber der Schmelzbewilligung verpflichtet, die Herkunft des Schmelzgutes besonders sorgfältig abzu- klären.”

    • PMCO/EMKV (articles in refs), EMKV (SR 941.311, Stand 1 Jan 2024) Art. 168b Abs. 1 (parsed into section sch-2)

      “derlichen organisatorischen Massnahmen, um das Schmelzen von Schmelzgut unrechtmässiger Herkunft zu verhindern.”

    • PMCO/EMKV (articles in refs), EMKV (SR 941.311, Stand 1 Jan 2024) Art. 168b Abs. 2 (parsed into section sch-2)

      “so ist die Ware durch den Inhaber der Schmelzbewilligung bis zur Klärung des Falles in unverändertem Zu- stand aufzubewahren.”

    • PMCO/EMKV (articles in refs), EMKV (SR 941.311, Stand 1 Jan 2024) Art. 168b Abs. 3 (parsed into section sch-2)

      “Schmelzprodukten müssen während zehn Jahren aufbewahrt werden.”

    • PMCO/EMKV (articles in refs), EMKV (SR 941.311, Stand 1 Jan 2024) Art. 168c Abs. 1 (parsed into section sch-2)

      “Der Inhaber einer Schmelzbewilligung muss über seine Ankäufe von Schmelzgut und Schmelzprodukten Buch führen.”

    • PMCO/EMKV (articles in refs), EMKV (SR 941.311, Stand 1 Jan 2024) Art. 168c Abs. 2 Bst. b (parsed into section sch-2)

      “die in Artikel 168a Absatz 2 vorgeschriebenen Identifikations- nachweise;”

    • PMCO/EMKV (articles in refs), BAZG Schmelzen und Prüfen (Dec 2023) Ziff. 4.1.6 (restates Art. 168a)

      “Er muss die Identität des Kunden anhand eines beweiskräftigen Dokumentes wie Pass oder Identitätskarte überprüfen und muss sich vor Ausführung des Auftrages den rechtmässigen Erwerb des Schmelzgutes durch den Auftraggeber nachweisen lassen.”

    • PMCO/EMKV (articles in refs), BAZG Schmelzen und Prüfen (Dec 2023) Ziff. 4.1.6 (restates Art. 168b Abs. 3)

      “Die Dokumente über den Geschäftsverkehr mit Schmelzgut und Schmelzprodukten müssen während zehn Jahren aufbewahrt werden.”

    • PMCO/EMKV (articles in refs), BAZG Richtlinie R-247 (1 Jan 2023) Ziff. 3.3.2

      “Bestehen Zweifel über die Herkunft des Materials oder in Bezug auf die Integrität des Kunden sind Bewilligungsinhaber verpflichtet, den Sachverhalt besonders sorgfältig abzuklären”

  • Purchase, import, transit and transport of gold (Annex 26) originating in Russia and exported from Russia after 4 Aug 2022, and of gold processed from it in third countries, are prohibited, as are related services (all kinds, including financial services, brokerage and technical assistance) and the …

    Primary law

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

  • Precious metals are 'sensitive goods' in free ports (Customs Ordinance Annex 2, as amended on 18 November 2015): the declarant must declare them electronically on entry into storage, and an electronic inventory record of them is kept per depositor and submitted by the warehouse keeper to customs on …

    Primary law

    • Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), AS 2015 4917, ZV Anhang 2 (sensitive goods) as amended

      “Anhang 2 wird wie folgt geändert:”

    • Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), ZV Anhang 2 Ziff. 5: precious metals ex tariff chapter 71

      “Perlen, Diamanten, Edelsteine, Schmucksteine, Edelmetalle und Edel- metallplattierungen sowie Waren daraus (ex Zolltarifkapitel 71)”

    • Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), AS 2015 4917 Ziff. IV: in force

      “Diese Verordnung tritt am 1. Januar 2016 in Kraft.”

    • Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), ZV Art. 178a Abs. 1: electronic declaration on entry into the free port

      “Die anmeldepflichtige Person muss sensible Waren bei der Einlagerung ins Zoll- freilager elektronisch anmelden.”

    • Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), ZV Art. 185: inventory record per depositor

      “Die Bestandesaufzeichnung für sensible Waren ist je Einlagererin oder je Einlagerer zu führen.”

    • Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), ZV Art. 184 Abs. 2: kept electronically

      “Sie muss elektronisch geführt werden.”

    • Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), ZV Art. 184 Abs. 3bis: warehouse keeper submits it on request

      “Auf Verlangen muss die Lagerhalterin oder der Lagerhalter der EZV die”

    • Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), AS 2015 4917, ZV Art. 246a: amendment date

      “Übergangsbestimmungen zur Änderung vom 18. November 2015”

    • Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), BAZG R-10-50 (1 Jul 2025) s.1.3.1: export goods count as sensitive goods

      “Ausfuhrwaren gelten als sensible Waren”

    • Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), R-10-50 s.4.1: inventory records over all sensitive goods

      “Bestandesaufzeichnungen nach den Grundsätzen der ordnungsgemässen Buchführung”

  • Cash threshold for dealers in goods (anti-money laundering)

    Primary law

    • GwG Art. 8a(1)

      “Händlerinnen und Händler nach Artikel 2 Absatz 1 Buchstabe b müssen folgende”

    • GwG Art. 8a(1)(a)

      “Identifizierung der Vertragspartei (Art. 3 Abs. 1);”

  • Cash threshold for dealers in gold (anti-money laundering)

    Primary law

    • GwG Art. 8a(1)

      “Händlerinnen und Händler nach Artikel 2 Absatz 1 Buchstabe b müssen folgende”

    • GwG Art. 8a(1)(a)

      “Identifizierung der Vertragspartei (Art. 3 Abs. 1);”

    • GwG Art. 8a(2bis)

      “oder Edelsteinen beträgt die massgebende Schwelle im Sinne von Ab-”

    • EMKG Art. 1(1)

      “Edelmetalle im Sinne dieses Gesetzes sind Gold, Silber, Platin und Palladium.”

Leg 2: United States

On the way

  1. 7

    Screen the supplier and the gold: KYC, OFAC sanctions lists, and confirm the gold is not of Russian Federation origin (unless it was outside Russia before 28 June 2022); apply CAHRA red flags from the 2023 Africa Gold Advisory

    Who
    Importer of record (bullion bank, trader, refiner or dealer)
    Needs
    Commercial invoice; Bar list (serials, weights, fineness)
    Issues
    Importer's supplier KYC and OFAC / Russian-origin screening file
    Primary law

    • E.O. 14068; OFAC Determination (effective 28 Jun 2022, amended 22 Dec 2023), E.O. 14068 s.1(a)(i); determination under s.1(a)(i)(A), 1(b) and 5; delegation 31 CFR 587.802

  2. 8

    File entry (CBP Form 3461 or electronic equivalent) with evidence of the right to make entry, commercial invoice and packing list, and the entry summary (CBP Form 7501) classifying the gold under HTSUS 7108 with country of origin; deposit any duty (heading 7108 free except 4.1% on 7108.12.50 and 7108.13.70 for non-preference origins) and the 0.3464% merchandise processing fee; shipments of $2,500 or less may use informal entry

    Who
    Licensed customs broker
    Needs
    Importer's supplier KYC and OFAC / Russian-origin screening file; Commercial invoice; Packing list; Air waybill
    Issues
    CBP Form 3461 entry / immediate delivery (or ACE electronic equivalent); CBP Form 7501 entry summary (HTSUS classification, origin, duties and fees)
    Primary law

    • 19 CFR 142.3; 19 CFR 143.21; 19 CFR 24.23; HTSUS 7108

  3. 9

    Review, examine if selected, and release the goods; CBP enforces the Russian-origin gold ban and any withhold release order on gold made with forced labour

    Who
    US Customs and Border Protection
    Needs
    CBP Form 3461 entry / immediate delivery (or ACE electronic equivalent)
    Issues
    CBP release of entered goods (ACE cargo release)
    Primary law

    • 19 CFR 142.3; E.O. 14068 gold determination; 19 U.S.C. 1307 and 19 CFR 12.42

  4. 10

    Deliver released gold directly to the refinery or to a COMEX-approved depository (for COMEX, bars must come directly from an approved producer or assayer with certificates, or from another depository)

    Who
    Secure logistics carrier (armoured / valuables; COMEX-approved carrier where relevant)
    Needs
    CBP release of entered goods (ACE cargo release)
    Issues
    Delivery record airport to refinery or depository
    Standard
  5. 11

    Deliver bars into a COMEX-approved depository directly from the approved producer with refiner certificates, from an approved assayer with assay certificates, or from another approved depository

    Who
    Secure logistics carrier (armoured / valuables; COMEX-approved carrier where relevant)
    Needs
    Refiner certificate for bars produced (brand, serial, weight, fineness)
    Issues
    Chain-of-integrity receipt at depository
    Standard
  6. 12

    Inspect and weigh the bars and record them as eligible stock

    Who
    COMEX-approved depository / bullion vault
    Needs
    Chain-of-integrity receipt at depository; Bar list (serials, weights, fineness)
    Issues
    Depository inspection, weight record and eligible-stock entry
    Standard
  7. 13

    Issue an electronic warrant in the name of the clearing member, referencing bar serials and the approved producer; the metal becomes registered (deliverable) stock

    Who
    COMEX-approved depository / bullion vault
    Needs
    Depository inspection, weight record and eligible-stock entry
    Issues
    COMEX gold warrant (electronic UCC Article 7 document of title)
    Standard

    • COMEX Rulebook; UCC Article 7, Rule 705.A; 113108

  8. 14

    Report eligible, pledged and registered stocks to the exchange registrar daily by 2:00 p.m.

    Who
    COMEX-approved depository / bullion vault
    Standard
  9. 15

    Optionally pledge the warrant to CME as collateral (title to CME, first-priority security interest, 15% haircut)

    Who
    Futures clearing member / bullion bank
    Needs
    COMEX gold warrant (electronic UCC Article 7 document of title)
    Standard
  10. 16

    Release the bars from the depository (load-out after warrant cancellation if on COMEX warrant) to the carrier

    Who
    COMEX-approved depository / bullion vault
    Needs
    Depository inspection, weight record and eligible-stock entry
    Standard
  11. 17

    File EEI in AES for the foreign-origin gold and give the ITN to the carrier (same rules as export; BIS licence for Russia/Belarus)

    Who
    US principal party in interest (USPPI) / exporter
    Issues
    EEI/ITN for re-export of foreign-origin gold
    Primary law

    • Foreign Trade Regulations, 15 CFR 30.2, 30.4

Taxes and fees

  • Customs duty on gold (HTSUS 7108)

    Column 1 general: Free on 7108.11.00 (powder), 7108.12.10 (bullion and dore), 7108.13.10 (gold leaf), 7108.13.55 (rectangular or near-rectangular shapes of 99.5%+ gold marked only with weight, purity or other identifying information), 7108.20.00 (monetary); 4.1% on 7108.12.50 (other unwrought) and 7108.13.70 (other semi-manufactured), Free for special programmes A, AU, BH, CL, CO, D, E, IL, JO, KR, MA, OM, P, PA, PE, S, SG (General Note 3(c)(i): e.g. S = USMCA, PE = Peru TPA, CO = Colombia TPA, AU = Australia FTA, CL = Chile FTA, SG = Singapore FTA, A = GSP, D = AGOA). Column 2: 65% on 7108.12.50 and 7108.13.70, 8% on gold leaf, Free on the others (7108.13.55 footnoted "See 9903.90.08") All imports of gold

    Primary lawAmount not confirmed

    • HTSUS (Revision 19, 2026), heading 7108

  • Nevada gold and silver excise tax

    0.75% of Nevada gross revenue above $20,000,000 up to $150,000,000 (i.e. $975,000 at $150m) plus 1.1% of the excess over $150,000,000; nothing due if $20,000,000 or less

    Official guidanceAmount not confirmed

    • NRS 363D (per Department of Taxation form EXC-F029), NRS 363D.160 (as cited by the Department)

  • IEEPA reciprocal tariff (E.O. 14257) - ended February 2026; gold bullion exempt throughout, other 7108 lines exempt from 8 Sep 2025

    10% on all imports from 12:01 a.m. EDT 5 Apr 2025 (E.O. 14257 s.3(a)) plus country-specific rates from 9 Apr 2025 as modified; goods in Annex II excepted 7108.12.10 (bullion and dore) was already in Annex II; E.O. 14346 Annex II (FR 43788-43789) marks 7108.11.00, 7108.12.50, 7108.13.10, 7108.13.55, 7108.13.70 and 7108.20.00 as "Addition" for goods entered from 12:01 a.m. EDT 8 Sep 2025. Before that, cast kilobars and 100 oz bars classified in 7108.13.5500 paid the additional duty (CBP ruling N351466: "subject to an additional 10 percent ad valorem rate of duty").

    Primary lawAmount not confirmed

    • E.O. 14257 as modified by E.O. 14346 (IEEPA); ended by E.O. 14389

  • Additional duty on Russian products (9903.90.08)

    35% ad valorem in lieu of column 2 rates Products of Russia in U.S. note 30(b); of heading 7108 only 7108.13.55 is listed. Moot for gold: its import is prohibited (us.ctl-russia-gold-ban)

    Primary lawAmount not confirmed

    • HTSUS chapter 99, 9903.90.08

  • Section 122 temporary import surcharge (Proclamation 11012) - gold excepted

    10% ad valorem on articles of any country (heading 9903.03.01), in addition to other duties; not applied to the goods listed in U.S. note 2(aa)(ii) (heading 9903.03.03), which include every 7108 subheading: 7108.11.00, 7108.12.10, 7108.12.50, 7108.13.10, 7108.13.55, 7108.13.70, 7108.20.00 Gold of HTSUS 7108 excepted ("metals used in currency and bullion", Proc. 11012 para. 14(b); Annex I para. 2; Annex II)

    Primary lawAmount not confirmed

    • Trade Act of 1974 s.122 (19 U.S.C. 2132); Proclamation 11012; HTSUS U.S. note 2(aa), subchapter III, chapter 99, 9903.03.01; 9903.03.03; note 2(aa)(ii)

  • Section 301 forced-labor tariffs on 60 economies (USTR, from 24 Jul 2026) - gold excluded

    Additional 10% or 12.5% ad valorem depending on the economy (headings 9903.05.20-9903.05.84), e.g. Canada 10% (9903.05.29), Mexico 10% (9903.05.55), United Kingdom 10% (9903.05.81), Peru 12.5% (9903.05.63), Colombia 12.5% (9903.05.32), United Arab Emirates 12.5% (9903.05.80), Switzerland: for goods whose column-1 rate is under 12.5%, column-1 rate plus additional duty totalling 12.5% (9903.05.74; note 52(k)); the same top-up method applies to the EU, Japan, South Korea and Taiwan headings; not applied to articles in U.S. note 52(b) (heading 9903.05.86), which lists 7108.11.00, 7108.12.10, 7108.12.50, 7108.13.10, 7108.13.55, 7108.13.70 and 7108.20.00 All HTSUS 7108 gold excluded; applies to other products of the listed economies

    Primary lawAmount not confirmed

    • Trade Act of 1974 s.301 (19 U.S.C. 2411); USTR notice FR Doc. 2026-15181; HTSUS U.S. note 52, subchapter III, chapter 99, 9903.05.20-9903.05.84; 9903.05.86; note 52(b)

  • VAT / sales tax on gold

    No federal VAT or import VAT; state sales taxes vary - about 33 states exempt investment bullion or have no sales tax (Mar 2026) Bullion sales to end buyers

    Secondary

  • BLM mining claim fees

    $49 location fee and $200 initial maintenance fee per new lode claim, mill site or tunnel site; $200 annual maintenance fee (placer: per 20 acres or portion) due on or before 1 September; processing fees per 43 CFR 3000.12 ($25 per new claim on the BLM page)

    Primary lawAmount not confirmed

    • 30 U.S.C. 28f; 43 CFR 3830.21, 43 CFR 3830.21(a), (d)

  • Merchandise processing fee

    0.3464% ad valorem on formal entries (19 CFR 24.23(b)(1)(i)(A)); minimum/maximum per entry $33.58/$651.50 for fiscal year 2026 (1 Oct 2025-30 Sep 2026, CBP Dec. 25-10) and $34.58/$670.86 from 1 Oct 2026 (FY2027 notice); base amounts $25/$485 CPI-adjusted; informal entries a flat fee (base $2-$9)

    Primary lawAmount not confirmed

    • 19 CFR 24.23, 24.23(b)(1)(i), (b)(2)

Controls

  • Beneficial ownership reporting under the Corporate Transparency Act applies only to a "reporting company" defined as an entity "(A) A corporation, limited liability company, or other entity; (B) Formed under the law of a foreign country; and (C) Registered to do business in any State or tribal juris…

    Primary law

    • 31 CFR 1010.380, 1010.380(a)(1), (c)(1)(ii)

  • Any trade or business receiving more than $10,000 in currency in one or related transactions must file Form 8300 within 15 days. There is no cash ceiling, only reporting.

    > $10,000 cash

    Primary lawAmount not confirmed

    • 31 CFR 1010.330; 26 USC 6050I, 1010.330(a)(1)(i)

  • Gold bullion is not a 'monetary instrument' under the BSA, so the cross-border currency report (CMIR) does not apply to gold carried or shipped across the border; customs entry and EEI are the only declarations.

    Primary law

    • 31 CFR 1010.340; 31 CFR 1010.100(dd), 1010.340(a); 1010.100(dd)

  • COMEX gold delivery: one 100 oz bar or three 1 kg bars, weight tolerance 5%, minimum 995 fineness, approved brand from an approved producer complying with LBMA RGG, held in an approved depository reached through the chain of integrity.

    Standard

    • COMEX Rulebook, 113101; Rules 703.A, 705.A

  • SEC-reporting issuers that manufacture or contract to manufacture products in which gold is necessary must "conduct in good faith a reasonable country of origin inquiry" (Form SD Item 1.01(a)); if they know or have reason to believe the gold may come from the DRC or an adjoining country and may not …

    Primary law

    • Dodd-Frank s.1502; Exchange Act Rule 13p-1; Form SD (as adopted 2012), 17 CFR 240.13p-1; Form SD Items 1.01-1.02

  • Dealers in precious metals (gold of 500+ fineness among covered goods) must keep a written risk-based AML program with compliance officer, training and independent testing; retailers are covered only if they buy over $50,000 from non-dealers.

    Purchased > $50,000 and sold > $50,000 of covered goods in the prior year

    Primary lawAmount not confirmed

    • 31 CFR 1027, 1027.100, 1027.210

  • HS 710812 and 710813 (non-monetary gold, unwrought other than powder, and semi-manufactured) are listed EAR 'luxury goods': "A license is required to export, reexport, or transfer (in-country) any item subject to the EAR listed in supplement no. 5 to this part to or within Russia or Belarus" (746.8(…

    Primary law

    • EAR 15 CFR 746.8(a)(7), (b)(3); Supplement No. 5 to Part 746, 746.8(a)(7)

  • Goods "mined, produced, or manufactured wholly or in part in any foreign country by convict labor or/and forced labor or/and indentured labor under penal sanctions shall not be entitled to entry" (19 U.S.C. 1307). Where information "reasonably but not conclusively indicates" such merchandise is bein…

    Primary law

    • Tariff Act of 1930 s.307 (19 U.S.C. 1307); 19 CFR 12.42, 19 U.S.C. 1307; 19 CFR 12.42(e)-(h)

  • US persons may not deal with SDN-listed parties; the 2023 multi-agency Africa Gold Advisory flags Wagner-linked gold from CAR and Sudan and conflict gold from Mali and Burkina Faso, warning of designation and penalties.

    Official guidance

    • IEEPA-based OFAC programs

  • Historical (2025 - Feb 2026): E.O. 14257 imposed an additional 10% on all imports from 5 Apr 2025 and country rates from 9 Apr 2025, with Annex II exceptions that from the start included 7108.12.10 (bullion and dore). CBP ruling N351466 (31 Jul 2025) classified cast 1 kg and 100 oz bars from Switzer…

    Primary law

    • E.O. 14257; E.O. 14346; E.O. 14389; Proclamation 11012; HTSUS U.S. notes 2(aa) and 52

  • Import into the US of gold of Russian Federation origin is prohibited unless licensed by OFAC; gold of Russian origin located outside Russia before 28 June 2022 is excluded.

    Primary law

    • E.O. 14068 as amended by E.O. 14114; OFAC Determination (effective 28 Jun 2022, amended 22 Dec 2023), E.O. 14068 s.1(a)(i)(A) (as amended by E.O. 14114 s.3(a)); delegation 31 CFR 587.802

Leg 3: Russia

On the way

  1. 18

    File the FPP import-control application in GIIS DMDK with the foreign-trade contract, specification, document on precious-metal content and special-registration record

    Who
    Importer of gold-bearing material for refining (refiner or special-registered company)
    Needs
    Special-registration register entry (FPP); Assay certificate (fineness and fine weight); Commercial invoice
    Issues
    FPP application for import control
    Primary law

    • EEC Board Decision 30, Annex 14, Annex 2 (Rules) para 4(a), Rules para 4(a)

  2. 19

    State control at a specialised customs post (all goods except ores and concentrates), within 5 working days; act of state control

    Who
    Federal Assay Chamber
    Needs
    FPP application for import control
    Issues
    Act of state control on import
    Primary law

    • Presidential Decree 1137 para 19¹; EEC Board Decision 30, Annex 14, Annex 2 para 10, para 19¹

  3. 20

    Declare the goods at a specialised customs post for release or processing, presenting the act of state control, and take delivery to the refinery

    Who
    Importer of gold-bearing material for refining (refiner or special-registered company)
    Needs
    Act of state control on import
    Issues
    EAEU goods declaration for import / customs processing
    Primary law

    [not-read] Import duty and import VAT treatment of gold-bearing material not read.

    • EEC Board Decision 30, Annex 14 paras 4, 8, Regulation para 8

  4. 21

    Screen buyer and destination: Russian-origin gold exported after the sanctions dates cannot be imported into the EU, UK, US, Switzerland or Japan, and Russian bars made from 7 Mar 2022 are not LBMA Good Delivery; sales go to non-sanctioning markets

    Who
    Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
    Primary law
  5. 22

    Sign the export contract and issue the commercial invoice

    Who
    Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
    Issues
    Export contract with foreign buyer; Commercial invoice
    Primary law
  6. 23

    Apply to Minpromtorg for an export licence (one-off for a contract, or a general licence under Decree 1126 or 867); Minfin approves the application in GIIS DMDK within 10 working days (Order 10n from 1 Sep 2026), except credit organisations' applications for refined gold, silver, platinum and palladium bars since 8 May 2026

    Who
    Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
    Needs
    Export contract with foreign buyer; Special-registration register entry (FPP)
    Issues
    Minfin conclusion (permissive document) approving an export-licence application (Order 10n from 1 Sep 2026); EAEU export licence issued by Minpromtorg (one-off or general)
    Primary law

    Licence validity and issue time from EEC Council Decision 125 Rules paras 9 and 13: a one-off licence is valid up to 1 year from its start (may be limited to the contract term); a general licence up to 1 year; the licensing authority decides within 15 working days of receiving the documents unless the Commission decision introducing the measure sets another term. [unconfirmed] Decision 125's own in-force date depends on the Protocol of 25.05.2023 (see ru.law-eec-125).

    • Presidential Decree 1137, Regulation paras 4 and 22; Minfin Order 10n, paras 4, 22

  7. 24

    File the application letter for FPP state control through GIIS DMDK with: the export licence copy (table-1 goods), the contract, the specification, the invoice, the calculation of the value of the precious metals (within 5% of world prices), special-registration record or bank licence, proof of lawful ownership, the precious-metal content document, technical documentation, the subsoil licence (mining subjects) and the document on the State Fund's refusal to buy (mining and producing subjects)

    Who
    Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
    Needs
    EAEU export licence issued by Minpromtorg (one-off or general); Export contract with foreign buyer; Commercial invoice; Document on the authorised bodies' refusal (non-exercise) to purchase; Passport for standard bar / certificate for measured bar of refined precious metal (FPP Order 154n; replaced by a single certificate under Order 144n from 1 Mar 2027)
    Issues
    Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK; Calculation of the value of precious metals in the consignment
    Primary law

    [transcription] EEC Board Decision 30 read in the ConsultantPlus copy published by the FPP; the FPP list reproduces the same paragraph.

    • EEC Board Decision 30, Annex 14, Annex 2 (Rules) para 4(b); Minfin Order 11n (valuation), Rules para 4(b)

  8. 25

    State control of the whole consignment within 5 working days: check against documents, origin, compliance with transaction rules, valuation, optional sampling; issue the act of state control (3 copies; the first for customs) or a refusal

    Who
    Federal Assay Chamber
    Needs
    Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK
    Issues
    Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber
    Primary law

    • EEC Board Decision 30, Annex 14, Annex 2 (Rules) paras 3, 8, 10; 41-FZ art. 26², Rules para 10

  9. 26

    Lodge the export declaration at a specialised customs post, presenting the export licence and the act of state control

    Who
    Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
    Needs
    EAEU export licence issued by Minpromtorg (one-off or general); Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber; Commercial invoice
    Issues
    Export goods declaration (accepted and released by customs); Certificate of origin (general form) for non-EAEU destinations
    Primary law

    [not-read] The customs rules on the declaration itself were not read.

    • EEC Board Decision 30, Annex 14 paras 4-5; Presidential Decree 1137 para 19¹, Regulation paras 4-5

  10. 27

    Carry the sealed consignment to the airport and hand to the airline (valuable cargo)

    Who
    Secure carrier of valuables
    Needs
    Export goods declaration (accepted and released by customs)
    Issues
    Packing list; Air waybill
    Unverified

    The armed-escort rule (41-FZ art. 29(3)) covers transport to the airport; no rule on the hand-over to the airline was read.

    • Federal Law 41-FZ, art. 29(3)

Taxes and fees

  • VAT on precious metals

    0% on sales of precious metals by mining or producing taxpayers to the State Fund, regional funds, the Bank of Russia and banks (art. 164(1)(6)); 0% on goods exported under the export customs procedure (art. 164(1)(1)); 0% on ores and concentrates sold by miners to listed refiners for refining (art. 164(1)(6³)); exempt: sales of precious metals to the State Fund, CBR and banks by others, bank and CBR sales of bars to banks, sales of refined bars (except silver) by banks, refiners and Goznak to individuals, and bank sales of bars kept in the vault (art. 149(3)(9)); exempt: legal-tender precious-metal coins (art. 149(2)(11))

    Primary lawAmount not confirmed

    • Tax Code Part Two, ch. 21, arts. 149(2)(11), 149(3)(9), 164(1)(1), (6), (6³)

Controls

  • FPP state control of every import from and export to non-EAEU states of goods in tables 1 and 3 of section 2.10 (41-FZ art. 26²; Decree 1137 para 19(b)): the whole batch is presented (for ores and concentrates, HS 2616, the documents only) and controlled within 5 working days; checks of the batch a…

    Primary law

    • EEC Board Decision 30, Annex 14, Annex 2 (Rules) paras 3, 4, 7, 8, 10; Presidential Decree 1137 paras 19, 19¹, Rules paras 3, 10

  • From 1 May 2026 export from Russia of refined gold in bars with a total weight over 100 g by individuals, legal entities and entrepreneurs is prohibited, except (a) to EAEU member states through the international airports Moscow (Vnukovo), Moscow (Domodedovo), Moscow (Sheremetyevo) and Vladivostok (…

    Total weight over 100 g

    Primary lawAmount not confirmed

    • Presidential Decree 193 of 25.03.2026; Government Decree 450 of 23.04.2026, para 2, para 4

  • Purchase and sale of precious metals (and jewellery and scrap) of RUB 1,000,000 or more is subject to mandatory control and reported to Rosfinmonitoring by the seller within 3 working days; individuals buying jewellery up to RUB 60,000 (RUB 400,000 with a personalised e-payment means) are not identi…

    RUB 1,000,000

    Primary lawAmount not confirmed

    • Law 115-FZ, art. 6(1)(4) sixth paragraph; art. 7(1.4-2)

  • Only listed refiners, Goznak and credit organisations may sell refined (investment) bars to individuals, and retailers only bars received on commission or agency from them; buy-back dealers and pawnshops may pass bars bought from individuals only to refiners. Deals between individuals in precious me…

    Primary law

    • Government Decree 604 of 15.05.2024 (Rules paras 3-4, 8); 41-FZ art. 22(6), Rules para 4

  • No gold-specific cash-payment limit was found. The RUB 1,000,000 mandatory-control threshold applies whatever the means of payment.

    Unverified

  • Export to non-EAEU states of goods in tables 1 and 2 of section 2.10 of the EAEU Single List (table 1 includes refined gold in bars, plates, powder and granules, unique and non-refinable nuggets, other unwrought gold incl. dore, scrap, ores and concentrates) requires a licence issued by Minpromtorg …

    Primary law

    • Presidential Decree 1137 (Regulation paras 4, 22, 23); EEC Board Decision 30, Annex 14 para 5; Minfin Order 10n, paras 4, 22, 23

  • Residents must receive export proceeds on their accounts in authorised banks (173-FZ art. 19(1)(1)). Under art. 19(8) this does not apply to contracts priced or payable in foreign currency, except for goods listed there; the list includes HS 7101-7103 and 7112 but not 7108 (gold). Where art. 19 appl…

    Primary law

    • Federal Law 173-FZ art. 19; Presidential Decrees 79 (para 2) and 430, art. 19(1), (8)

  • Traceability: participants must record precious-metal operations in GIIS DMDK, with UINs and electronic accompanying documents between participants; refiners report receipt and shipment of metal in any form.

    Primary law

    • 41-FZ art. 12², art. 20(2); Government Decree 270 of 26.02.2021, art. 12²

  • Refined metal in standard form must, before it enters circulation, be offered by a purchase proposal to the State Fund institution under Minfin and to the authority of the mining region (where a regional fund exists) - for the next year by 31 December, with an additional proposal within 10 working d…

    Primary law

    • Federal Law 41-FZ, art. 2(5), art. 20(4)-(5)

  • LBMA suspended six Russian refiners on 7 Mar 2022; their bars produced from that date are not Good Delivery; Russian bars already in loco London/Swiss before then remain Good Delivery, with clearing banks attesting conformity.

    Standard

  • Mined and produced precious metals (except nuggets) must, after the necessary processing, go for refining to organisations on the Government list (41-FZ art. 20(1)); only listed organisations may refine (art. 4(4)); the refining agreement's mandatory terms and the refiner's reporting duties are set …

    Primary law

    • Federal Law 41-FZ, art. 20(1)

  • Switzerland: purchase, import, transit and transport into and through Switzerland of gold under Annex 26 (includes HS 7108) originating in Russia and exported from Russia after 4 August 2022 are prohibited (Art. 14d(1)); the same applies to such gold processed in a third country (Art. 14d(2)) and, s…

    Primary law

    • Swiss Ukraine Ordinance SR 946.231.176.72 (Stand 21.09.2026), Art. 14d

  • EU: it is prohibited to purchase, import or transfer, directly or indirectly, gold listed in Annex XXVI (HS 7108; 7112 91 gold waste and scrap; ex 7118 90 gold coins) that originates in Russia and was exported from Russia into the Union or to any third country after 22 July 2022 (art. 3o(1)); the sa…

    Primary law

    • Regulation (EU) 833/2014 as amended by 2022/1269, art. 3o

  • Japan: import of precious metals originating in Russia and shipped from Russia on or after 1 August 2022 requires the Minister of Finance's permission under FEFTA art. 19(2) (MOF Notice No 443 of 2006 as amended 25 July 2022, item 4); the government announced it on 5 July 2022 as an import ban.

    Primary law

    • MOF Notice No 443 of 2006 as amended 25 Jul 2022, item 4

  • UK: import of gold originating in Russia and exported from Russia on or after 21 July 2022 is prohibited (reg 46Z11, Chapter 4J inserted by SI 2022/850, in force 21 Jul 2022), with prohibitions on acquisition with intent to import, supply and delivery, technical assistance, financial services and br…

    Primary law

    • Russia (Sanctions) (EU Exit) Regulations 2019, regs 46Z11-46Z16, 46Z16A-46Z16C

  • US: import of gold of Russian Federation origin is prohibited from 28 Jun 2022, except gold located outside Russia before that date (OFAC determination under E.O. 14068 s. 1(a)(i)(A), amended version of 22 Dec 2023). U.S. persons may not deal with the Central Bank, the National Wealth Fund or the Mi…

    Primary law

    • E.O. 14068 and the OFAC determination; E.O. 14024 as amended by E.O. 14114, E.O. 14068 s. 1(a)(i)(A); E.O. 14024 s. 11

      “the importation into the United States of … products of Russian Federation origin”

  • Temporary ban from 1 June to 30 November 2026 on export from Russia of precious-metal waste and scrap (HS 7112) and electrical and electronic waste used mainly to recover precious metals (8549 21 000 0, 8549 29 000 0), with exceptions for samples of up to 500 g per batch exported by listed refiners …

    Primary law

    • Government Decree 558 of 16.05.2026, para 1

  • Legal entities, entrepreneurs and artist-jewellers operating with precious metals must be on the FPP special register kept in GIIS DMDK; those that should be registered and are not may not carry out operations (41-FZ art. 13¹(2)). Registration within 30 calendar days of state registration (Rules pa…

    Primary law

    • 41-FZ art. 13¹; Government Decree 1052 (Rules paras 2, 5), art. 13¹

  • Precious metals and products from them are transported by air, sea, inland water, rail or specialised equipped road vehicles under armed escort; raw materials with less than 1% gold (or 5% silver), jewellery, investment metals (within a weight limit set by the Government) and some other items may mo…

    Primary law

    • Federal Law 41-FZ, art. 29(3)

Leg 4: China

Where the goods arrive

Doré bar - unstamped → 999.9 kilobar

  1. 28

    Hold the PBoC gold import/export qualification (bank that is an SGE financial member or market maker, or qualified mining group or refiner)

    Who
    Bank holding PBoC gold import/export qualification (SGE financial member or market maker)
    Primary law

    • Gold and Gold Products Import/Export Measures, Arts. 7, 8, 10

  2. 29

    Apply to the PBoC for a permit for the batch: application form, import contract and (on repeat applications) nothing further unless details changed

    Who
    Bank holding PBoC gold import/export qualification (SGE financial member or market maker)
    Issues
    Gold and Gold Products Import/Export Application Form (《黄金及黄金制品进出口申请表》) with contract; Gold import/export contract (required with the permit application)
    Primary law

    • Gold and Gold Products Import/Export Measures, Art. 10

  3. 30

    Examine (verification by two or more staff where needed) and decide within 20 working days; issue the permit, one per batch, usable within 40 working days

    Who
    People's Bank of China (permit issuer and reserve holder)
    Needs
    Gold and Gold Products Import/Export Application Form (《黄金及黄金制品进出口申请表》) with contract; Gold import/export contract (required with the permit application)
    Issues
    PBoC permit (import batch)
    Primary law

    • Gold and Gold Products Import/Export Measures, Arts. 3, 14-17

  4. 31

    Pay the foreign seller through the bank under foreign-exchange rules

    Who
    Bank holding PBoC gold import/export qualification (SGE financial member or market maker)
    Needs
    Gold import/export contract (required with the permit application)
    Issues
    Import payment through an FX-authorised bank
    Primary law

    [not-read] SAFE detailed goods-trade FX rules (current-account guidelines) not held; the FX Regulations require a genuine transaction basis checked by the bank.

    • Gold and Gold Products Import/Export Measures; FX Regulations, Measures art. 23; FX Regulations arts. 12, 14

  5. 32

    Declare the gold to Customs (HS 7108) presenting the PBoC permit; import-stage VAT is exempt for gold (incl. standard gold) and gold ore

    Who
    Bank holding PBoC gold import/export qualification (SGE financial member or market maker)
    Needs
    PBoC permit (import batch); Export customs declaration accepted by the dispatching country's customs; Air waybill; Refiner's certificate for the bars it produced (serials, fineness, weights, year); Commercial invoice
    Issues
    Customs import declaration (进口货物报关单), HS 7108
    Primary law

    [unconfirmed] Import duty rate for 7108 not held (cn.gap-tariff). [unconfirmed] Continuation of the import-stage VAT exemption after 1 Jan 2026 (cn.gap-import-vat-2026; MOF/GAC/SAT 2026 No. 17 read only in summary [summary]).

    • Gold and Gold Products Import/Export Measures; Customs Law; Caishui [2002] 142, Measures arts. 3, 17; Customs Law art. 24; Caishui 142 point 1

  6. 33

    Register the imported gold on SGE and complete its first trade there (duty to balance domestic physical supply)

    Who
    Bank holding PBoC gold import/export qualification (SGE financial member or market maker)
    Needs
    Customs import declaration (进口货物报关单), HS 7108
    Issues
    SGE registration and first-trade record of imported gold; SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)
    Primary law

    • Gold and Gold Products Import/Export Measures, Art. 6

  7. 34

    Report execution of the permit to the PBoC

    Who
    Bank holding PBoC gold import/export qualification (SGE financial member or market maker)
    Needs
    PBoC permit (import batch)
    Issues
    Report to PBoC on use of the import/export permit
    Primary law

    • Gold and Gold Products Import/Export Measures, Art. 19

  8. 35

    Receive and assay doré or raw gold under the refining or purchase agreement

    Who
    SGE-accredited refiner (standard gold ingot / bar refiner)
    Needs
    Refining Agreement (fee schedule, assay/settlement formula); VAT-exempt sales invoice for non-standard gold or gold ore (producer sale)
    Unverified

    Chinese refiner intake practice not documented in sources read.

  9. 36

    Refine into SGE standard ingots or bars (Au99.99 1 kg; Au99.95 3 kg; Au99.5 12.5 kg; Au100g/Au50g at 999.9) under the refiner's SGE accreditation

    Who
    SGE-accredited refiner (standard gold ingot / bar refiner)
    Form
    Doré bar - unstamped → 999.9 kilobar
    Official guidance

    • SGE Detailed Delivery Rules; SGE Refiner Measures 2025, Delivery Rules Art. 11 and Annex 1; Refiner Measures arts. 2, 26-27

  10. 37

    Issue the certificate of quality and packing list (bar list) for the bars

    Who
    SGE-accredited refiner (standard gold ingot / bar refiner)
    Issues
    Refiner's certificate of quality and packing list for SGE standard bars; Bar list (serials, weights, fineness)
    Official guidance

    • SGE Detailed Delivery Rules, Art. 30

  11. 38

    Open an FT account at a margin custodian bank and trade International Board contracts (iAu99.99, iAu99.5) in offshore RMB

    Who
    SGE international member or international client (SGEI, Shanghai FTZ)
    Issues
    Free Trade (FT) account statement in offshore RMB (SGEI)
    Official guidance

    • SGE Member Management Measures (2026); SGEI Business Management Measures, Member Measures Arts. 3-4; SGEI Measures arts. 4, 20-21

  12. 39

    Bring bars from abroad into an International Board vault (Customs-supervised, bonded) without a PBoC permit (exempt channel), through the vault's designated carrier and customs broker, giving SGE the invoice (incl. origin), packing list, bar list and non-wood packaging declaration; load-in needs SGE authorisation and bars from SGE-accredited or recognised international suppliers

    Who
    SGE international member or international client (SGEI, Shanghai FTZ)
    Needs
    Air waybill; Refiner's certificate for the bars it produced (serials, fineness, weights, year)
    Issues
    IB vault entry papers; SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)
    Primary law

    [not-read] Customs' own entry formalities for the bonded zone (declaration form, supervision code) not held; the SGE guidelines say the vault's appointed customs broker files them.

    • Gold and Gold Products Import/Export Measures; SGE IB Vault Guidelines; SGE Vault Measures; Delivery Rules, Measures art. 20(2); Guidelines arts. 4-9; Vault Measures arts. 4, 12; Delivery Rules Art. 27 and Annex 2

  13. 40

    Hold the bars in an International Board vault (3 bonded vaults: trading vaults in Shanghai (2) and Shenzhen (1); safekeeping vault in Shanghai). SGE's January 2026 fee schedule lists IB storage rates, while the IB page says storage and in/out fees are currently waived

    Who
    SGE designated vault / International Board certified vault operator
    Official guidance

    [conflict] cn.div-conflict-ib-fees: fee schedule rates versus the waiver stated on the IB page.

    • SGE Vault Measures; SGE fee schedule (Jan 2026), Vault Measures Art. 3

  14. 41

    Withdraw for re-export abroad (exempt channel: invoice and SGE withdrawal papers; carrier appointed by the vault) or for entry into the domestic market (only by a member or client holding the gold import/export qualification, with the PBoC permit copy 1 and a customs import declaration); the destination is reported to SGE and Customs

    Who
    SGE international member or international client (SGEI, Shanghai FTZ)
    Issues
    SGE Application for Load-Out and Application of Take-delivery
    Primary law

    • Gold and Gold Products Import/Export Measures; SGE IB Vault Guidelines; Delivery Rules; Vault Measures, Measures arts. 4, 20; Guidelines arts. 10-12, 17-19; Delivery Rules Art. 42; Vault Measures Arts. 17-18

  15. 42

    Deposit bars at an SGE designated vault through a registered designated deposit person, with the Load-In application (3 copies), quality certificate and packing list; the vault checks gross weight (tolerance ±0.1 g for ingots, ±0.05 g for bars) and accepts only bars from SGE-accredited refiners or suppliers accredited by an SGE-recognised international market

    Who
    SGE comprehensive member (producer, processor, jeweller or trader)
    Needs
    Refiner's certificate of quality and packing list for SGE standard bars; Bar list (serials, weights, fineness)
    Issues
    SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)
    Official guidance

    • SGE Detailed Delivery Rules; Vault Measures, Delivery Rules Arts. 11, 29-31; Vault Measures Art. 4

  16. 43

    Sell standard gold on SGE; the seller's sale is VAT-exempt (it invoices the exchange with an ordinary invoice against the exchange's settlement invoice); while no physical delivery out of the vault takes place, the exchange's sale is also exempt and the buyer receives a settlement invoice (结算发票) only

    Who
    SGE comprehensive member (producer, processor, jeweller or trader)
    Needs
    SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)
    Issues
    SGE trade and clearing record
    Primary law

    • MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 point 1; SAT No. 23 point 1

  17. 44

    Buyer (member or client) applies through the member platform to take delivery and presents the Load-Out application, take-delivery application and withdrawer's ID at the vault

    Who
    SGE institutional client (e.g. jewellery manufacturer) trading through a member
    Needs
    SGE trade and clearing record
    Issues
    SGE Application for Load-Out and Application of Take-delivery
    Official guidance

    • SGE Detailed Delivery Rules, Arts. 37, 43, 45

  18. 45

    On delivery out of the vault to a member that declared investment use on the delivery-out slip, the exchange's sale is subject to VAT levied and immediately refunded to the exchange (urban construction tax and education surcharges exempt) and SGE issues the member a VAT special invoice labelled 会员单位投资性黄金

    Who
    Shanghai Gold Exchange (and SGEI)
    Needs
    SGE Application for Load-Out and Application of Take-delivery
    Issues
    SGE VAT special invoice labelled 会员单位投资性黄金 (member withdrawal for investment use)
    Primary law

    • MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 points 1(1), 5, 7; SAT No. 23 point 2(1)-(2)

  19. 46

    Deduct the input VAT shown on the SGE special invoice after use confirmation on the tax platform; onward sales of the gold, or of investment gold products made from it, are invoiced with ordinary invoices only (no special invoices, except legal gold coins)

    Who
    SGE comprehensive member (producer, processor, jeweller or trader)
    Needs
    SGE VAT special invoice labelled 会员单位投资性黄金 (member withdrawal for investment use)
    Issues
    Member's input-VAT deduction on the SGE special invoice (VAT return schedule 2, after use confirmation)
    Primary law

    • SAT Announcement 2025 No. 23; MOF/SAT Announcement 2025 No. 11, SAT No. 23 point 2(3)-(4); 2025 No. 11 point 1(1)

  20. 47

    On delivery out of the vault for non-investment use (declared on the delivery slip), or to a client, the exchange's sale is exempt and SGE issues an ordinary invoice labelled 会员单位非投资性黄金 or 客户标准黄金; a general-taxpayer buyer computes input VAT at 6% of the invoice amount

    Who
    Shanghai Gold Exchange (and SGEI)
    Needs
    SGE Application for Load-Out and Application of Take-delivery
    Issues
    SGE VAT ordinary invoice labelled 会员单位非投资性黄金 or 客户标准黄金 (non-investment use or client withdrawal)
    Primary law

    • MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 point 1(2)-(3); SAT No. 23 points 3-4

  21. 48

    Report the change of use to the exchange before it happens and apply, once, within 6 months, to change the declared use; red-letter invoice reversal and re-issue

    Who
    SGE comprehensive member (producer, processor, jeweller or trader)
    Issues
    Application to change declared use (investment / non-investment), once within 6 months
    Primary law

    • MOF/SAT Announcement 2025 No. 11, Point 8

  22. 49

    Sell onward (bars or jewellery) charging VAT at 13%; gold jewellery also bears consumption tax of 5% at retail, on the sales value excluding VAT

    Who
    SGE institutional client (e.g. jewellery manufacturer) trading through a member
    Primary law

    [unconfirmed] Later changes to the consumption-tax rate table not checked.

    • VAT Law; Consumption Tax Regulations; Caishui [1994] 95, VAT Law art. 10(1); Consumption Tax rate table item 4.1; Caishui [1994] 95 points 1-2, 7

Taxes and fees

  • Consumption tax on gold jewellery

    5% Gold jewellery at retail

    Primary lawAmount not confirmed

    • Consumption Tax Regulations; Caishui [1994] 95, Rate table item 4.1; Caishui [1994] 95 points 1-4, 7

  • Export of gold-containing goods: VAT-exempt without refund

    VAT-exempt (no export refund; input VAT not refunded) Goods containing gold or platinum listed in annex 8, incl. HS 71081100, 71081200, 71081300 and 71082000; diamonds and diamond jewellery

    Primary law

    • MOF/SAT Announcement 2026 No. 11, Art. 6(1)1(4)

  • No export VAT rebate on gold

    No rebate on gold; for gold jewellery only the processing value added is rebated

    Primary law

    • Caishui [2002] 142 point 3, replaced by Guoshuifa [2005] 125, Point 3

  • Import customs duty on unwrought gold (HS 7108)

    Unverified

  • Import-stage VAT on gold and gold ore

    Exempt Imported gold (incl. standard gold) and gold ore

    Primary lawAmount not confirmed

    • Caishui [2002] 142, Point 1

  • VAT on standard gold sold off-exchange

    13% (standard VAT rate on goods) Standard gold not sold through SGE or SHFE

    Primary lawAmount not confirmed

    • MOF/SAT Announcement 2025 No. 11 point 2; VAT Law, 2025 No. 11 point 2; VAT Law art. 10(1)

  • Earlier VAT regime for SGE members' sales of standard gold (Caishui [2002] 142 point 2)

    No physical delivery: exempt; physical delivery: the tax authority issued a special invoice at the actual price and VAT was levied and immediately refunded, with urban construction tax and education surcharges exempt (for sales through the exchange with its settlement voucher)

    Primary law

    • Caishui [2002] 142, Point 2

  • VAT on standard gold withdrawn by a member for investment use

    VAT levied and immediately refunded to the exchange (即征即退), urban construction tax and education surcharges exempt; the exchange issues the member a special invoice (label 会员单位投资性黄金) whose VAT the member deducts; the member's onward sales carry ordinary invoices only Member withdrawals for direct sale or processing into 99.5%+ bars, ingots or legal gold coins

    Primary law

    • MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 points 1(1), 5; SAT No. 23 point 2

  • VAT on SGE / SHFE trades of standard gold without physical delivery

    Exempt: the seller's sale to the exchange, and the exchange's sale while no physical delivery takes place; the buyer receives a settlement invoice (结算发票) Standard gold (AU99.99/99.95/99.9/99.5; 50 g, 100 g, 1 kg, 3 kg, 12.5 kg) traded on the exchange

    Primary lawAmount not confirmed

    • MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 point 1; SAT No. 23 point 1

  • VAT on standard gold withdrawn for non-investment use or by a client

    Exempt at the exchange (ordinary invoice); general-taxpayer buyer deducts input VAT at 6%; onward sales taxed normally with special invoices Jewellery, industrial and other non-investment uses; all client withdrawals

    Primary lawAmount not confirmed

    • MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 point 1(2)-(3); SAT No. 23 points 3-4

  • VAT on producers' sales of non-standard gold and gold ore

    Exempt Sales of gold other than standard gold, and gold ore (incl. associated gold), by gold producers and dealers

    Primary lawAmount not confirmed

    • Caishui [2002] 142, Point 1

  • VAT on gold producers' and dealers' sales of non-standard gold and gold ore (2026-2027)

    Exempt Sales of gold other than standard gold (AU9999, AU9995, AU999, AU995 in 50 g, 100 g, 1 kg, 3 kg, 12.5 kg) and of gold ore (incl. associated gold) by gold producers and dealers

    Primary lawAmount not confirmed

    • MOF/SAT Announcement 2026 No. 10, 二(二)24

Controls

  • No permit is needed for processing trade, for movements between special customs supervision areas/bonded sites and abroad or between such areas, or for repair, return and temporary import/export; Customs supervises them.

    Primary law

    • Gold and Gold Products Import/Export Measures, Art. 20

  • Special preventive measures: for persons on the counter-terrorism list, the Foreign Ministry notices implementing UN Security Council targeted financial sanctions, and the PBoC high-risk list, institutions must immediately stop services and restrict transfers of funds and assets and report to the PB…

    Primary law

    • AML Law 2024; PBoC PM AML Measures; Anti-Foreign Sanctions Law, AML Law art. 40; Measures art. 27; AFSL arts. 11-12

  • Mining without a mining right: ordered to stop; confiscation of tools, equipment and the minerals taken; fine of 3 to 5 times the market value of the minerals illegally extracted, or RMB 100,000 to 1,000,000 where nothing was extracted or the value is under RMB 100,000; suspension if the activity co…

    Primary law

    • Mineral Resources Law 2024, Art. 64

  • Dealers in precious-metal spot trading are specific non-financial institutions (AML Law art. 64(3)). Under the PBoC Measures (in force 1 Aug 2025) they must run AML controls, assess risk at least every 3 years, carry out CDD incl. beneficial owners on cash of RMB 100,000 or more, report large cash t…

    Cash of RMB 100,000 single or daily cumulative (Measures arts. 2, 15, 24)

    Primary lawAmount not confirmed

    • AML Law 2024; PBoC PM AML Measures; Import/Export Measures, AML Law arts. 34, 64; Measures arts. 2, 13-16, 24-26, 38; Import/Export Measures art. 22

  • SGE deposit and delivery accept only standard ingots/bars from SGE-accredited refiners, or from suppliers accredited by an SGE-recognised international market. The Delivery Rules (Annex 2) and the overseas criteria name LBMA Good Delivery refiners; overseas refiners can also be accredited directly (…

    Official guidance

    • SGE Detailed Delivery Rules; SGE Vault Measures; SGE Refiner Measures and Overseas Criteria, Delivery Rules Art. 11 and Annex 2; Vault Measures Art. 4; Overseas Criteria arts. 6, 19

  • Exports of unwrought gold are subject to the same PBoC qualification and per-batch permit; the export is VAT-exempt without refund (MOF/SAT 2026 No. 11 art. 6 and annex 8).

    Primary law

    • Gold and Gold Products Import/Export Measures, Arts. 3, 8

  • Foreign-exchange receipts and payments arising from gold imports and exports follow SAFE rules (Measures art. 23): current-account payments are unrestricted but need a genuine, lawful transaction basis checked by the bank and are made against valid documents (FX Regulations arts. 5, 12, 14); receipt…

    Primary law

    • Gold and Gold Products Import/Export Measures; FX Regulations, Measures art. 23; FX Regulations arts. 5, 9, 12, 14

  • Import and export of gold and gold products in the PBoC catalogue need a PBoC permit presented to Customs: one permit per batch, used within 40 working days, only for entities holding the PBoC qualification; the PBoC may restrict quantities for macro-economic reasons (art. 3). No other channel is la…

    Every batch

    Primary law

    • Gold and Gold Products Import/Export Measures; Customs Law, Measures arts. 3, 4, 8, 17, 21; Customs Law art. 24

  • Gold carried into China by travellers is not limited in quantity but must be declared to Customs; gold may be carried out only against a PBoC certificate or up to the quantity declared on entry (Gold and Silver Regulations arts. 25-26). The Import/Export Measures (art. 4) leave rules for individuals…

    Primary law

    • Gold and Silver Regulations (rev. 2011); Import/Export Measures, Regulations arts. 25-26; Measures art. 4

  • Qualified importers/exporters must help balance domestic physical supply; imported gold must be registered and first traded on the State Council-approved gold spot exchange (SGE).

    Primary law

    • Gold and Gold Products Import/Export Measures, Art. 6

  • Import and export of national gold reserves are handled only by the PBoC; gold coins (incl. commemorative) only by an institution the PBoC designates (Measures art. 5). Gold coins are minted and issued only by the PBoC (Gold and Silver Regulations art. 21).

    Primary law

    • Gold and Gold Products Import/Export Measures, Art. 5

Leg 5: Switzerland

Back in the origin country: the proceeds of the export

  1. 50

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

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

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

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

  2. 51

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

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

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

  3. 52

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

    Who
    Swiss bank (bullion buyer)
    Issues
    Settlement confirmation / custody account entry; Allocated account weight list (specific bars = ownership) or unallocated account statement (contractual claim only)
    Secondary
  4. 53

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

    Who
    Swiss bank (bullion buyer)
    Primary law

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

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

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

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

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

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

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

Crossings between countries

  • Switzerland → United States Researched

    Papers that cross: Passar export declaration (HS 7108); Veranlagungsverfuegung Ausfuhr; Air waybill (outbound)

  • United States → Russia Not researched

    Papers that cross: CBP Form 3461 entry / immediate delivery (or ACE electronic equivalent); CBP Form 7501 entry summary (HTSUS classification, origin, duties and fees); CBP release of entered goods (ACE cargo release); Delivery record airport to refinery or depository; Chain-of-integrity receipt at depository; Depository inspection, weight record and eligible-stock entry; EEI/ITN for re-export of foreign-origin gold

  • Russia → China Researched

    Papers that cross: FPP application for import control; Act of state control on import; EAEU goods declaration for import / customs processing; Minfin conclusion (permissive document) approving an export-licence application (Order 10n from 1 Sep 2026); EAEU export licence issued by Minpromtorg (one-off or general); Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK; Calculation of the value of precious metals in the consignment; Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber; Export goods declaration (accepted and released by customs); Certificate of origin (general form) for non-EAEU destinations; Packing list; Air waybill

Paperwork gaps

  • ru.st-31 expects Assay certificate (fineness and fine weight); the earlier legs don't model this paper