Sudan [private exporter (legal person), since 5 Nov 2025] → Russian Federation → United Arab Emirates · Reconcile assays and pay the balance

Where the goods start

Doré bar - unstamped → Doré bar - stamped/exporter-sealed

• Royalty (al-'awa'id al-jalila) on traditional (artisanal) gold mining

  10% of the product (in gold or cash); alternatively 20% of the ore produced Traditional (artisanal) gold mining under a traditional mining contract

  Primary lawAmount not confirmed

  • Traditional Gold Mining Regulation 2016, art.8; Schedule (art.20)

• Corporation tax on gold companies

  18% (reduced from 28%, 2024); USGS 2019 reported 15%

  SecondaryAmount not confirmed

• Royalty on gold (concession companies)

  5-7% of mineral value (2019 policy)

  SecondaryAmount not confirmed

  • Regulation on the Exploitation of Minerals 2016, arts.13(6), 15

• Community (social) responsibility contribution on gold producers

  4% in kind of tailings companies' gold output; 1% in cash of concession companies' gold production value (based on the previous year's output)

  Primary lawAmount not confirmed

  • MoF Decision No. 90 of 2021, ثالثاً

• Fee for transferring artisanal gold from mining areas to city markets

  Waived (2024)

  Secondary

• Licence and contract fees

  MMDA Schedule (SDG): mining contract application 3,000, issue 15,000, transfer/assignment 50,000; small mining contract 3,000 / 10,000 / 50,000; traditional mining contract application 3,000, issue 7,000, regularisation 40,000, new contract 15,000; certificates 100 (samples up to 20 kg), 500 (ore export), 200 (other). Traditional Gold Mining Regulation Schedule (SDG): traditional mining licence 3,000; contract fee 7,000 (well), 50,000 / 150,000 / 250,000 (small / medium / large pit); sieve licences 10,000 / 50,000 / 100,000; miner card 100. Exploitation Regulation 2016 (EUR): ore export certificate 500; sample export 100 per 20 kg; tailings-processing contract signing bonus and renewal SDG 5,000,000 each.

  Primary lawAmount not confirmed

  • MMDA 2015, s.20(1); Schedule

• Implicit levy: CBOS indicative price set USD 10/oz below the international price

  USD 10 per troy ounce

  Official guidanceAmount not confirmed

  • CBOS Circular 13/2026, items 1-3

• State share in concessions

  30% of concessions (reported); plus a reported '40% tax on any gold sold' (unexplained)

  SecondaryAmount not confirmed

  • MMDA 2015 s.27أ (2023); Circular 2/2025 ثالثاً

• Dealers in metals or precious stones are "non-financial institutions" under the AML/CFT Act 2014 when they conclude cash transactions above a threshold the Minister sets by decision (s.3): customer due diligence (s.5), record keeping and suspicious-transaction reports to the Financial Information Un…

  Cash transactions above the Minister's threshold (not found)

  Primary law

  • Anti-Money Laundering and Counter-Terrorist Financing Act 2014, s.3, s.5, s.6

• EU ban on selling, supplying, transferring or exporting mercury (CN 2805 40) and sodium cyanides (CN 2837 11) to Sudan, with related services; humanitarian exceptions; sodium cyanide contracts concluded before 15 Jul 2026 may be executed until 16 Jan 2027.

  Primary law

  • Council Regulation (EU) 2026/1724, art.1b

• Banks may not finance the purchase of gold and its tailings (CBOS 2026 policies, list of prohibited financing, item vii "شراء الذهب ومخلفاته"). Gold buyers and exporters must use own funds or foreign advance payments.

  Official guidance

  • CBOS monetary and financial policies for 2026

• Sudan is an active conflict zone with both SAF and RSF financing themselves from gold; downstream refiners following OECD/LBMA due diligence must treat all Sudanese gold as high-risk, including gold from state-owned producers now under UK sanctions. Sudan itself has no conflict-minerals law found.

  Secondary

• 2014 version: banks may not complete gold export banking procedures for any company exporting gold, including mining and tailings companies, without CBOS prior written approval (Circular 11/2014). Superseded in substance by the 2025-2026 approval rules (sd.ctl-export-approvals-2025).

  Official guidance

  • CBOS Circular 11/2014

• 14 Sep - 5 Nov 2025 (Circular 14/2025): purchase of free (artisanal) and tailings gold inside Sudan reserved to CBOS or its delegate; export reserved to CBOS alone and banned for any natural or legal person; purchases executed by Sudan Gold Refinery. Concession and small-mining companies stayed unde…

  Official guidance

  • CBOS Circular 14/2025, ثانياً 1-4

• Concession companies may export 70% of the output remaining after in-kind deduction of the government's zakat, royalty and profit shares, and must sell the other 30% to CBOS or its delegate whether or not they export; small-mining companies likewise (Circular 2/2025 ثالثاً). Earlier versions: …

  30% of net output (after in-kind government shares)

  Official guidanceAmount not confirmed

  • CBOS Circular 2/2025, ثالثاً-1(ب), ثالثاً-2(د)

• Every person entering or leaving Sudan must declare to customs the currency and bearer negotiable instruments carried, at amounts set by regulations (AML/CFT Act 2014 s.31(1)); customs may seize them on suspicion or false declaration (s.32); breach of s.31 is punished by a fine equal to twice the am…

  Primary law

  • Anti-Money Laundering and Counter-Terrorist Financing Act 2014, s.31, s.32, s.38(4)

• EU ban on purchasing, importing or transferring, directly or indirectly, gold (CN 7108, 7112 91, ex 7118 90) that originates in Sudan and was exported from Sudan into the EU or any third country after 15 July 2026, and on related technical assistance, brokering, financing and financial assistance. E…

  Primary law

  • Council Regulation (EU) 2026/1724, art.1a

• Approvals banks must see before completing a gold export: concession and small-mining gold - CBOS written approval, an SSMO certificate and a Ministry of Minerals export-approval certificate (Circular 2/2025 ثانياً); tailings gold - CBOS written approval (17/2025 ثالثاً-5; restated by 18…

  Official guidance

  • CBOS Circulars 2/2025 and 17/2025

• Free and tailings gold may be exported by any legal person (شخص اعتباري) after all export procedures (Circular 17/2025 ثالثاً-1); exports by government bodies and by foreigners, individuals or companies, are banned except concession companies in gold mining (خامساً-4). Individu…

  Official guidance

  • CBOS Circular 17/2025, ثالثاً-1; خامساً-4

• No export, including export for manufacture and return, of precious metals or gemstones as bars or jewellery without hallmarking by SSMO's Hallmarking and Precious Metals Control Department as regulations provide; imports need the Department's approval, assay and hallmark unless a mutual-recognition…

  Primary law

  • Precious Metals and Gemstones Act 2008, s.20; s.7

• 2014 directions: raw gold exports prohibited and company exports refined at the Khartoum refinery (historical). Current texts: CBOS purchases are executed by Sudan Gold Refinery with fineness set by SSMO (Circular 2/2025 رابعاً; 14/2025 ثانياً-4); exporters must comply with Sudan Gold Re…

  Official guidance

  • CBOS Circular 17/2025, خامساً-1

• Minimum gold export contract 10 kg "or as MoIT decides" (Circular 17/2025 خامساً-2, from 5 Nov 2025); replaced on 13 May 2026 by a 1 kg minimum for free-gold export contracts (Circular 11/2026 item 3).

  1 kg per free-gold contract since 13 May 2026 (10 kg, 5 Nov 2025 - 12 May 2026)

  Official guidanceAmount not confirmed

  • CBOS Circular 11/2026, item 3

• Payment by advance payment or by confirmed sight documentary credit whose terms contain no condition on the goods such as overseas assay ("calibration"); L/C proceeds on acceptance of documents and at most 30 days from shipment (Circular 17/2025 ثالثاً-2; same for small-mining companies under …

  Official guidance

  • CBOS Circular 17/2025, ثالثاً-2

• CBOS prices gold for export daily at the international 24-carat price less USD 10 per ounce, in USD per gram, announced on the XAR system to MoIT and the unified gold export window; exporters are settled at this price and no shipment passes if the proceeds fall below the value at the announced price…

  Official guidance

  • CBOS Circular 13/2026, items 1-3

• L/C proceeds within 30 days of shipment (17/2025 ثالثاً-2). Proceeds are credited to a "gold export account" in the exporter's name and may stay there at most 21 working days, after which the bank buys them for CBOS at its announced rate (ثالثاً-3). Free-gold proceeds may be used for the…

  30 days from shipment; 21 working days in the gold export account; 21 working days in the import account

  Official guidanceAmount not confirmed

  • CBOS Circulars 17/2025, 11/2026 and 12/2026, 17/2025 ثالثاً-2, ثالثاً-3

• Offences (MMDA s.32(1)): exploring without a licence - up to 2 years (أ); extracting without a mining contract - up to 3 years (ب); withholding production data - up to 5 years (ج); false information - fine of at least SDG 100,000 (د); transporting, exporting, storing, possessing or dealing in mi…

  Primary law

  • MMDA 2015, s.32(1), s.32(2), s.33

• 13 May - 21 Sep 2026: CBOS bought 100% of tailings (mining-waste) companies' gold at its announced price after in-kind deduction of profits and royalties from total production (Circular 11/2026 item 2). Cancelled and replaced on 21 Sep 2026 by Circular 18/2026 (see sd.ctl-tailings-sale-2026-09).

  Official guidance

  • CBOS Circular 11/2026, item 2

• Since 21 Sep 2026 (replacing sd.ctl-tailings-100pct): tailings companies may sell all their gold to CBOS, its delegate or exporters; tailings gold may be exported by advance payment (priced daily by CBOS) or confirmed sight L/C with proceeds within 30 days of shipment; proceeds held in a gold export…

  Official guidance

  • CBOS Circular 18/2026, items 1-6

• The UAE, which took about 88-95% of Sudan's official gold exports, suspended trade with Sudan in August 2025, forcing a search for other buyers (Qatar refinery agreement, Egypt, Turkey, India, Hong Kong).

  Secondary

• UK asset freezes (16 Jul 2026) on three Sudanese state-owned mining companies - Omdurman Mining and Ariab Mining Company (suspected of generating gold revenue for the SAF) and Sudamin Company Ltd (suspected of channelling conflict-gold revenue to both SAF and RSF, incl. past links to Al Junaid) - pl…

  Official guidance

  • The Sudan (Sanctions) (EU Exit) Regulations 2020

• Transporting, exporting, storing, possessing or dealing in minerals or tailings whose source of production one does not own, without a licence or Ministry permission, is an offence (MMDA s.32(1)(هـ), added 2019; up to five years). Press reported that the Aug 2025 measures made holding undocumented…

  Primary law

  • MMDA 2015, s.32(1)(هـ)

• US designations under EO 14098: Al Junaid Multi Activities Co (RSF-controlled; gold mining and export since the 2017 takeover of Jebel Amer) on 1 Jun 2023; on 7 Jan 2025 RSF leader Hemedti and UAE companies incl. Al Zumoroud and Al Yaqoot Gold & Jewellers (bought Sudanese gold for the RSF and moved …

  Official guidance

  • Executive Order 14098

On the way

• 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)

• 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)

Where the goods arrive

• Customs duty on gold imports

  0% for goods entering a free zone (FZ Transit In); mainland imports of gold: 0% under the GCC exempted-commodities list (read via WebFetch only) Unwrought and semi-manufactured gold

  Official guidanceAmount not confirmed

  • Dubai Customs Customer Guide v3.03; GCC common customs law; UAE list of exempted commodities, Customer Guide s.9 (duty suspended for goods admitted into free zones), s.15.12.2

• Domestic reverse charge on precious metals and precious stones between registered businesses

  Recipient accounts for VAT Supplies of gold, silver, platinum, palladium, precious stones and jewellery made of them, for resale or production, between VAT-registered persons, with the buyer's written declaration (CD 127/2024, replacing CD 25/2018)

  Primary law

  • Cabinet Decision 127/2024; FTA VATP043, Art. 1 (Goods: precious metals - gold, silver, palladium, platinum - precious stones and jewellery mostly of them), Art. 2(1)-(4), Art. 4 (repeals CD 25/2018)

    “Precious Metals, Precious Stones and jewelry made of any Precious Metals or Precious Stones”

• Special reverse charge on gold and diamonds between registrants (Cabinet Decision 25/2018)

  Registered recipient accounts for VAT Gold and products mostly of gold not qualifying for zero-rating, and diamonds, supplied between registrants; exports of gold items and investment precious metals outside its scope (VATP029)

  Official guidance

  • Cabinet Decision No. 25 of 2018

• Import VAT

  5% standard; 0% for investment precious metals (99%+ purity, tradeable form) Doré is not investment gold, so it is standard-rated; refined bars of 99%+ are zero-rated

  Primary lawAmount not confirmed

  • Federal Decree-Law 8/2017 on VAT; Executive Regulation, Art. 3 (5%), 45(8), 48(1), 49; Exec. Reg. Art. 36(2), 48, 50(1)

    “a standard rate of 5% Tax shall be imposed on any supply or Import”

• Precious metals crossing the UAE border must be disclosed; declarations are also required for precious metals over AED 60,000 crossing through cargo, mail or shipments, cargo being declared through the official customs systems.

  AED 60,000

  Primary lawAmount not confirmed

  • Federal Decree-Law 10/2025; CBUAE Regulation on the Declaration of Currencies, BNIs, and Precious Metals and Stones (OG 703, 31 May 2021), FDL 10/2025 Art. 10 (duty to disclose, per the disclosure system issued by the ICP with the Central Bank), Art. 41(3) (regulations under FDL 20/2018 remain effective insofar as not conflicting), Art. 34 (penalty)

    “Any person entering into or departing from the State shall be under the obligation to make a disclosure whenever they carry currencies, bearer negotiable instruments, precious metals, or valuable stones, in accordance with the disclosure system issued by the Federal Authority for Identity, Citizenship, Customs and Port Security, in coordination with the Central Bank”

• Dealers in precious metals and stones are DNFBPs for any single cash transaction, or linked transactions, of AED 55,000 or more (CR 134/2025 Art. 3 item 3), and keep records for at least 5 years (Art. 25). The DPMSR report, including for dealings with companies of AED 55,000 or more paid in cash or …

  AED 55,000

  Primary law

  • Cabinet Resolution 134/2025; MoET Supplemental Guidance for DPMS 2026, CR 134 Art. 3(3), Art. 25(1); Guidance s.1.4.1

    “when carrying out any single cash transaction or several transactions that appear to be linked and whose value equals or exceeds fifty-five thousand dirhams (AED 55,000)”

• Supply-chain entities and precious-metals dealers must have due-diligence management systems, identify and assess supply-chain risks and adopt a risk-management strategy (Decree Art. 1(A)); refiners must also appoint an independent third-party auditor and submit a due-diligence report (Art. 1(B)), u…

  Primary law

  • Ministerial Decree 68/2024; MoE Due Diligence Regulations v1 (2022), Decree Art. 1(A), 1(B), Art. 3 (penalties under the AML law)

Back in the origin country: the proceeds of the export