Russian Federation [Licensed export (miner, refiner or bank)] → United Arab Emirates (refine) → Turkey (Türkiye) (refine) · Exchange trade, bank and retail sale

Extract gold ore or placer sands within the licensed plot

Who

Subsoil user (gold mining company)

Needs

Subsoil-use licence (electronic); Special-registration register entry (FPP)

Form

Ore (in situ / run-of-mine) → Concentrate / black sand

• Law 'On Subsoil', art. 11

Process on site (gravity, leaching, smelting) into dore bars or placer (shlikh) gold; the metal must then go to refining

Who

Subsoil user (gold mining company)

Issues

Batch number / GIIS UIN of the dore lot

Form

Concentrate / black sand → Doré bar - unstamped

Processing technology is industry practice; the law only requires "necessary processing" before refining.

• Federal Law 41-FZ, art. 20(1)

Sign a refining agreement with a listed refiner; it must set the delivery schedule and volumes, limits of harmful substances, the inventory of each lot, commission acceptance with control sampling, timing and specifications of the output, return-waste norms, the recipients of refined metal, the owner's delivery obligations to the State Fund or regional funds, liability and dispute settlement

Who

Subsoil user (gold mining company)

Issues

Refining (tolling) agreement miner-refiner

• Government Decree 972, Procedure para 3, para 3

Record the lot in GIIS DMDK and issue an electronic accompanying document (ESD) with the lot's UIN for dispatch to the refiner

Who

Subsoil user (gold mining company)

Needs

Batch number / GIIS UIN of the dore lot; Refining (tolling) agreement miner-refiner

Issues

ESD for dispatch of dore/placer gold to the refiner

[not-read] The GIIS DMDK Rules (Decree 270) were not read in full; the ESD fields for dore were not seen.

• Government Decree 270 of 26.02.2021

Transport dore to the refinery by air, sea, inland water, rail or a specialised equipped road vehicle under armed escort

Who

Secure carrier of valuables

Needs

ESD for dispatch of dore/placer gold to the refiner

• Federal Law 41-FZ, art. 29(3)

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)

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

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)

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

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

[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)

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

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

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

[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

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

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)

Pre-contract KYC on the Nigerian exporter: corporate docs, UBO, MBC/export-permit evidence, mine-of-origin declaration

Who

DMCC importer / trader

Needs

Bank-to-bank reference confirmation (not a public letter) on the Nigerian exporter

Issues

Importer's KYC/due-diligence pack on the Nigerian exporter; Evidence pack from the Nigerian exporter: export licence/permit, mine location, legal existence of the ASM operation

[conflict] For an ordinary DMCC trader the binding CDD duties are those of CR 134/2025 (Arts. 5-14); DMCC RBD-GPM binds only its Accredited Members (see ae.div-dmcc-role). [inferred] "Highest-scrutiny category" for ASM is the model's reading of Rule 1.6, not a phrase in the Rules.

• DMCC RBD-GPM Rules v2/2020; Cabinet Resolution 134/2025, DMCC Rules 1.4-1.8 (KYC; Rule 1.6 specific requirements for ASM supply), Rules 2.4-2.8 (red flags); CR 134 Art. 25(1) (records at least 5 years)

File the Dubai Customs declaration on Mirsal 2 with invoice, packing list, certificate of origin and air waybill (for a free-zone consignee the Customer Guide's 'FZ Transit In' type appears to apply, not import to local); disclose the precious metals crossing the border

Who

DMCC importer / trader

Needs

Air waybill; Certificate of origin; Origin country's export authorisation for the gold (permit, licence or clearance issued by the mining or trade authority); Commercial invoice; Packing list

Issues

Dubai Customs declaration filed online (for goods entering a free zone: "FZ Transit In"); Disclosure of precious metals crossing the UAE border (cargo included)

No UAE import permit for gold: Dubai Customs lists DMCC as restricting authority only for "Pearls, Diamonds, Rough Diamonds etc." (Customer Guide App. I). FZ Transit In (s.15.12.2): "foreign goods originated from any country may be brought into the free zones without being subject to customs duties or taxes. The owner of the goods in the Documents shall be a Free Zone Licensee"; documents MAWB/HAWB, commercial invoice, certificate of origin, packing list, delivery order. Mainland duty: the GCC exempted list's gold line is printed "71060000" (silver's heading) [summary][blocked]. Cross-border disclosure: see ae.doc-pm-disclosure-ae. [unconfirmed] Neither Dubai Customs guide names the declaration type for gold into a DMCC company or the DMCC Vault. [conflict] Supporting documents are due within 14 days (Customer Guide s.15.7) or 30 days (Service Guide v9 App. A) - see ae.div-customs-doc-deadline. KPMG (secondary): periodic "Goods Consumption within FZ" declaration under Dubai Customs Notice 17/2020.

• Dubai Customs Customer Guide v3.03; Dubai Customs Service Guide v9; Federal Decree-Law 10/2025, Customer Guide s.15.12.2 (FZ Transit In), App. J (DMCC declarations at the Customer Service Center at DMCC); FDL 10/2025 Art. 10 (cross-border disclosure)

Import VAT: registered importer accounts for VAT on its own return (reverse charge); investment-grade gold is zero-rated, doré is not

Who

DMCC importer / trader

Issues

Import VAT accounted on the importer's own VAT return (registered importer)

Investment precious metals = gold, silver or platinum of 99% purity or more, in a form tradeable in global bullion markets (ER Art. 36(2), not amended in the consolidation to CD 100/2025); their supply or import is zero-rated (Art. 45(8)). [inferred] Doré below 99% does not qualify. [unconfirmed] DMCC's absence from the Designated Zones was checked only against the 2017 list (secondary copy). [not-read] FDL 16/2025 amendments (from 1 Jan 2026) not held.

• Federal Decree-Law 8/2017 on VAT; Executive Regulation (Cabinet Decision 52/2017, as amended; consolidated to CD 100/2025), Law Art. 45(8), 48(1), 49; ER Art. 36(2), 48(1), 48(5), 50(1)

If the importer sells the doré to the refiner (rather than toll-refining it): refiner gives two written statements before supply; importer issues a tax invoice without VAT (reverse charge)

Who

DMCC importer / trader

Issues

Refiner's two written statements: VAT-registered, and buying to resell or use in production; Tax invoice without VAT for the importer-to-refiner sale

[inferred] Conditional: the model reads the reverse charge as not applying where the refiner only toll-refines metal the importer keeps title to; the sources read do not address toll refining.

• Cabinet Decision 127/2024; VAT Executive Regulation, CD 127 Art. 2(1), 2(3) (two written declarations before supply; supplier keeps them and verifies registration), 2(4) (no declarations: no reverse charge); ER Art. 59(1)(l)

Refiner performs its own CDD on the supplier; third-party audit, assurance or certification reports are supporting evidence only, and the relationship must stop if CDD cannot be completed

Who

Dubai refiner (UAEGD-accredited)

Needs

Importer's KYC/due-diligence pack on the Nigerian exporter; Evidence pack from the Nigerian exporter: export licence/permit, mine location, legal existence of the ASM operation; Air waybill

Issues

Refiner KYC and custody file: supplier identity/constitution/licence/UBOs, PEP approval, invoices, declared weight and assay, unique input/output references, transport documents, arrival and assay-final dates, payment details (kept 5 years); Red-flag assessment by location of origin and by supplier

• UAE MoE Due Diligence Regulations v1 (2022); Ministerial Decree 68/2024; EBC Rules for RBDG v1/2021, Regs s.1.3.1-1.3.7, 1.3.6 (cease if CDD cannot be done), 1.3.10 (records 5 years), 1.5 (own KYC; third-party audits only supporting evidence), 2.1-2.2; Decree Art. 1(A)-(B); EBC Rules 1.6-1.14

Weigh-in, seal-check, sample, fire-assay the doré

Who

Dubai refiner (UAEGD-accredited)

Needs

Refining agreement, Dubai refiner; Refiner KYC and custody file: supplier identity/constitution/licence/UBOs, PEP approval, invoices, declared weight and assay, unique input/output references, transport documents, arrival and assay-final dates, payment details (kept 5 years); Pre-shipment notification to refiner/buyer

Issues

Refiner outturn/assay report

Specific weighing/sampling/fire-assay methodology not published in any UAE-specific source found

Melt, refine and cast to 995.0 or 999.9 bars, marked with serial number, the refiner's hallmark/brand stamp, fineness to four significant figures and weight (year optional, otherwise on the manufacturer's certificate)

Who

Dubai refiner (UAEGD-accredited)

Needs

Refiner outturn/assay report

Issues

Manufacturer certificate accompanying UAEGD bars (states year of manufacture if not stamped); Output record: unique reference, refiner name and stamp, year for each bar

Form

Doré bar - stamped/exporter-sealed → Pre-refined 995 bar (e.g. 'Dubai 995')

[unconfirmed] Refining method (Miller chlorination) is not in the UAEGD Rules or RBDG Rules.

• EBC UAE Good Delivery Accreditation Rules v1/2021, s.7.1 (bar marking)

Refiner appoints an independent third-party auditor and submits the due-diligence report to the MoE (Decree 68/2024 Art. 1(B)); the Reviewer sends its reports to the MoE within 90 calendar days of the end of the review period (DD Regulations Annex I s.12.1). UAEGD (EBC) and DMCC Accredited Members also publish an annual report (EBC Rules / DMCC RBD-GPM Rule 5.1).

Who

Dubai refiner (UAEGD-accredited)

Issues

RBD-GPM annual disclosure; MoET responsible-sourcing audit report

The EBC and DMCC reporting duties are rules of those bodies (official-guidance) and bind their Accredited Members only. [conflict] DMCC accreditation status after 2021: see ae.div-dmcc-role.

• Ministerial Decree 68/2024; MoE Due Diligence Regulations v1; EBC Rules for RBDG v1/2021; DMCC RBD-GPM v2/2020, Decree Art. 1(B); Regulations Step 5, Annex I s.12.1; EBC Rules Rule 5.1; DMCC Rules Art. 3.1, Rule 5.1

Deposit refined bars into DMCC Vault (operated by Brink's)

Who

DMCC Vault (operated by Brink's)

Needs

Manufacturer certificate accompanying UAEGD bars (states year of manufacture if not stamped)

Issues

DMCC Vault deposit/withdrawal receipt; DMCC Tradeflow warrant (optional; used for pledging and title transfer)

DMCC: the Vault is "Owned by DMCC and operated by Brink's Global Services" and "DMCC can assist with all customs processes". [not-read] Deposit/withdrawal documents and any bonded status of the Vault are not published; the receipt document is inferred.

Obtain a Certificate of Origin from Dubai Chambers: a non-preferential certificate for UAE-origin goods (goods produced in the UAE by a licensed exporter; copy of the industrial licence and the factory's invoice) or a certificate for foreign goods re-exported

Who

DMCC importer / trader

Needs

Refiner outturn/assay report

Issues

UAE Certificate of Origin / re-export documentation (Dubai Chambers)

Unresolved: whether refining doré into bars confers UAE origin - both can sit in HS 7108.12 and no gold-specific rule was found; CR 43/2022 Art. 4 also allows "specific manufacturing operations". India's Noida SEZ SOP treats gold bars sourced from the UAE as not UAE-originating (see ae-in). Fee AED 100, two hours (Dubai Chambers service page; the Resolution sets no amount). [summary][blocked] FL 11/2019 and CR 43/2022 read through WebFetch only (downloads Cloudflare-challenged).

• Federal Law 11/2019; Cabinet Resolution 43/2022; Dubai Chambers Resolution 7/2024, FL 11/2019 Art. 4 (minimal operations do not confer origin), Art. 6 (issue of certificates; the Chamber issues certificates for re-exported foreign commodities); CR 43/2022 Art. 4 (last major operation, incl. "a change in the customs item or ... specific manufacturing operations"); DC Res. 7/2024 Art. 2 (types), Art. 3(a) (conditions), Art. 3(b) (UAE-origin certificate only for goods produced in the UAE by an exporter licensed by the Competent Entity), Art. 4 (electronic application), Art. 6 (valid six months), Art. 7 (register kept 3 years)

File Dubai Customs export/re-export declaration; VAT zero-rated on export

Who

DMCC importer / trader

Needs

UAE Certificate of Origin / re-export documentation (Dubai Chambers)

Issues

Dubai Customs export/re-export declaration

• Federal Decree-Law 8/2017 on VAT; VAT Executive Regulation; Cabinet Decision 127/2024; Dubai Customs Customer Guide v3.03, DL 8/2017 Art. 45(1) (exports zero-rated); ER Art. 30 (export within 90 days, with customs declaration and commercial evidence); CD 127/2024 Art. 2(2) (no reverse charge on zero-rated supplies); Customer Guide s.15.12.3 (FZ Transit Out; penalty 10% of value without proof of export), s.16 (proof of export by air)

Book air cargo as valuable/secure freight (specialist carrier), security clearance, sealed/inspected shipment at DXB/DWC

Who

Secure logistics provider (UAE/air legs)

Needs

Dubai Customs export/re-export declaration

Issues

Air waybill, Dubai -> Zurich/Geneva

CAR VII has nothing gold-specific; booking as valuable/secure freight with a specialist carrier is practice. [inferred] Road leg to the airport in Dubai needs a SIRA Money and Valuables Transport licence.

• GCAA CAR Part VII Ed. 05; SIRA Resolution 1/2018, CAR VII 4.6.1 (security controls on cargo), 4.6.6 (operators accept cargo only with security controls confirmed), 4.6.7 (security status accompanies cargo); SIRA Res. Art. 3(a)(6)

Run know-your-counterparty and responsible-supply checks on the foreign supplier and the metal (zero tolerance); imported standard bars (other than under inward processing) must come from a refinery on the Borsa İstanbul Refinery List and bear its seal, name or emblem

Who

Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)

Needs

Ministry operating licence - precious-metals intermediary institution (Faaliyet İzin Belgesi); Borsa İstanbul Membership Certificate (Borsa Üyelik Belgesi); Refiner's certificate for the bars it produced (serials, fineness, weights, year); Refiner's responsible-sourcing / due-diligence compliance report or audit; Bar list (serials, weights, fineness)

Issues

Customer identification and KYC file (Law 5549 Art 3; ROM Art 5; zero-tolerance know-your-counterparty rule of the exchange)

• Tebliğ 2008-32/34 Art 6(4); Procedure 31.PRO.11 s. 2.2.2, 2.2.6.1, Tebliğ 2008-32/34 Art 6(4)

Confirm the month's import quota allocation covers the shipment

Who

Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)

Needs

Monthly unwrought-gold import quota allocation

[not-read] The quota decision is not published; the Ministry letter held (April 2024) states the 12 t monthly quota from 07.08.2023. [summary] How the allocation is checked at import, and the exclusion of inward-processing imports, come from press and a customs broker.

• Ministry quota (from 07.08.2023) under Tebliğ 2008-32/34 Art 6(11) and Regulation of 2007 Art 24

Notify the exchange via the Single Window System (TPS) with the Pre-importation Notification Form (Annex-3) at least 1 business day before the closing date of the customs declaration (3 business days for import with waiver), stating payment method and purpose; for intermediated imports add the customer's name and identity/tax number and the brokerage contract

Who

Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)

Needs

Customer identification and KYC file (Law 5549 Art 3; ROM Art 5; zero-tolerance know-your-counterparty rule of the exchange)

Issues

Borsa İstanbul Pre-importation Notification Form (Procedure Annex-3) submitted via the Single Window System (TPS)

• Regulation of 2007 Art 12/A(1); Procedure 31.PRO.11 s. 2.2, 2.2.2, 2.2.3.3, Regulation Art 12/A(1)

Pay the foreign supplier by one of the permitted methods: cash in advance (payment documents to the exchange before the declaration closes), payment against goods (proof of payment to the exporter within 60 days of the declaration closing) or free of payment (only for inward processing, capital contribution, or offset against export proceeds)

Who

Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)

Needs

Borsa İstanbul Pre-importation Notification Form (Procedure Annex-3) submitted via the Single Window System (TPS)

Issues

Bank transfer record

• Tebliğ 2008-32/34 Art 6(6)-(7); Regulation of 2007 Art 12/A(4)-(7), Tebliğ 2008-32/34 Art 6(6); Regulation Art 12/A(5)-(6)

Clear customs on arrival: the import declaration for unwrought gold is enough and the import regime is not applied; only the CBRT and intermediaries may declare it; intermediated imports show the customer on the declaration; non-standard metal needs a Mint assay report; bullion import is VAT-exempt

Who

Secure logistics carrier / customs broker

Needs

Borsa İstanbul Pre-importation Notification Form (Procedure Annex-3) submitted via the Single Window System (TPS); Air waybill; Commercial invoice; Packing list; Export customs declaration accepted by the dispatching country's customs

Issues

Turkish customs import declaration (HS 7108)

[unconfirmed] No text held requires a certificate of origin for unwrought gold imports; the customs regulation was not read (tr.gap-origin-cert).

• Decree 32 Art 7(2)(a)-(b); Regulation of 2007 Art 12/A(2); Tebliğ 2008-32/34 Art 6(3); VAT Law Arts 16(1)(a), 17(4)(g), Decree 32 Art 7(2)(a)-(b)

Deliver all imported standard and non-standard unwrought gold to Borsa Istanbul within 3 business days

Who

Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)

Needs

Turkish customs import declaration (HS 7108)

Issues

Allocated-account weight list or unallocated account statement

• Decree 32 Art 7(2)(b); Procedure 31.PRO.11 s. 2.2.6-2.2.7, Art 7(2)(b)

The exchange checks the metal and documents: information notified via TPS may not differ from the customs declaration by more than 2% in weight or 10% in value, otherwise the metal is returned to the country of origin and the Ministry informed; non-standard metal comes sealed by the Mint with its calibration analysis report

Who

Borsa Istanbul Precious Metals and Diamond Market (clearing house for metal, custody vault)

Needs

Turkish customs import declaration (HS 7108)

Issues

Borsa Istanbul vault Control Form (Annex-1) and vault deposit entry; Mint (Darphane) assay report (ayar raporu / calibration analysis report) for non-standard unwrought metal

• Regulation of 2007 Art 12/A(3); Procedure 31.PRO.11 s. 2.2.2, 2.2.6.2; Tebliğ 2008-32/34 Art 6(3), Regulation Art 12/A(3)

For non-standard metal, deliver it to the vault with the Post-import Notification Form (Annex-2) and the Mint report

Who

Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)

Needs

Borsa Istanbul vault Control Form (Annex-1) and vault deposit entry

Issues

Borsa İstanbul Post-import Notification Form (Procedure Annex-2) - non-standard metal

• Procedure 31.PRO.11 s. 2.2.6.2

Make the first sale of imported metal on the Borsa Istanbul Precious Metals Market

Who

Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)

Needs

Allocated-account weight list or unallocated account statement

Issues

Borsa Istanbul trade and settlement record (metal via exchange clearing, money via Takasbank)

• Decree 32 Art 7(6); Procedure 31.PRO.11 s. 2.2.6, Art 7(6)

Accept doré, scrap or non-standard metal after supplier KYC and responsible-supply due diligence

Who

Ministry-licensed Turkish refinery on the Borsa Istanbul refinery list (two also LBMA Good Delivery)

Needs

Refinery Operating Licence (Rafineri Faaliyet İzin Belgesi), per metal; Entry on the Borsa Istanbul List of Refineries; Customer identification and KYC file (Law 5549 Art 3; ROM Art 5; zero-tolerance know-your-counterparty rule of the exchange); Assay certificate (fineness and fine weight)

• Tebliğ 2023/1 Art 10(2); Law 5549 Art 3; Directive on the Responsible Supply Chain Assurance Engagement, Tebliğ 2023/1 Art 10(2)

Refine to standard (gold at least 995/1000) and cast bars marked with fineness stamp, refinery emblem or stamp and fineness, "GOLD" or "AU", and (above 1 kg) the year or month and year; bars of 10 g or less may carry the serial number on the package; tradable sizes 1-500 g mini bars, 1 kg bars and larger bars

Who

Ministry-licensed Turkish refinery on the Borsa Istanbul refinery list (two also LBMA Good Delivery)

Issues

Bar list (serials, weights, fineness)

Form

Doré bar - stamped/exporter-sealed → 999.9 kilobar

• Tebliğ 2023/1 Art 4; Decree 32 Art 2(j)(i); Procedure 31.PRO.11 s. 2.1.1, Tebliğ 2023/1 Art 4(1)-(3)

Apply the KMTS security label/mark with its unique code to each standard bar and printed product during production (the labelling area under 24/7 camera recording) and activate the product record in KMTS (producer, date and place, weight, fineness, serial number); products not registered in KMTS cannot be sold

Who

Ministry-licensed Turkish refinery on the Borsa Istanbul refinery list (two also LBMA Good Delivery)

Needs

Bar list (serials, weights, fineness)

Issues

KMTS security label/mark and unique KMTS code

• Tebliğ 2023/1 Art 17(2), (4); KMTS procedures s. 5.1, 5.4, 5.5.3, Tebliğ 2023/1 Art 17(2)

Record each stock entry and exit in KMTS at the moment of movement against the shipping document

Who

Ministry-licensed Turkish refinery on the Borsa Istanbul refinery list (two also LBMA Good Delivery)

Needs

KMTS security label/mark and unique KMTS code

Issues

KMTS stock entry/exit record (against shipping document)

• Tebliğ 2023/1 Art 17(3); KMTS procedures s. 5(e), Tebliğ 2023/1 Art 17(3)

For gold from Turkish mines: refine in a Turkish refinery on the Borsa İstanbul list and deliver the standard gold to the exchange clearing centre within 7 business days of refining, with the ore notification form; the CBRT, and if it does not use it the Mint, has a pre-emption right; the metal is then traded on the exchange

Who

Domestic gold mining company (ore-produced metal)

Issues

Borsa İstanbul notification form for precious metals produced from ore (Procedure Annexes 23-26); Allocated-account weight list or unallocated account statement

Form

Doré bar - unstamped → 999.9 kilobar

• Tebliğ 2023/1 Art 14(1)(a), 14(3); Decree 32 Art 7(4)(ğ); Procedure 31.PRO.11 s. 9.2-9.3, Tebliğ 2023/1 Art 14(1)(a), (3)

  “ve bu işlemi müteakip 7 iş günü içinde Borsa Takas Merkezine teslim edilir”

Prepare the supply-chain compliance report by end of March and have it audited (reasonable-assurance independent report) by end of June; publish both and send them to the Ministry and, for listed refineries, to Borsa İstanbul (LBMA-listed refiners may use their LBMA assurance report)

Who

Independent assurance provider (ISAE 3000 responsible supply chain engagement)

Issues

Supply Chain Compliance Report and Independent Assurance Report (reasonable assurance, ISAE 3000 equivalent)

• Tebliğ 2023/1 Art 16(4), (7), (9); Directive on the Responsible Supply Chain Assurance Engagement Arts 33-34, Tebliğ 2023/1 Art 16(4), (7)

Pay the state royalty (Devlet hakkı) on gold at the Table (3) rate for the period's London average price, on the pit-head sale price, by the end of June; 40% is not collected on gold processed in the producer's own domestic plant

Who

Domestic gold mining company (ore-produced metal)

• Mining Law 3213 Arts 9, 14 and Table (3), Art 14; Table (3)

Hold metal in the Borsa Istanbul custody vault under a custody vault agreement, allocated or (where allowed) unallocated; the exchange is clearing house for metal

Who

Borsa Istanbul Precious Metals and Diamond Market (clearing house for metal, custody vault)

Needs

Borsa Istanbul custody vault agreement (Annexes 13, 16-17)

Issues

Allocated-account weight list or unallocated account statement

• Directive on Precious Metals Market Art 47; Regulation of 2007 Art 13(1)(e), Directive Art 47(1)

Move metal between accounts, or convert it, by ELTAS instruction

Who

Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)

Needs

Allocated-account weight list or unallocated account statement

Issues

ELTAS electronic instruction (vault deposit, withdrawal, transfer)

• Directive on Precious Metals Market

If unwrought metal from abroad is placed in a customs warehouse (only by the CBRT or an intermediary in its own name) or brought into a free zone instead of being released for free circulation, notify Borsa İstanbul in writing within 3 business days (Annex-39 form)

Who

Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)

Issues

Borsa İstanbul Precious Metals Customs Warehouse / Free Zone Entry Form (Procedure Annex-39)

• Decree 32 Art 7(2)(e)-(f); Procedure 31.PRO.11 s. 2.2 (Annex-39), Art 7(2)(e)-(f)

Trade on the Borsa Istanbul Precious Metals Market; metal settles on the exchange's books, money through Takasbank; settlement T+0 to T+120

Who

Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)

Needs

Allocated-account weight list or unallocated account statement

Issues

Borsa Istanbul trade and settlement record (metal via exchange clearing, money via Takasbank); Allocated-account weight list or unallocated account statement

• Directive on Precious Metals Market

Identify the customer and beneficial owner before the transaction (any amount in a continuing relationship; 185,000 TL or more for occasional transactions); banks trade only precious metals traded on exchanges or meeting Treasury/Borsa İstanbul standards, and value physical gold collected for gold accounts at minimum millesimal values (0.995 for 24-carat Mint and listed-refinery products, 0.992 for other 24-carat products)

Who

Bank that is a Borsa Istanbul Precious Metals Market member

Issues

Customer identification and KYC file (Law 5549 Art 3; ROM Art 5; zero-tolerance know-your-counterparty rule of the exchange)

• Law 5549 Art 3; ROM Art 5(1); BDDK regulation on banks' precious-metals trading Art 4, ROM Art 5(1); BDDK regulation Art 4

Sell to the buyer with an invoice; the jeweller must hold a Ministry of Trade authorisation certificate; collections and payments above 30,000 TL (including from non-taxpayer buyers) go through a bank, payment institution or PTT, except with foreigners or non-residents

Who

Authorised jewellery business (kuyum işletmesi with a Ministry of Trade yetki belgesi) - manufacturer, exporter or retailer

Needs

KMTS security label/mark and unique KMTS code; Jewellery trade authorisation certificate (kuyum ticareti yetki belgesi)

Issues

Commercial invoice; Bank transfer record

• VUK General Communiqué No. 459 s. 4.1, 4.2(h); Kuyum Ticareti Yönetmeliği Art 5, VUK 459 s. 4.1

Report suspicious transactions to MASAK on the STR form within 10 business days of the suspicion arising, at any amount, without tipping off; keep documents 8 years

Who

Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)

Issues

Suspicious Transaction Report Form (Şüpheli İşlem Bildirim Formu) to MASAK

• Law 5549 Arts 4, 8; ROM Arts 27-29, 46, ROM Art 28(2); Law 5549 Art 8

Receive payment through an authorised bank; the statutory repatriation duty (173-FZ art. 19(1)(1)) applies to rouble-priced contracts but not, under art. 19(8), to FX-priced gold contracts; foreign currency credited under the contract is subject to mandatory sale in the share set by the Government Commission (Decree 79 para 2)

Who

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

Issues

Receipt of export proceeds

[inferred] Exemption of FX-priced gold contracts read from the absence of 7108 in the art. 19(8) list. [unconfirmed] The current mandatory-sale share is not in a legal act found. Western bank channels are largely closed by sanctions (OFAC FAQ 1029).

• Federal Law 173-FZ art. 19; Presidential Decrees 79 and 430, art. 19