Zimbabwe [state buyer/exporter (FGR) or gold dealing licensee] → South Africa (refine) → United Arab Emirates · Reconcile assays and pay the balance

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

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Zimbabwe (Doré bar - unstamped → Pre-refined 995 bar (e.g. 'Dubai 995')) ⟶ South Africa (Pre-refined 995 bar (e.g. 'Dubai 995') → LBMA Good Delivery 400oz bar) ⟶ United Arab Emirates (LBMA Good Delivery 400oz bar)

Not researched: South Africa → United Arab Emirates

Leg 1: Zimbabwe

Where the goods start

Doré bar - unstamped → Pre-refined 995 bar (e.g. 'Dubai 995')

1
Register as an exporter in CEPECS through the authorised dealer
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Issues
CEPECS exporter registration
Official guidance
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.1
2
Obtain the Gold Export Certificate for the lot
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Issues
Gold Export Certificate
Official guidance
[unconfirmed] Issuer and form of the 'Gold Export Certificate' are stated in no text held (FX Guidelines, Gold Trade Act and Regulations, Exchange Control Regulations and General Order all read); requested (zw.gap-gec).
3
Prepare assays and a pro-forma invoice showing the quantity, price and total value of the gold
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Needs
FGR bar list for the export lot
Issues
Assays supporting the RBZ export application; Pro-forma invoice: quantity, price and total value of gold to be exported (FXG 3.2.30)
Official guidance
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.30
4
Submit the export application on the RBZ Document Management System with the Gold Export Certificate, Gold Dealership Licence, assays and pro-forma invoice
Who
Authorised dealer bank
Needs
Gold Export Certificate; Gold dealing licence ('Gold Dealership Licence'); Assays supporting the RBZ export application; Pro-forma invoice: quantity, price and total value of gold to be exported (FXG 3.2.30); CEPECS exporter registration
Primary law
- Exchange Control Regulations SI 109/1996; RBZ Foreign Exchange Guidelines FXD5/2026, Regulations s.20(1)(e) (no export of gold unless authorised by an exchange control authority); Guidelines para 3.2.30 ('All exports of Gold require prior Reserve Bank approval')
5
Approve the gold export within 24 working hours and issue an approval reference number
Who
Reserve Bank of Zimbabwe
Issues
RBZ gold export approval (approval reference number on the Document Management System)
Official guidance
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.30
6
Raise the CEPECS Form CD1 quoting the RBZ approval reference
Who
Authorised dealer bank
Needs
RBZ gold export approval (approval reference number on the Document Management System)
Issues
CEPECS Form CD1 (exchange control export form)
Official guidance
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), paras 3.2.5, 3.2.30
7
Issue the commercial invoice to the foreign buyer/refiner (attached to the export entry)
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Issues
Commercial invoice
Official guidance
ZIMRA lists 'Suppliers' invoices' for the export entry; the pro-forma invoice goes to the RBZ (3.2.30). [blocked] ZIMRA page via WebFetch only.
8
Lodge the export bill of entry (Form 21) through a registered clearing agent in ASYCUDA World before the gold leaves, with the CEPECS Form CD1, the invoice and the RBZ approval; pay the clearance fee - 'No duties are payable on export'
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Needs
CEPECS Form CD1 (exchange control export form); RBZ gold export approval (approval reference number on the Document Management System); Commercial invoice
Issues
Customs export bill of entry (Form 21, lodged in ASYCUDA World)
Primary law
[blocked] The ZIMRA clearance page was read only through WebFetch. [unconfirmed] Any gold-specific customs examination is not described.
- Customs and Excise Act [Chapter 23:02]; Customs and Excise (General) Regulations 2001, Act s.54(1), s.61; Regulations s.62(1)(a); Exchange Control Regulations s.21
9
Where the buyer or the importing country's customs requires one (e.g. the UAE import declaration, ae.st-18), obtain a certificate of origin from the Zimbabwe National Chamber of Commerce on its form: the exporter declares 'that all the goods are of ZIMBABWE ORIGIN' and the chamber certifies it; the form carries the invoice, consignee and destination, transport, tariff number, description, net weight and the bill of entry number
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Needs
Commercial invoice; Customs export bill of entry (Form 21, lodged in ASYCUDA World)
Issues
ZNCC certificate of origin for the gold consignment
Secondary
ZNCC's own form read in full (a chamber, not a regulator). [unconfirmed] Whether FGR or other gold exporters obtain one in practice, its fee and turnaround were not found (requested from ZNCC). [inferred] Treated as optional: no Zimbabwean export rule requires it. [blocked] ZIMRA origin page via WebFetch only.
- Customs and Excise Act [Chapter 23:02]; Customs and Excise (General) Regulations 2001, Act s.89(1)(a) ('wholly grown or produced' test for unmanufactured goods); Regulations s.25 (certificates of origin for lower duty - imports)
10
An officer authorises loading by stamping the consignment note or air waybill; the airline accepts the sealed consignment as valuable cargo under the air waybill and the gold must leave Zimbabwe within ten days of the authority
Who
Secure logistics provider / airline
Needs
Customs export bill of entry (Form 21, lodged in ASYCUDA World)
Issues
Air waybill
Primary law
[inferred] Air freight from Harare is assumed; no Zimbabwe source names the route or carriers.
- Customs and Excise (General) Regulations 2001; Customs and Excise Act, Regulations s.63(1), (3); Act s.55(1)

Taxes and fees

Export duty and customs clearance fee
none on export ('No duties are payable on export'); clearance fee per Form 21
Official guidanceAmount not confirmed
- Customs and Excise (General) Regulations 2001, s.62(1)(a)(ii); s.175 (clearance fee)
Gold dealing licence fee
US$200,000 per year
Primary lawAmount not confirmed
- Gold Trade (Licence Fees) Notice 1978, Schedule 2, as replaced by SI 32 of 2023
Presumptive tax on small-scale miners
0% of the purchase price of precious metals Precious metals bought from small-scale miners
Primary lawAmount not confirmed
- Finance Act [Chapter 23:04] s.22C(1)(b) as substituted by Finance Act 2024 s.6, s.22C(1)(b)
Gold royalty, artisanal and small-scale miners
2% (reported, 2025-2026); previously 1% Gold sold by artisanal and small-scale miners
SecondaryAmount not confirmed
- Mines and Minerals Act s.244-245; Finance Act [Chapter 23:04] Schedule to Chapter VII; Income Tax Act 37th Schedule, MMA ss.244-245; 37th Schedule paras 2-3, 7
Gold royalty, 'gold produced by other miners' (price-banded, from 1 January 2026)
3% (sold 'at a time when its price is US$1 200 per ounce'); 5% (above US$1,200 but below US$5,000 per ounce); 10% (above US$5,000 per ounce) 'Gold produced by other miners' (the Schedule item replaced by the Finance Act 2025; the item for small-scale miners is separate and not held)
Primary lawAmount not confirmed
- Finance Act 2025 s.61 (Schedule to Chapter VII of the Finance Act [Chapter 23:04]); Income Tax Act 37th Schedule, s.61; 37th Schedule paras 2, 3, 7
Gold royalty, large-scale producers (before Finance Act 2025)
3% below US$1,200/oz; 5% above US$1,200/oz
SecondaryAmount not confirmed
Implicit cost: 10% ZiG payment to small-scale miners and FGR discount to spot
~5% below spot (best FGR tier) plus 10% of value paid in ZiG (ASM) / 30% (LSM)
SecondaryAmount not confirmed

Controls

Exporters surrender 30% of gross proceeds to the RBZ at the interbank rate and retain 70% indefinitely (retention cut from 75% to 70% in the February 2025 MPS); 50% surrender on overdue proceeds; proceeds due within 90 days.
30% of gross export receipts
Official guidanceAmount not confirmed
- Exchange Control Regulations SI 109/1996; RBZ FX Guidelines FXD5/2026, Regulations ss.5, 35(1)(c); Guidelines paras 3.2.2, 3.2.3; Directive FXD5/2026 para 2
Gold Trade Act licensees and permit holders are 'precious metals dealers' (MLPC Act s.13): identify and verify customers who pay 'in currency equal to or exceeding fifteen thousand United States dollars' (s.15(2)(d)) and whenever ML/TF is suspected, and the beneficial owner (s.15(3)); EDD for PEPs (…
US$15,000 CDD threshold for occasional transactions
Primary lawAmount not confirmed
- MLPC Act [9:24]; FIU DPMS Guidance (2026), MLPC Act ss.13, 15(2)(d), 15(3), 20, 24, 30, 31; Guidance paras 155, 172
Authorised gold bars are FGR-produced 99.5% bars of gazetted weights and dimensions bearing the FGR hallmark; defacing, altering, counterfeiting or smelting them is an offence (level 14 fine or up to 15 years).
Primary law
- Gold Trade Act [Chapter 21:03] as amended by Finance Act 2025, ss.2, 3, 12A
A traveller may take out at most 'US$2,000 or its equivalent in any other currency, combination of currencies or gold coins' in foreign cash, and ZiG cash equivalent to US$2,000 (FX Guidelines 3.2.33-3.2.34). Personal-use gold articles in baggage are exempt from the export prohibition (Exchange Cont…
US$2,000
Official guidanceAmount not confirmed
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), paras 3.2.33-3.2.34
All gold won must be delivered 'not later than the 10th of every month' to the holder of a gold dealing licence (GTA s.6(1)), who 'shall deal with such gold in accordance with directions issued to him by the Minister responsible for finance' (s.6(3)). Only licence or permit holders, location holders…
All gold, any quantity
Primary law
- Gold Trade Act [Chapter 21:03], ss.3(1), 4, 5, 6(1), 6(3)
Gold Trade Enforcement Unit (FGR staff plus police) may inspect mining locations and premises, examine documents and devices, and seize gold; obstruction is an offence.
Primary law
- Gold Trade Act [Chapter 21:03] Part IIIA, ss.22B-22E
Payment for gold delivered to refineries: ASGM not more than 90% foreign currency / not less than 10% ZiG; LSGM 70% / 30% (from 1 March 2026).
Official guidance
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.29
'No person shall dispatch by post any postal article containing gold unless he is authorized to do so by any regulation' (GTA s.10(1)); authorised: licence holders, permit holders, location holders or tributors and their employees or agents (GT Regulations reg 8); suspect articles may be detained an…
Primary law
- Gold Trade Act [Chapter 21:03]; Gold Trade Regulations 1978, s.10; reg 8
No person may export gold unless authorised by an exchange control authority (Exchange Control Regulations s.20(1)(e)); 'All exports of Gold require prior Reserve Bank approval', applied for by the authorised dealer on the Document Management System with 'The Gold Export Certificate', 'Gold Dealersh…
Primary law
- Exchange Control Regulations SI 109/1996; Exchange Control Act; RBZ FX Guidelines FXD5/2026, Regulations s.20(1)(e); Act s.5(4c); Guidelines para 3.2.30
  “a fine of three times the value of the item”
'No person shall smelt or change the form of any manufactured article containing gold unless he has received the permission of the Minister' (GTA s.12(1)); fine up to level nine or two years (s.12(2)).
Primary law
- Gold Trade Act [Chapter 21:03], s.12
Contravening s.3(1): without special circumstances 'imprisonment for a period of not less than five years or more than ten years', not suspendable (s.3(3)(a), (4)); with special circumstances up to five years or a fine up to level nine or twice the value of the gold (s.3(3)(b)); the same for ss.4, 5…
Primary law
- Gold Trade Act [Chapter 21:03], ss.3(3)-(4), 24, 30
On 4 March 2024 the US ended the Zimbabwe sanctions programme and designated President Mnangagwa and 10 other individuals plus Sakunda Holdings, Fossil Agro and Fossil Contracting under Global Magnitsky, citing involvement in gold and diamond smuggling networks. FGR is not named. US persons must scr…
Official guidance

Leg 2: South Africa

On the way

Pre-refined 995 bar (e.g. 'Dubai 995') → LBMA Good Delivery 400oz bar

11
Onboard the foreign depositor: KYC pack, mined-material questionnaire, refining agreement; apply LBMA Responsible Gold Guidance / OECD due diligence
Who
Refining-licence holder (refinery)
Issues
Refiner KYC pack on foreign depositor; KYC questionnaire for mined material; Refining agreement with depositor
Industry practice
Rand Refinery states KYC and conflict-free sourcing policies; its depositor requirements and the RGG text were not read in this pass.
12
Hold a current SADPMR permit to import unwrought precious metal (Form PMI: quantity, fineness, form, value, period, ports, countries of origin, purpose)
Who
Refining-licence holder (refinery)
Needs
SADPMR refining licence; SAPS police clearance certificate
Issues
SADPMR permit to import precious metals
Primary law
- Precious Metals Act; Precious Metals Regulations, s.10(1)-(2); regs 21-22
13
Ship dore by air to Johannesburg with the origin country's export authorisation, export declaration and assay
Who
Foreign mine or exporter depositing doré
Needs
Origin country's export authorisation for the gold (permit, licence or clearance issued by the mining or trade authority); Export customs declaration accepted by the dispatching country's customs; Assay certificate (fineness and fine weight); Air waybill
Issues
Air waybill, origin to Johannesburg (OR Tambo)
Unverified
[unconfirmed] PMA s.10(2)(b) requires the importer to declare and prove the origin of the metal in the permit application, and s.10(4) says the permit states the origin; which origin-country documents must accompany each shipment is not stated in any text read. The listed hand-off kinds are the model's route logic.
14
Enter the doré for customs with SARS on a bill of entry for import (the metal must be duly entered for customs under reg 21(4)(b)); entry may be refused if the Regulator considers it of dubious origin or incorrectly declared (reg 21(5))
Who
Refining-licence holder (refinery)
Needs
SADPMR permit to import precious metals; Air waybill, origin to Johannesburg (OR Tambo)
Issues
SARS import declaration for dore
Primary law
[not-read] Customs and Excise Act procedure, tariff heading 7108 and import VAT on doré not read (Act not held). Manual C(G): gold import applications are referred to SADPMR.
- Precious Metals Regulations; Customs and Excise Act 1964, reg 21(4)(b), 21(5)
  “A precious metal may be refused entry into the South Africa if - (a) that precious metal is in the opinion of the Regulator of dubious origin; or (b) that precious metal has been incorrectly described or declared.”
15
Carry the dore from the airport to the refinery with the reg 26 waybill; SADPMR or SAPS may inspect imported metal
Who
Secure carrier of precious metal
Issues
Waybill, port of entry to refinery
Primary law
- Precious Metals Act, s.10(3), s.13; reg 26
16
Submit specimens of the imported metal to the SAPS Forensic Science Laboratory
Who
Refining-licence holder (refinery)
Issues
Specimen submission (importer)
Primary law
- Precious Metals Act, s.22(1)
  “Any producer or any person who imports precious metal must submit to the Forensic Science Laboratory of the South African Police Service such specimens of any precious metals produced or imported by him or her as may be prescribed.”
17
Weigh, melt, sample and assay each lot on receipt; issue outturn (final assay and fine weight) to the depositor
Who
Refining-licence holder (refinery)
Needs
Refining agreement with depositor
Issues
Refiner outturn / assay report
Industry practice
18
Refine at the licensed premises and cast 400 oz Good Delivery bars, kilobars (995-999.9), minted bars (10/50/100 g, 999.9) or grain
Who
Refining-licence holder (refinery)
Issues
Refiner bar list for bars produced
Form
Doré bar - unstamped → LBMA Good Delivery 400oz bar
Primary law
- Precious Metals Act; Precious Metals Regulations, s.7(1), 7(5); reg 28 (minted bars)
19
Record receipts and outputs in the PMR2 register within 24 hours
Who
Refining-licence holder (refinery)
Issues
PMR2 refinery register entry / quarterly copy
Primary law
- Precious Metals Act, s.15(1); reg 33
20
Publish annual responsible-gold / LBMA compliance report
Who
Refining-licence holder (refinery)
Issues
Refiner responsible gold / LBMA compliance report
Industry practice
21
Credit fine gold to the depositor's metal account and hold the bars in the refinery vault pending sale or export
Who
Refining-licence holder (refinery)
Needs
Refiner outturn / assay report; Refiner bar list for bars produced
Issues
Metal account credit / settlement confirmation
Industry practice
Rand Refinery lists vault and logistics services; account terms not seen.
22
Obtain Treasury permission and, for any unwrought or semi-fabricated output, SADPMR export approval; file the customs export declaration for the refined bars
Who
Refining-licence holder (refinery)
Needs
Refiner bar list for bars produced; SADPMR export approval for gold (PMA s.12); National Treasury approval to export gold (Exchange Control Reg 3; PMA s.12(1))
Issues
SARS customs declaration / bill of entry for export
Primary law
[unconfirmed] No SADPMR or SARB text specific to re-export of refined foreign-origin gold was found; Reg 3, Manual C(B) and PMA s.12 are applied as written.
- Exchange Control Regulations; Precious Metals Act, Reg 3; s.12(1)
23
Ship the bars to the depositor's buyer or vault abroad
Who
Secure carrier of precious metal
Issues
Waybill, refinery/exporter to port of export; Air waybill, Johannesburg to destination
Primary law
- Precious Metals Act, s.13; reg 26

Taxes and fees

VAT on other domestic supplies of gold
15% Domestic gold supplies not zero-rated (e.g. recycled gold to banks; sales to traders)
Primary lawAmount not confirmed
- Value-Added Tax Act 1991
VAT zero-rating of gold supplied to the SARB, SA Mint and banks
0% Refined primary gold sold to the SARB, the SA Mint or a registered bank; recycled gold excluded (Lueven Metals, ZACC 23 June 2026)
Primary lawAmount not confirmed
- Value-Added Tax Act 1991, s.11(1)(f)
SADPMR licence and permit fees
Refining licence R20,000; beneficiation licence R5,000; jeweller's permit R500; import permit R1,000; certificate R1,000; special permit R5,000; appeal R500 (Annexure A, 2014) Applications and renewals
Primary lawAmount not confirmed
- Precious Metals Regulations, Annexure A as substituted by GN R737 (GG 38014, 22 Sept 2014)

Controls

A business dealing in high-value goods (items valued in that business at R100,000 or more) is an accountable institution for transactions in which it receives payment of R100,000 or more (Schedule 1 item 20, from 19 Dec 2022): FIC registration (s.43B), risk management and compliance programme (s.42)…
Payment of R100,000 or more in a transaction; goods valued at R100,000 or more
Primary lawAmount not confirmed
- FICA 38 of 2001, Schedule 1 item 20; ss.20A-21H, 22-23, 28, 29, 42, 43B
A UN Security Council Chapter VII resolution identifying persons or entities 'has immediate effect for the purposes of this Act upon its adoption' (FICA s.26A(1)); the FIC Director must give notice of it (s.26A(3)). No person may, directly or indirectly, acquire, collect, use, possess or own propert…
Primary law
- FICA 38 of 2001, ss.26A-26C
  “A resolution adopted by the Security Council of the United Nations when acting under Chapter VII of the Charter of the United Nations, providing for financial sanctions which entail the identification of persons or entities against whom member states of the United Nations must take the actions specified in the resolution, has immediate effect for the purposes of this Act upon its adoption by the Security Council of the United Nations.”
Contravening s.5(4) (as enacted; replaced by s.5A from 7 June 2013), 19, 20(2) or 28 is an offence with a fine up to R100 000 or up to two years' imprisonment, or both (s.99(1)(a)); failing to notify the Minister before beneficiating abroad (s.26(3)) carries up to R500 000 for each day (s.99(1)(f)).
Primary law
- MPRDA 2002, ss.98, 99(1)(a), 99(1)(f)
Goods exported for sale must be sold, and the full proceeds received, not later than six months from shipment; an Authorised Dealer may allow credit of up to 12 months. Proceeds must be offered for sale to an Authorised Dealer within 30 days or dealt with under the CFC rules. The Authorised Dealer r…
Official guidance
- Exchange Control Regulations; Currency and Exchanges Manual, Regs 6, 10, 11; B.18(B), (D)
No export of unwrought or semi-fabricated gold except with the approval of the National Treasury under the Exchange Control Regulations, granted with the Minister's concurrence (PMA s.12(1)); no gold may be exported without Treasury permission (Reg 3); applications to export gold in any form are ref…
Primary law
- Precious Metals Act; Exchange Control Regulations, PMA s.12(1); Reg 3
Producers submit gold specimens (nuggets, concentrate, dore) to the SAPS Forensic Science Laboratory every six months, and importers submit specimens of imported metal, building a forensic database to trace seized gold to its source.
Primary law
- Precious Metals Act; Precious Metals Regulations, s.22(1); reg 29
  “Any producer or any person who imports precious metal must submit to the Forensic Science Laboratory of the South African Police Service such specimens of any precious metals produced or imported by him or her as may be prescribed.”
Except with Treasury permission, only authorised dealers may buy, borrow, sell or lend gold other than wrought gold (Reg 2). A resident entitled to sell gold must offer it for sale to the Treasury within 30 days unless exempted (Reg 5). Producers exempted by FinSurv from Reg 5 may sell their total o…
Primary law
- Exchange Control Regulations 1961, Regs 2, 5, 22
No import of unwrought or semi-fabricated precious metal without an SADPMR import permit (valid up to one year), issued after consulting the National Commissioner and the National Treasury, on documentary proof of origin (s.10(2)); the Regulator or SAPS may inspect and sample imported metal (s.10(3)…
Primary law
- Precious Metals Act, s.10, s.22(1)
  “must state the origin of the precious metal in question, the purpose of the import”
Export approval requires projections of monthly production against sales showing the applicant contributes to local demand; approval only where provision has been made to meet local demand for beneficiation.
Primary law
- Precious Metals Regulations; Precious Metals Act, reg 23(3)(a) as substituted by GN R387
Minted gold bars must be 10, 50 or 100 g, of prescribed dimensions and at least 999.9 fine (reg 28, Annexure B Table 1); only approved manufacturers may make them and no more than 500 000 troy ounces a year may be manufactured (reg 27B).
Primary law
- Precious Metals Regulations, regs 27B, 28; Annexure B
  “The quantity of minted bars that maybe manufactured in the Republic may not exceed 500 000 troy ounces in a calendar year”
Only a refining-licence holder, an authorised dealer, a producer (for gold it won or recovered), an SADPMR certificate holder, a holder of a special permit (metal not exceeding a prescribed mass, for scientific or beneficiation purposes or jewellery) or a beneficiation-licence holder may acquire, po…
Primary law
- Precious Metals Act, s.4(1), s.20(1)
Rand Refinery, as an LBMA Good Delivery refiner, applies KYC and conflict-free sourcing policies to depositors and publishes responsible-gold and LBMA compliance reports.
Industry practice
- LBMA Responsible Gold Guidance
Unwrought or semi-fabricated gold may not be carried outside a mine or refinery boundary without the prescribed waybill.
Primary law
- Precious Metals Act; Precious Metals Regulations, s.13; reg 26

Leg 3: United Arab Emirates

Where the goods arrive

24
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
Official guidance
[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)
25
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)
Official guidance
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)
26
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)
Primary law
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)
27
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
Primary law
[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)
28
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)
Official guidance
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.
29
Reconcile the provisional (origin) assay against the Dubai refiner's outturn assay: within the contract's splitting limit the two assays are commonly averaged; beyond it an umpire assay decides (the assay closer to the umpire's is used, and the party further from it pays the umpire); settle the difference and pay the final balance
Who
DMCC importer / trader
Needs
Refiner outturn/assay report; Commercial invoice
Issues
Final invoice from the Nigerian exporter (against Dubai outturn assay); Reconciliation of provisional vs outturn assay; Balance/final payment wire; DPMSR filed in goAML for the final settlement
Secondary
[unconfirmed] Debit and credit notes are not described in the two contracts read; the Johnson Matthey contract settles by metal credit, adjusted after the umpire result.
- Refining/sale contract settlement clause -- splitting limit + umpire assay if the two figures diverge beyond it

Taxes and fees

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”

Controls

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)

Leg 4: Zimbabwe

Back in the origin country: the proceeds of the export

30
Receive payment within three months (90 days) from export or when contractually due
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Issues
Receipt of export proceeds
Primary law
- Exchange Control Regulations SI 109/1996; Exchange Control (General) Order SI 110/1996; RBZ FX Guidelines FXD5/2026, Regulations ss.5, 21; General Order s.13(2) ('within three months from the date of export'); Guidelines para 3.2.2
31
Pre-acquit the Form CD1 within 48 hours of receiving the proceeds
Who
Authorised dealer bank
Issues
CD1 acquittal (proceeds received)
Official guidance
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.7
32
Sell 30% of gross proceeds to the RBZ at the weighted-average willing-buyer willing-seller interbank rate; the exporter keeps 70% indefinitely (50% surrender where proceeds were overdue)
Who
Authorised dealer bank
Issues
Sale of 30% surrender portion to RBZ at the WBWS interbank rate
Official guidance
[unconfirmed] Whether the general 30% surrender applies to FGR's own gold export proceeds is not stated. The February 2026 MPS (para 233) keeps 70% retention for all sectors 'with the exception of small-scale gold producers, whose retention shall be 90%'.
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026); FXD5/2026, FXG para 3.2.3; FXD5 para 2.2

Crossings between countries

Zimbabwe → South Africa Researched
Papers that cross: CEPECS exporter registration; Gold Export Certificate; Assays supporting the RBZ export application; Pro-forma invoice: quantity, price and total value of gold to be exported (FXG 3.2.30); RBZ gold export approval (approval reference number on the Document Management System); CEPECS Form CD1 (exchange control export form); Customs export bill of entry (Form 21, lodged in ASYCUDA World); ZNCC certificate of origin for the gold consignment; Air waybill
South Africa → United Arab Emirates Not researched
Papers that cross: SADPMR permit to import precious metals; Air waybill, origin to Johannesburg (OR Tambo); SARS import declaration for dore; Waybill, port of entry to refinery; Refiner outturn / assay report; Refiner bar list for bars produced; SARS customs declaration / bill of entry for export; Waybill, refinery/exporter to port of export; Air waybill, Johannesburg to destination

Paperwork gaps

ae.st-18 expects Packing list; the earlier legs don't model this paper