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

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

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Switzerland (Doré bar - unstamped) ⟶ United States (Doré bar - unstamped) ⟶ Hong Kong SAR China (Doré bar - unstamped) ⟶ China (Doré bar - unstamped → 999.9 kilobar)

Not researched: United States → Hong Kong SAR China

Leg 1: Switzerland

Where the goods start

1
Screen the bars, buyer and destination against Swiss sanctions before release: no purchase, import, transit or related services (including brokerage and financing) for gold of Russian origin exported after 4 Aug 2022 or gold processed from it in third countries
Who
Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)
Primary law
[transcription] Art. 14d paras 1-4 read in an unofficial third-party English translation (as at 22 Mar 2024, held in laws/); Annex 26 covers 7108, 7112 91 and ex 7118 90 gold coins; Annex 27 ex 7113 and ex 7114. [unconfirmed] The official consolidation is now Stand 21 Sep 2026 and was not read (the fetch tool truncates before Art. 14d); changes after March 2024 are not ruled out. The ordinance contains no explicit ban on selling gold to Russia; the export-side effect is through the services ban.
- Ordinance of 4 March 2022 on measures in connection with the situation in Ukraine (SR 946.231.176.72), Art. 14d
2
Release the bars from the refinery vault or free port against the owner's instruction and prepare the weight list (bar list), commercial invoice and packing list for the shipment
Who
Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)
Issues
Outbound weight list / bar list; Commercial invoice to the foreign buyer; Packing list
Standard
The weight list is sourced to LBMA Annex C; commercial invoice and packing list are standard export practice, not read in a Swiss source.
- LBMA Good Delivery Rules, Annex C (weight lists); Customs Act Arts. 62-66 (free ports)
3
Lodge the electronic export declaration in Passar (HS 7108; e-dec Export was usable only to end-2025); the declarant must make it binding and physically export the goods within 120 days of its acceptance in the IT system
Who
Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)
Issues
Passar export declaration (HS 7108)
Official guidance
R-10-10 (valid 1 Jan 2026) cites Art. 25-29 ZG and Art. 79-83 ZV for the declaration duty, says declarations are electronic in principle, and sets the 120-day limit from acceptance in the IT system. R-10-10 held and read in full on 2026-09-28; the Customs Act and Ordinance texts themselves were not read. R-10-10 has no gold-specific rule.
- Customs Act (ZG, SR 631.0); BAZG R-10-10, ZG Arts. 25-29 (as cited in R-10-10)
4
Receive the export assessment notice (Veranlagungsverfuegung Ausfuhr), the evidence that the goods were properly cleared for export
Who
Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)
Issues
Veranlagungsverfuegung Ausfuhr
Official guidance
R-10-10 cites Art. 38 and 69 ZG and Art. 92 ZV for the export assessment notice and says it is evidence of proper assessment and of export for VAT. R-10-10 held and read in full on 2026-09-28.
- Customs Act (ZG); BAZG R-10-10, ZG Arts. 38 and 69; ZV Art. 92 (as cited in R-10-10)
5
Treat the sale as a VAT-exempt export (supply of goods directly transported abroad) and keep the export assessment notice as evidence
Who
Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)
Needs
Veranlagungsverfuegung Ausfuhr
Primary law
Art. 23(2) no. 1 read in the held MWSTG (Stand 1 Jan 2025, German wording current). Art. 23(3): direct export includes export into an open customs warehouse or a free port. Investment gold of at least 995 fineness is separately exempt with credit under Art. 23(2) no. 12 (see ch.tax-import-vat).
- Federal VAT Act (MWSTG, SR 641.20), Art. 23(2) no. 1
6
Hand the sealed consignment to a secure valuables carrier and fly it out (Zurich or Geneva) under an air waybill
Who
Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)
Issues
Air waybill (outbound)
Unverified
Carrier practice. Cantonal licensing: in the Canton of Zurich "Sicherheitstransporte von Personen, Gütern und Wertsachen" require a licence under the Polizeigesetz, 9. Abschnitt (cantonal page, read by WebFetch 2026-09-28; PolG text not read). Geneva and other cantons not checked. No Swiss source read describes the outbound air leg for gold.

Controls

Banks identify the contracting party and beneficial owner for precious-metals trading and for cash transactions over CHF 15,000 (CDB 20; Form A, Form K).
CHF 15,000 cash
StandardAmount not confirmed
- CDB 20 (SBA), CDB Art. 4(2)(f)-(g), 7, 20-21, 27-28
Melt material imported from abroad for sale in Switzerland needs a formal import declaration; simplified and oral declarations are excluded in principle. A buyer or licensee who accepts melt material that has not been through customs breaches due diligence under the PMCA: fine up to CHF 2,000 per ca…
Official guidance
- BAZG Merkblatt 'Annahme von Schmelzgut aus dem Ausland' (Jan 2024)
Commercial production of melt products (bars, plates, rods, granules made by melting precious metal or melt material) requires a melt licence; acting without it is punishable by a fine (EMKG Art. 48). Every melt product must bear the licence holder's stamp; melt products for resale must be assayed b…
Primary law
- EMKG/PMCA (SR 941.31), Arts. 1(2), 24, 31(1), 32-33, 47, 48
Holders of a melter licence may accept melt material only from persons who can prove lawful acquisition, and must verify the customer's identity by a probative document such as a passport or identity card. Where origin is doubtful or the offer comes from unknown persons, origin must be clarified wit…
Primary law
- PMCO/EMKV (articles in refs), EMKV (SR 941.311, Stand 1 Jan 2024) Art. 168a Abs. 1 (parsed into section sch-2)
  “Der Inhaber einer Schmelzbewilligung darf Schmelzgut nur von Per-”
- PMCO/EMKV (articles in refs), EMKV (SR 941.311, Stand 1 Jan 2024) Art. 168a Abs. 2 (parsed into section sch-2)
  “Es muss die Identität des Kunden anhand eines beweiskräftigen Do- kumentes wie Pass oder Identitätskarte überprüfen.”
- PMCO/EMKV (articles in refs), EMKV (SR 941.311, Stand 1 Jan 2024) Art. 168a Abs. 3 (parsed into section sch-2)
  “Bestehen über die Herkunft der Ware Zweifel oder stammen die An- gebote von Unbekannten, so ist der Inhaber der Schmelzbewilligung verpflichtet, die Herkunft des Schmelzgutes besonders sorgfältig abzu- klären.”
- PMCO/EMKV (articles in refs), EMKV (SR 941.311, Stand 1 Jan 2024) Art. 168b Abs. 1 (parsed into section sch-2)
  “derlichen organisatorischen Massnahmen, um das Schmelzen von Schmelzgut unrechtmässiger Herkunft zu verhindern.”
- PMCO/EMKV (articles in refs), EMKV (SR 941.311, Stand 1 Jan 2024) Art. 168b Abs. 2 (parsed into section sch-2)
  “so ist die Ware durch den Inhaber der Schmelzbewilligung bis zur Klärung des Falles in unverändertem Zu- stand aufzubewahren.”
- PMCO/EMKV (articles in refs), EMKV (SR 941.311, Stand 1 Jan 2024) Art. 168b Abs. 3 (parsed into section sch-2)
  “Schmelzprodukten müssen während zehn Jahren aufbewahrt werden.”
- PMCO/EMKV (articles in refs), EMKV (SR 941.311, Stand 1 Jan 2024) Art. 168c Abs. 1 (parsed into section sch-2)
  “Der Inhaber einer Schmelzbewilligung muss über seine Ankäufe von Schmelzgut und Schmelzprodukten Buch führen.”
- PMCO/EMKV (articles in refs), EMKV (SR 941.311, Stand 1 Jan 2024) Art. 168c Abs. 2 Bst. b (parsed into section sch-2)
  “die in Artikel 168a Absatz 2 vorgeschriebenen Identifikations- nachweise;”
- PMCO/EMKV (articles in refs), BAZG Schmelzen und Prüfen (Dec 2023) Ziff. 4.1.6 (restates Art. 168a)
  “Er muss die Identität des Kunden anhand eines beweiskräftigen Dokumentes wie Pass oder Identitätskarte überprüfen und muss sich vor Ausführung des Auftrages den rechtmässigen Erwerb des Schmelzgutes durch den Auftraggeber nachweisen lassen.”
- PMCO/EMKV (articles in refs), BAZG Schmelzen und Prüfen (Dec 2023) Ziff. 4.1.6 (restates Art. 168b Abs. 3)
  “Die Dokumente über den Geschäftsverkehr mit Schmelzgut und Schmelzprodukten müssen während zehn Jahren aufbewahrt werden.”
- PMCO/EMKV (articles in refs), BAZG Richtlinie R-247 (1 Jan 2023) Ziff. 3.3.2
  “Bestehen Zweifel über die Herkunft des Materials oder in Bezug auf die Integrität des Kunden sind Bewilligungsinhaber verpflichtet, den Sachverhalt besonders sorgfältig abzuklären”
Purchase, import, transit and transport of gold (Annex 26) originating in Russia and exported from Russia after 4 Aug 2022, and of gold processed from it in third countries, are prohibited, as are related services (all kinds, including financial services, brokerage and technical assistance) and the …
Primary law
- Ordinance of 4 March 2022 on measures in connection with the situation in Ukraine (SR 946.231.176.72), Art. 14d
Precious metals are 'sensitive goods' in free ports (Customs Ordinance Annex 2, as amended on 18 November 2015): the declarant must declare them electronically on entry into storage, and an electronic inventory record of them is kept per depositor and submitted by the warehouse keeper to customs on …
Primary law
- Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), AS 2015 4917, ZV Anhang 2 (sensitive goods) as amended
  “Anhang 2 wird wie folgt geändert:”
- Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), ZV Anhang 2 Ziff. 5: precious metals ex tariff chapter 71
  “Perlen, Diamanten, Edelsteine, Schmucksteine, Edelmetalle und Edel- metallplattierungen sowie Waren daraus (ex Zolltarifkapitel 71)”
- Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), AS 2015 4917 Ziff. IV: in force
  “Diese Verordnung tritt am 1. Januar 2016 in Kraft.”
- Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), ZV Art. 178a Abs. 1: electronic declaration on entry into the free port
  “Die anmeldepflichtige Person muss sensible Waren bei der Einlagerung ins Zoll- freilager elektronisch anmelden.”
- Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), ZV Art. 185: inventory record per depositor
  “Die Bestandesaufzeichnung für sensible Waren ist je Einlagererin oder je Einlagerer zu führen.”
- Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), ZV Art. 184 Abs. 2: kept electronically
  “Sie muss elektronisch geführt werden.”
- Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), ZV Art. 184 Abs. 3bis: warehouse keeper submits it on request
  “Auf Verlangen muss die Lagerhalterin oder der Lagerhalter der EZV die”
- Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), AS 2015 4917, ZV Art. 246a: amendment date
  “Übergangsbestimmungen zur Änderung vom 18. November 2015”
- Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), BAZG R-10-50 (1 Jul 2025) s.1.3.1: export goods count as sensitive goods
  “Ausfuhrwaren gelten als sensible Waren”
- Customs Ordinance (ZV) as amended on 18 November 2015 (articles in refs), R-10-50 s.4.1: inventory records over all sensitive goods
  “Bestandesaufzeichnungen nach den Grundsätzen der ordnungsgemässen Buchführung”
Cash threshold for dealers in goods (anti-money laundering)
Primary law
- GwG Art. 8a(1)
  “Händlerinnen und Händler nach Artikel 2 Absatz 1 Buchstabe b müssen folgende”
- GwG Art. 8a(1)(a)
  “Identifizierung der Vertragspartei (Art. 3 Abs. 1);”
Cash threshold for dealers in gold (anti-money laundering)
Primary law
- GwG Art. 8a(1)
  “Händlerinnen und Händler nach Artikel 2 Absatz 1 Buchstabe b müssen folgende”
- GwG Art. 8a(1)(a)
  “Identifizierung der Vertragspartei (Art. 3 Abs. 1);”
- GwG Art. 8a(2bis)
  “oder Edelsteinen beträgt die massgebende Schwelle im Sinne von Ab-”
- EMKG Art. 1(1)
  “Edelmetalle im Sinne dieses Gesetzes sind Gold, Silber, Platin und Palladium.”

Leg 2: United States

On the way

7
Screen the supplier and the gold: KYC, OFAC sanctions lists, and confirm the gold is not of Russian Federation origin (unless it was outside Russia before 28 June 2022); apply CAHRA red flags from the 2023 Africa Gold Advisory
Who
Importer of record (bullion bank, trader, refiner or dealer)
Needs
Commercial invoice; Bar list (serials, weights, fineness)
Issues
Importer's supplier KYC and OFAC / Russian-origin screening file
Primary law
- E.O. 14068; OFAC Determination (effective 28 Jun 2022, amended 22 Dec 2023), E.O. 14068 s.1(a)(i); determination under s.1(a)(i)(A), 1(b) and 5; delegation 31 CFR 587.802
8
File entry (CBP Form 3461 or electronic equivalent) with evidence of the right to make entry, commercial invoice and packing list, and the entry summary (CBP Form 7501) classifying the gold under HTSUS 7108 with country of origin; deposit any duty (heading 7108 free except 4.1% on 7108.12.50 and 7108.13.70 for non-preference origins) and the 0.3464% merchandise processing fee; shipments of $2,500 or less may use informal entry
Who
Licensed customs broker
Needs
Importer's supplier KYC and OFAC / Russian-origin screening file; Commercial invoice; Packing list; Air waybill
Issues
CBP Form 3461 entry / immediate delivery (or ACE electronic equivalent); CBP Form 7501 entry summary (HTSUS classification, origin, duties and fees)
Primary law
- 19 CFR 142.3; 19 CFR 143.21; 19 CFR 24.23; HTSUS 7108
9
Review, examine if selected, and release the goods; CBP enforces the Russian-origin gold ban and any withhold release order on gold made with forced labour
Who
US Customs and Border Protection
Needs
CBP Form 3461 entry / immediate delivery (or ACE electronic equivalent)
Issues
CBP release of entered goods (ACE cargo release)
Primary law
- 19 CFR 142.3; E.O. 14068 gold determination; 19 U.S.C. 1307 and 19 CFR 12.42
10
Deliver released gold directly to the refinery or to a COMEX-approved depository (for COMEX, bars must come directly from an approved producer or assayer with certificates, or from another depository)
Who
Secure logistics carrier (armoured / valuables; COMEX-approved carrier where relevant)
Needs
CBP release of entered goods (ACE cargo release)
Issues
Delivery record airport to refinery or depository
Standard
11
Deliver bars into a COMEX-approved depository directly from the approved producer with refiner certificates, from an approved assayer with assay certificates, or from another approved depository
Who
Secure logistics carrier (armoured / valuables; COMEX-approved carrier where relevant)
Needs
Refiner certificate for bars produced (brand, serial, weight, fineness)
Issues
Chain-of-integrity receipt at depository
Standard
12
Inspect and weigh the bars and record them as eligible stock
Who
COMEX-approved depository / bullion vault
Needs
Chain-of-integrity receipt at depository; Bar list (serials, weights, fineness)
Issues
Depository inspection, weight record and eligible-stock entry
Standard
13
Issue an electronic warrant in the name of the clearing member, referencing bar serials and the approved producer; the metal becomes registered (deliverable) stock
Who
COMEX-approved depository / bullion vault
Needs
Depository inspection, weight record and eligible-stock entry
Issues
COMEX gold warrant (electronic UCC Article 7 document of title)
Standard
- COMEX Rulebook; UCC Article 7, Rule 705.A; 113108
14
Report eligible, pledged and registered stocks to the exchange registrar daily by 2:00 p.m.
Who
COMEX-approved depository / bullion vault
Standard
15
Optionally pledge the warrant to CME as collateral (title to CME, first-priority security interest, 15% haircut)
Who
Futures clearing member / bullion bank
Needs
COMEX gold warrant (electronic UCC Article 7 document of title)
Standard
16
Release the bars from the depository (load-out after warrant cancellation if on COMEX warrant) to the carrier
Who
COMEX-approved depository / bullion vault
Needs
Depository inspection, weight record and eligible-stock entry
Standard
17
File EEI in AES for the foreign-origin gold and give the ITN to the carrier (same rules as export; BIS licence for Russia/Belarus)
Who
US principal party in interest (USPPI) / exporter
Issues
EEI/ITN for re-export of foreign-origin gold
Primary law
- Foreign Trade Regulations, 15 CFR 30.2, 30.4

Taxes and fees

Customs duty on gold (HTSUS 7108)
Column 1 general: Free on 7108.11.00 (powder), 7108.12.10 (bullion and dore), 7108.13.10 (gold leaf), 7108.13.55 (rectangular or near-rectangular shapes of 99.5%+ gold marked only with weight, purity or other identifying information), 7108.20.00 (monetary); 4.1% on 7108.12.50 (other unwrought) and 7108.13.70 (other semi-manufactured), Free for special programmes A, AU, BH, CL, CO, D, E, IL, JO, KR, MA, OM, P, PA, PE, S, SG (General Note 3(c)(i): e.g. S = USMCA, PE = Peru TPA, CO = Colombia TPA, AU = Australia FTA, CL = Chile FTA, SG = Singapore FTA, A = GSP, D = AGOA). Column 2: 65% on 7108.12.50 and 7108.13.70, 8% on gold leaf, Free on the others (7108.13.55 footnoted "See 9903.90.08") All imports of gold
Primary lawAmount not confirmed
- HTSUS (Revision 19, 2026), heading 7108
Nevada gold and silver excise tax
0.75% of Nevada gross revenue above $20,000,000 up to $150,000,000 (i.e. $975,000 at $150m) plus 1.1% of the excess over $150,000,000; nothing due if $20,000,000 or less
Official guidanceAmount not confirmed
- NRS 363D (per Department of Taxation form EXC-F029), NRS 363D.160 (as cited by the Department)
IEEPA reciprocal tariff (E.O. 14257) - ended February 2026; gold bullion exempt throughout, other 7108 lines exempt from 8 Sep 2025
10% on all imports from 12:01 a.m. EDT 5 Apr 2025 (E.O. 14257 s.3(a)) plus country-specific rates from 9 Apr 2025 as modified; goods in Annex II excepted 7108.12.10 (bullion and dore) was already in Annex II; E.O. 14346 Annex II (FR 43788-43789) marks 7108.11.00, 7108.12.50, 7108.13.10, 7108.13.55, 7108.13.70 and 7108.20.00 as "Addition" for goods entered from 12:01 a.m. EDT 8 Sep 2025. Before that, cast kilobars and 100 oz bars classified in 7108.13.5500 paid the additional duty (CBP ruling N351466: "subject to an additional 10 percent ad valorem rate of duty").
Primary lawAmount not confirmed
- E.O. 14257 as modified by E.O. 14346 (IEEPA); ended by E.O. 14389
Additional duty on Russian products (9903.90.08)
35% ad valorem in lieu of column 2 rates Products of Russia in U.S. note 30(b); of heading 7108 only 7108.13.55 is listed. Moot for gold: its import is prohibited (us.ctl-russia-gold-ban)
Primary lawAmount not confirmed
- HTSUS chapter 99, 9903.90.08
Section 122 temporary import surcharge (Proclamation 11012) - gold excepted
10% ad valorem on articles of any country (heading 9903.03.01), in addition to other duties; not applied to the goods listed in U.S. note 2(aa)(ii) (heading 9903.03.03), which include every 7108 subheading: 7108.11.00, 7108.12.10, 7108.12.50, 7108.13.10, 7108.13.55, 7108.13.70, 7108.20.00 Gold of HTSUS 7108 excepted ("metals used in currency and bullion", Proc. 11012 para. 14(b); Annex I para. 2; Annex II)
Primary lawAmount not confirmed
- Trade Act of 1974 s.122 (19 U.S.C. 2132); Proclamation 11012; HTSUS U.S. note 2(aa), subchapter III, chapter 99, 9903.03.01; 9903.03.03; note 2(aa)(ii)
Section 301 forced-labor tariffs on 60 economies (USTR, from 24 Jul 2026) - gold excluded
Additional 10% or 12.5% ad valorem depending on the economy (headings 9903.05.20-9903.05.84), e.g. Canada 10% (9903.05.29), Mexico 10% (9903.05.55), United Kingdom 10% (9903.05.81), Peru 12.5% (9903.05.63), Colombia 12.5% (9903.05.32), United Arab Emirates 12.5% (9903.05.80), Switzerland: for goods whose column-1 rate is under 12.5%, column-1 rate plus additional duty totalling 12.5% (9903.05.74; note 52(k)); the same top-up method applies to the EU, Japan, South Korea and Taiwan headings; not applied to articles in U.S. note 52(b) (heading 9903.05.86), which lists 7108.11.00, 7108.12.10, 7108.12.50, 7108.13.10, 7108.13.55, 7108.13.70 and 7108.20.00 All HTSUS 7108 gold excluded; applies to other products of the listed economies
Primary lawAmount not confirmed
- Trade Act of 1974 s.301 (19 U.S.C. 2411); USTR notice FR Doc. 2026-15181; HTSUS U.S. note 52, subchapter III, chapter 99, 9903.05.20-9903.05.84; 9903.05.86; note 52(b)
VAT / sales tax on gold
No federal VAT or import VAT; state sales taxes vary - about 33 states exempt investment bullion or have no sales tax (Mar 2026) Bullion sales to end buyers
Secondary
BLM mining claim fees
$49 location fee and $200 initial maintenance fee per new lode claim, mill site or tunnel site; $200 annual maintenance fee (placer: per 20 acres or portion) due on or before 1 September; processing fees per 43 CFR 3000.12 ($25 per new claim on the BLM page)
Primary lawAmount not confirmed
- 30 U.S.C. 28f; 43 CFR 3830.21, 43 CFR 3830.21(a), (d)
Merchandise processing fee
0.3464% ad valorem on formal entries (19 CFR 24.23(b)(1)(i)(A)); minimum/maximum per entry $33.58/$651.50 for fiscal year 2026 (1 Oct 2025-30 Sep 2026, CBP Dec. 25-10) and $34.58/$670.86 from 1 Oct 2026 (FY2027 notice); base amounts $25/$485 CPI-adjusted; informal entries a flat fee (base $2-$9)
Primary lawAmount not confirmed
- 19 CFR 24.23, 24.23(b)(1)(i), (b)(2)

Controls

Beneficial ownership reporting under the Corporate Transparency Act applies only to a "reporting company" defined as an entity "(A) A corporation, limited liability company, or other entity; (B) Formed under the law of a foreign country; and (C) Registered to do business in any State or tribal juris…
Primary law
- 31 CFR 1010.380, 1010.380(a)(1), (c)(1)(ii)
Any trade or business receiving more than $10,000 in currency in one or related transactions must file Form 8300 within 15 days. There is no cash ceiling, only reporting.
> $10,000 cash
Primary lawAmount not confirmed
- 31 CFR 1010.330; 26 USC 6050I, 1010.330(a)(1)(i)
Gold bullion is not a 'monetary instrument' under the BSA, so the cross-border currency report (CMIR) does not apply to gold carried or shipped across the border; customs entry and EEI are the only declarations.
Primary law
- 31 CFR 1010.340; 31 CFR 1010.100(dd), 1010.340(a); 1010.100(dd)
COMEX gold delivery: one 100 oz bar or three 1 kg bars, weight tolerance 5%, minimum 995 fineness, approved brand from an approved producer complying with LBMA RGG, held in an approved depository reached through the chain of integrity.
Standard
- COMEX Rulebook, 113101; Rules 703.A, 705.A
SEC-reporting issuers that manufacture or contract to manufacture products in which gold is necessary must "conduct in good faith a reasonable country of origin inquiry" (Form SD Item 1.01(a)); if they know or have reason to believe the gold may come from the DRC or an adjoining country and may not …
Primary law
- Dodd-Frank s.1502; Exchange Act Rule 13p-1; Form SD (as adopted 2012), 17 CFR 240.13p-1; Form SD Items 1.01-1.02
Dealers in precious metals (gold of 500+ fineness among covered goods) must keep a written risk-based AML program with compliance officer, training and independent testing; retailers are covered only if they buy over $50,000 from non-dealers.
Purchased > $50,000 and sold > $50,000 of covered goods in the prior year
Primary lawAmount not confirmed
- 31 CFR 1027, 1027.100, 1027.210
HS 710812 and 710813 (non-monetary gold, unwrought other than powder, and semi-manufactured) are listed EAR 'luxury goods': "A license is required to export, reexport, or transfer (in-country) any item subject to the EAR listed in supplement no. 5 to this part to or within Russia or Belarus" (746.8(…
Primary law
- EAR 15 CFR 746.8(a)(7), (b)(3); Supplement No. 5 to Part 746, 746.8(a)(7)
Goods "mined, produced, or manufactured wholly or in part in any foreign country by convict labor or/and forced labor or/and indentured labor under penal sanctions shall not be entitled to entry" (19 U.S.C. 1307). Where information "reasonably but not conclusively indicates" such merchandise is bein…
Primary law
- Tariff Act of 1930 s.307 (19 U.S.C. 1307); 19 CFR 12.42, 19 U.S.C. 1307; 19 CFR 12.42(e)-(h)
US persons may not deal with SDN-listed parties; the 2023 multi-agency Africa Gold Advisory flags Wagner-linked gold from CAR and Sudan and conflict gold from Mali and Burkina Faso, warning of designation and penalties.
Official guidance
- IEEPA-based OFAC programs
Historical (2025 - Feb 2026): E.O. 14257 imposed an additional 10% on all imports from 5 Apr 2025 and country rates from 9 Apr 2025, with Annex II exceptions that from the start included 7108.12.10 (bullion and dore). CBP ruling N351466 (31 Jul 2025) classified cast 1 kg and 100 oz bars from Switzer…
Primary law
- E.O. 14257; E.O. 14346; E.O. 14389; Proclamation 11012; HTSUS U.S. notes 2(aa) and 52
Import into the US of gold of Russian Federation origin is prohibited unless licensed by OFAC; gold of Russian origin located outside Russia before 28 June 2022 is excluded.
Primary law
- E.O. 14068 as amended by E.O. 14114; OFAC Determination (effective 28 Jun 2022, amended 22 Dec 2023), E.O. 14068 s.1(a)(i)(A) (as amended by E.O. 14114 s.3(a)); delegation 31 CFR 587.802

Leg 3: Hong Kong SAR China

On the way

18
Onboard the supplier: KYC and source-of-supply review. Hong Kong law makes CDD mandatory for a Category B registrant only for specified cash transactions (AMLO s.5A(5A)); for bank-paid purchases the pack is the importer's own risk choice, with LBMA/OECD guidance applying where the buyer or refiner is bound by it
Who
Registered bullion dealer / trader (DPMS registrant)
Needs
DPMS Category A registration certificate; Commercial invoice
Issues
Supplier KYC pack held by the Hong Kong importer; Customer due diligence file (Category B, specified cash transaction); Supplier's commercial invoice
Official guidance
[inferred] No Hong Kong rule found that requires origin documents for imported gold; the KYC pack is commercial practice outside cash transactions. The legal scope of CDD is read in the Ordinance.
- AMLO s. 5A and Sch. 2 (only for specified cash transactions), s. 5A(5A)-(5B)
  “An AML/CTF requirement that applies to a DNFBP who is a Category B PMS registrant only applies when, by way of business, the registrant carries out, in Hong Kong with a customer, a specified cash transaction that is not an excluded transaction”
19
Fly the consignment into HKIA and deliver it to the importer's vault. If it is transhipment cargo (consigned on a through bill of lading or through air waybill to a place outside Hong Kong) or transit cargo, no Hong Kong declaration is required and the gold never enters the Hong Kong market
Who
Secure logistics carrier / forwarder
Needs
Supplier's commercial invoice; Air waybill; Export customs declaration accepted by the dispatching country's customs
Issues
Inbound air waybill
Primary law
- Import and Export (Registration) Regulations (Cap. 60E), reg. 3(a)-(b); Cap. 60 s. 2 (transhipment cargo, article in transit)
20
Receive the bars, weigh them and check serials against the bar list; credit the importer's allocated account
Who
Precious-metals vault operator
Needs
Inbound air waybill
Issues
Weight and quality verification record; Bar list (serials, weights, fineness); Allocated account weight list
Industry practice
[inferred] Vault intake practice is not documented in an official source; the clearing press release confirms designated vaults record deposits.
21
Lodge the import declaration within 14 days after the day of importation using the specified system (Trade Single Window, or during the transition a government-appointed service provider). Gold bars of fineness 995.0 or above (HKHS 7108 1210, 7108 2010) go on Form 1B with no declaration charge; other gold pays the charge. No customs duty or VAT; gold is not an exempted article
Who
Registered bullion dealer / trader (DPMS registrant)
Needs
Inbound air waybill; Supplier's commercial invoice
Issues
Hong Kong import declaration (Cap. 60E, lodged electronically within 14 days)
Primary law
- Import and Export (Registration) Regulations (Cap. 60E), regs 3, 4(1)-(2), 7, 8(1), (1AA), (4), 18
22
If the gold is paid for with physical currency or BNIs above HK$120,000 carried across the boundary, declare the cash (not the gold) to C&ED: advance CDS declaration for cargo, red channel for arriving travellers
Who
Registered bullion dealer / trader (DPMS registrant)
Issues
CBNI advance electronic declaration (CDS) for cash moved as cargo
Primary law
- Cap. 629, ss. 2, 4, 9, 11; Sch. 4
23
Mainland buyer (holder of a PBOC gold import qualification) obtains a PBOC Gold and Gold Products Import/Export Permit for the consignment: one shipment, one permit, used within 40 working days
Who
Mainland importer holding a PBOC gold import qualification
Issues
PBOC Gold and Gold Products Import/Export Permit (中国人民银行黄金及黄金制品进出口准许证)
Primary law
- PBOC/GACC gold import-export measures, Arts. 3, 8, 17
24
Agree the sale with the Mainland importer and release bars (typically 999.9 kilobars or bank-refined bars) to the cross-boundary carrier
Who
Registered bullion dealer / trader (DPMS registrant)
Needs
PBOC Gold and Gold Products Import/Export Permit (中国人民银行黄金及黄金制品进出口准许证); Allocated account weight list
Issues
Hong Kong exporter's commercial invoice; Packing list; Outbound air waybill / cross-boundary transport document
Official guidance
[unconfirmed] Bar form preferred by the Mainland market not confirmed from an opened source.
25
Lodge the Hong Kong export declaration within 14 days; C&SD records the flow as an export to the Mainland
Who
Registered bullion dealer / trader (DPMS registrant)
Needs
Hong Kong exporter's commercial invoice
Issues
Hong Kong export / re-export declaration (Cap. 60E, lodged within 14 days)
Primary law
C&SD FAQ Q1: Hong Kong is a separate customs territory, so a declaration is required for goods exported to the Mainland.
- Import and Export (Registration) Regulations (Cap. 60E), reg. 5(1)-(2)
26
Clear Mainland customs by presenting the PBOC permit, then register the gold on the State Council-approved gold spot exchange and complete its first trade there
Who
Mainland importer holding a PBOC gold import qualification
Needs
PBOC Gold and Gold Products Import/Export Permit (中国人民银行黄金及黄金制品进出口准许证); Hong Kong export / re-export declaration (Cap. 60E, lodged within 14 days); Export customs declaration accepted by the dispatching country's customs
Primary law
This step happens under Mainland law and belongs to the China module; kept here to show the hand-off.
- PBOC/GACC gold import-export measures, Arts. 6, 17

Taxes and fees

Customs duty on gold
Nil All gold imports and exports; the Ordinance applies only to alcoholic liquors, tobacco, aircraft spirit, light diesel oil, motor spirit, kerosene and methyl alcohol (s.3(1))
Primary lawAmount not confirmed
- Dutiable Commodities Ordinance (Cap. 109), ss. 3(1), 4(1)
Profits tax on gold trading profits
Corporations: 8.25% on the first HK$2,000,000 of assessable profits and 16.5% above (Sch. 8B s.2(a)); unincorporated businesses: 7.5% and 15% (Sch. 8A s.2); years of assessment from 1 April 2018 Trading profits of Hong Kong gold dealers; not a transaction tax
Primary lawAmount not confirmed
- Inland Revenue Ordinance (Cap. 112), s. 14; Schs. 8A, 8B
  “Subject to the provisions of this Ordinance, profits tax shall be charged for each year of assessment on every person carrying on a trade, profession or business in Hong Kong in respect of his assessable profits arising in or derived from Hong Kong for that year from such trade, profession or business (excluding profits arising from the sale of capital assets)”
VAT / GST on gold
None (Hong Kong has no VAT or GST) Import and sale of gold
UnverifiedAmount not confirmed
Import/export declaration charge
Nil on declarations relating to gold bars (reg. 8(4)); C&SD defines these as gold bars of fineness 995.0 or above, HKHS codes 7108 1210 and 7108 2010, declared on Forms 1B/2B. Other gold (e.g. dore below 995.0): HK$0.20 for value up to HK$46,000, then 12.5 cents per additional HK$1,000 or part, rounded up to 10 cents, capped at HK$200 per declaration (reg. 8(1)(b)-(d), (1AA)) Each import and export declaration
Primary lawAmount not confirmed
- Import and Export (Registration) Regulations (Cap. 60E), reg. 8(1), (1AA), (4); reg. 7
  “No charge shall be payable under paragraph (1)(b), (c) or (d) in respect of a declaration relating to gold bars within the meaning of the Imports and Exports Classification List”

Controls

A Category B registrant must, before a specified cash transaction (cash of HK$120,000 or more) with a customer, identify and verify the customer and any beneficial owner, obtain the purpose of a business relationship and verify anyone acting for the customer (Sch. 2 ss.2, 3(1)(b)); obtain senior-man…
Cash payment of HK$120,000 or more
Primary law
- AMLO (Cap. 615) s. 5A and Sch. 2; C&ED Guideline for Category B registrants, s. 5A(5A)-(5B); Sch. 2 ss. 2, 3, 5, 10, 15, 19, 20; s. 53ZVF
  “for a period of at least 5 years beginning on the date on which the transaction is completed”
A non-Hong Kong dealer (an individual not ordinarily resident, or a foreign legal person that is neither a registered non-Hong Kong company nor a re-domiciled company; no place of business in Hong Kong; business in Hong Kong on no more than 60 days a year) is outside registration but must report eac…
HK$120,000 cash
Primary lawAmount not confirmed
- AMLO (Cap. 615) Part 5C, ss. 53ZTZ, 53ZUA(2), 53ZVK; Sch. 3J
Any person who knows or suspects that property represents proceeds of, or was or is intended to be used in connection with, an indictable offence (OSCO s.25A(1)) or drug trafficking (DTROP s.25A(1)), or that property is terrorist property (UNATMO s.12(1)), must disclose it to an authorized officer (…
Primary law
- OSCO (Cap. 455), DTROP (Cap. 405), UNATMO (Cap. 575), Cap. 455 s. 25A; Cap. 405 s. 25A; Cap. 575 s. 12
  “Where a person knows or suspects that any property— (a) in whole or in part directly or indirectly represents any person’s proceeds of; (b) was used in connection with; or (c) is intended to be used in connection with, an indictable offence, he shall as soon as it is reasonable for him to do so disclose that knowledge or suspicion … to an authorized officer”
Hong Kong applies only UN Security Council sanctions, through regulations the Chief Executive makes under Cap. 537 on instructions from the Ministry of Foreign Affairs (ss.2-3); dealing with funds or economic resources of designated persons without a licence is an offence under those regulations (C&…
Primary law
- United Nations Sanctions Ordinance (Cap. 537), ss. 2-3
  “the Ministry of Foreign Affairs of the People’s Republic of China”
Currency and bearer negotiable instruments above HK$120,000 (Sch. 4) must be declared by arriving travellers (s.4), disclosed on request by other arrivals and by departing travellers (ss.5-6), and declared in advance electronically when moved as cargo in one batch (ss.9-11). "CBNI" means notes or co…
HK$120,000 of CBNIs
Primary lawAmount not confirmed
- Cap. 629, ss. 2, 4-6, 9-11; Sch. 4
The central clearing system accepts only about-400-oz bars meeting international standards (in effect LBMA Good Delivery) into designated vaults, held unallocated and commingled.
Official guidance
- Clearing Rulebook
No new commodity exchange may be established or operated for gold, silver or the other listed commodities (Cap. 82 s.4 and Schedule items 6, 13; fine HK$500,000 plus HK$50,000 a day), except an exchange "which was in operation on 20 June 1973" (s.3(d)) or a recognized futures market under the Securi…
Primary law
- Commodity Exchanges (Prohibition) Ordinance (Cap. 82), ss. 3(d)-(e), 4; Schedule
  “(e) a recognized futures market”
Anyone who by way of business trades in, imports, exports, manufactures, refines or carries out value-adding work on precious metals (gold "in a manufactured or unmanufactured state"), issues or trades precious-asset-backed instruments, or acts as intermediary (s.53ZU(1)) must be registered before c…
HK$120,000 per transaction or linked transactions
Primary lawAmount not confirmed
- AMLO (Cap. 615) Part 5C, ss. 53ZTZ, 53ZU, 53ZUA, 53ZUE; Schs. 3H, 3I
Only bars from HKGX authorised minters (13 members) are good delivery on the exchange, by type: 99 gold 5-tael, 999.9 gold kilo, 999.9 gold 5-tael and 999.9 silver 15 kg.
Industry practice
- HKGX rules
A Legislative Council question of May 2026 refers to "the current 50-gram limit" on gold products for personal use carried by Mainland visitors, and asks about "simplifying the tax collection process for amounts exceeding the limit"; the limit is a Mainland rule. The Government replied only that Hon…
50 g (per LegCo question; Mainland rule not read)
SecondaryAmount not confirmed
Gold entering the Mainland from Hong Kong under general trade needs a PBOC Gold and Gold Products Import/Export Permit presented to customs (Art. 3), issued only to qualified importers (Art. 8, e.g. financial-institution members or market makers of the State Council-approved gold exchange); "one bat…
Primary law
- PBOC/GACC gold import-export measures (Order [2015] No. 1, amended 2020), Arts. 3, 4, 6, 8, 17, 20
No import or export licence, permit or duty applies to gold. Licences are needed only for articles listed in the regulations under Cap. 60 (s.6C: Cap. 60A Sch. 1; s.6D: Cap. 60A Sch. 2; s.6A: strategic commodities), and gold is not listed in Cap. 60A Schedules 1-2. The only customs formality is the …
Primary law
- Import and Export Ordinance (Cap. 60) and regulations, Cap. 60 ss. 6A, 6C, 6D; Cap. 60A Schs. 1-2; Cap. 60E regs 3-5

Leg 4: China

Where the goods arrive

Doré bar - unstamped → 999.9 kilobar

27
Hold the PBoC gold import/export qualification (bank that is an SGE financial member or market maker, or qualified mining group or refiner)
Who
Bank holding PBoC gold import/export qualification (SGE financial member or market maker)
Primary law
- Gold and Gold Products Import/Export Measures, Arts. 7, 8, 10
28
Apply to the PBoC for a permit for the batch: application form, import contract and (on repeat applications) nothing further unless details changed
Who
Bank holding PBoC gold import/export qualification (SGE financial member or market maker)
Issues
Gold and Gold Products Import/Export Application Form (《黄金及黄金制品进出口申请表》) with contract; Gold import/export contract (required with the permit application)
Primary law
- Gold and Gold Products Import/Export Measures, Art. 10
29
Examine (verification by two or more staff where needed) and decide within 20 working days; issue the permit, one per batch, usable within 40 working days
Who
People's Bank of China (permit issuer and reserve holder)
Needs
Gold and Gold Products Import/Export Application Form (《黄金及黄金制品进出口申请表》) with contract; Gold import/export contract (required with the permit application)
Issues
PBoC permit (import batch)
Primary law
- Gold and Gold Products Import/Export Measures, Arts. 3, 14-17
30
Pay the foreign seller through the bank under foreign-exchange rules
Who
Bank holding PBoC gold import/export qualification (SGE financial member or market maker)
Needs
Gold import/export contract (required with the permit application)
Issues
Import payment through an FX-authorised bank
Primary law
[not-read] SAFE detailed goods-trade FX rules (current-account guidelines) not held; the FX Regulations require a genuine transaction basis checked by the bank.
- Gold and Gold Products Import/Export Measures; FX Regulations, Measures art. 23; FX Regulations arts. 12, 14
31
Declare the gold to Customs (HS 7108) presenting the PBoC permit; import-stage VAT is exempt for gold (incl. standard gold) and gold ore
Who
Bank holding PBoC gold import/export qualification (SGE financial member or market maker)
Needs
PBoC permit (import batch); Export customs declaration accepted by the dispatching country's customs; Air waybill; Refiner's certificate for the bars it produced (serials, fineness, weights, year); Commercial invoice
Issues
Customs import declaration (进口货物报关单), HS 7108
Primary law
[unconfirmed] Import duty rate for 7108 not held (cn.gap-tariff). [unconfirmed] Continuation of the import-stage VAT exemption after 1 Jan 2026 (cn.gap-import-vat-2026; MOF/GAC/SAT 2026 No. 17 read only in summary [summary]).
- Gold and Gold Products Import/Export Measures; Customs Law; Caishui [2002] 142, Measures arts. 3, 17; Customs Law art. 24; Caishui 142 point 1
32
Register the imported gold on SGE and complete its first trade there (duty to balance domestic physical supply)
Who
Bank holding PBoC gold import/export qualification (SGE financial member or market maker)
Needs
Customs import declaration (进口货物报关单), HS 7108
Issues
SGE registration and first-trade record of imported gold; SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)
Primary law
- Gold and Gold Products Import/Export Measures, Art. 6
33
Report execution of the permit to the PBoC
Who
Bank holding PBoC gold import/export qualification (SGE financial member or market maker)
Needs
PBoC permit (import batch)
Issues
Report to PBoC on use of the import/export permit
Primary law
- Gold and Gold Products Import/Export Measures, Art. 19
34
Receive and assay doré or raw gold under the refining or purchase agreement
Who
SGE-accredited refiner (standard gold ingot / bar refiner)
Needs
Refining Agreement (fee schedule, assay/settlement formula); VAT-exempt sales invoice for non-standard gold or gold ore (producer sale)
Unverified
Chinese refiner intake practice not documented in sources read.
35
Refine into SGE standard ingots or bars (Au99.99 1 kg; Au99.95 3 kg; Au99.5 12.5 kg; Au100g/Au50g at 999.9) under the refiner's SGE accreditation
Who
SGE-accredited refiner (standard gold ingot / bar refiner)
Form
Doré bar - unstamped → 999.9 kilobar
Official guidance
- SGE Detailed Delivery Rules; SGE Refiner Measures 2025, Delivery Rules Art. 11 and Annex 1; Refiner Measures arts. 2, 26-27
36
Issue the certificate of quality and packing list (bar list) for the bars
Who
SGE-accredited refiner (standard gold ingot / bar refiner)
Issues
Refiner's certificate of quality and packing list for SGE standard bars; Bar list (serials, weights, fineness)
Official guidance
- SGE Detailed Delivery Rules, Art. 30
37
Open an FT account at a margin custodian bank and trade International Board contracts (iAu99.99, iAu99.5) in offshore RMB
Who
SGE international member or international client (SGEI, Shanghai FTZ)
Issues
Free Trade (FT) account statement in offshore RMB (SGEI)
Official guidance
- SGE Member Management Measures (2026); SGEI Business Management Measures, Member Measures Arts. 3-4; SGEI Measures arts. 4, 20-21
38
Bring bars from abroad into an International Board vault (Customs-supervised, bonded) without a PBoC permit (exempt channel), through the vault's designated carrier and customs broker, giving SGE the invoice (incl. origin), packing list, bar list and non-wood packaging declaration; load-in needs SGE authorisation and bars from SGE-accredited or recognised international suppliers
Who
SGE international member or international client (SGEI, Shanghai FTZ)
Needs
Air waybill; Refiner's certificate for the bars it produced (serials, fineness, weights, year)
Issues
IB vault entry papers; SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)
Primary law
[not-read] Customs' own entry formalities for the bonded zone (declaration form, supervision code) not held; the SGE guidelines say the vault's appointed customs broker files them.
- Gold and Gold Products Import/Export Measures; SGE IB Vault Guidelines; SGE Vault Measures; Delivery Rules, Measures art. 20(2); Guidelines arts. 4-9; Vault Measures arts. 4, 12; Delivery Rules Art. 27 and Annex 2
39
Hold the bars in an International Board vault (3 bonded vaults: trading vaults in Shanghai (2) and Shenzhen (1); safekeeping vault in Shanghai). SGE's January 2026 fee schedule lists IB storage rates, while the IB page says storage and in/out fees are currently waived
Who
SGE designated vault / International Board certified vault operator
Official guidance
[conflict] cn.div-conflict-ib-fees: fee schedule rates versus the waiver stated on the IB page.
- SGE Vault Measures; SGE fee schedule (Jan 2026), Vault Measures Art. 3
40
Withdraw for re-export abroad (exempt channel: invoice and SGE withdrawal papers; carrier appointed by the vault) or for entry into the domestic market (only by a member or client holding the gold import/export qualification, with the PBoC permit copy 1 and a customs import declaration); the destination is reported to SGE and Customs
Who
SGE international member or international client (SGEI, Shanghai FTZ)
Issues
SGE Application for Load-Out and Application of Take-delivery
Primary law
- Gold and Gold Products Import/Export Measures; SGE IB Vault Guidelines; Delivery Rules; Vault Measures, Measures arts. 4, 20; Guidelines arts. 10-12, 17-19; Delivery Rules Art. 42; Vault Measures Arts. 17-18
41
Deposit bars at an SGE designated vault through a registered designated deposit person, with the Load-In application (3 copies), quality certificate and packing list; the vault checks gross weight (tolerance ±0.1 g for ingots, ±0.05 g for bars) and accepts only bars from SGE-accredited refiners or suppliers accredited by an SGE-recognised international market
Who
SGE comprehensive member (producer, processor, jeweller or trader)
Needs
Refiner's certificate of quality and packing list for SGE standard bars; Bar list (serials, weights, fineness)
Issues
SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)
Official guidance
- SGE Detailed Delivery Rules; Vault Measures, Delivery Rules Arts. 11, 29-31; Vault Measures Art. 4
42
Sell standard gold on SGE; the seller's sale is VAT-exempt (it invoices the exchange with an ordinary invoice against the exchange's settlement invoice); while no physical delivery out of the vault takes place, the exchange's sale is also exempt and the buyer receives a settlement invoice (结算发票) only
Who
SGE comprehensive member (producer, processor, jeweller or trader)
Needs
SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)
Issues
SGE trade and clearing record
Primary law
- MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 point 1; SAT No. 23 point 1
43
Buyer (member or client) applies through the member platform to take delivery and presents the Load-Out application, take-delivery application and withdrawer's ID at the vault
Who
SGE institutional client (e.g. jewellery manufacturer) trading through a member
Needs
SGE trade and clearing record
Issues
SGE Application for Load-Out and Application of Take-delivery
Official guidance
- SGE Detailed Delivery Rules, Arts. 37, 43, 45
44
On delivery out of the vault to a member that declared investment use on the delivery-out slip, the exchange's sale is subject to VAT levied and immediately refunded to the exchange (urban construction tax and education surcharges exempt) and SGE issues the member a VAT special invoice labelled 会员单位投资性黄金
Who
Shanghai Gold Exchange (and SGEI)
Needs
SGE Application for Load-Out and Application of Take-delivery
Issues
SGE VAT special invoice labelled 会员单位投资性黄金 (member withdrawal for investment use)
Primary law
- MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 points 1(1), 5, 7; SAT No. 23 point 2(1)-(2)
45
Deduct the input VAT shown on the SGE special invoice after use confirmation on the tax platform; onward sales of the gold, or of investment gold products made from it, are invoiced with ordinary invoices only (no special invoices, except legal gold coins)
Who
SGE comprehensive member (producer, processor, jeweller or trader)
Needs
SGE VAT special invoice labelled 会员单位投资性黄金 (member withdrawal for investment use)
Issues
Member's input-VAT deduction on the SGE special invoice (VAT return schedule 2, after use confirmation)
Primary law
- SAT Announcement 2025 No. 23; MOF/SAT Announcement 2025 No. 11, SAT No. 23 point 2(3)-(4); 2025 No. 11 point 1(1)
46
On delivery out of the vault for non-investment use (declared on the delivery slip), or to a client, the exchange's sale is exempt and SGE issues an ordinary invoice labelled 会员单位非投资性黄金 or 客户标准黄金; a general-taxpayer buyer computes input VAT at 6% of the invoice amount
Who
Shanghai Gold Exchange (and SGEI)
Needs
SGE Application for Load-Out and Application of Take-delivery
Issues
SGE VAT ordinary invoice labelled 会员单位非投资性黄金 or 客户标准黄金 (non-investment use or client withdrawal)
Primary law
- MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 point 1(2)-(3); SAT No. 23 points 3-4
47
Report the change of use to the exchange before it happens and apply, once, within 6 months, to change the declared use; red-letter invoice reversal and re-issue
Who
SGE comprehensive member (producer, processor, jeweller or trader)
Issues
Application to change declared use (investment / non-investment), once within 6 months
Primary law
- MOF/SAT Announcement 2025 No. 11, Point 8
48
Sell onward (bars or jewellery) charging VAT at 13%; gold jewellery also bears consumption tax of 5% at retail, on the sales value excluding VAT
Who
SGE institutional client (e.g. jewellery manufacturer) trading through a member
Primary law
[unconfirmed] Later changes to the consumption-tax rate table not checked.
- VAT Law; Consumption Tax Regulations; Caishui [1994] 95, VAT Law art. 10(1); Consumption Tax rate table item 4.1; Caishui [1994] 95 points 1-2, 7

Taxes and fees

Consumption tax on gold jewellery
5% Gold jewellery at retail
Primary lawAmount not confirmed
- Consumption Tax Regulations; Caishui [1994] 95, Rate table item 4.1; Caishui [1994] 95 points 1-4, 7
Export of gold-containing goods: VAT-exempt without refund
VAT-exempt (no export refund; input VAT not refunded) Goods containing gold or platinum listed in annex 8, incl. HS 71081100, 71081200, 71081300 and 71082000; diamonds and diamond jewellery
Primary law
- MOF/SAT Announcement 2026 No. 11, Art. 6(1)1(4)
No export VAT rebate on gold
No rebate on gold; for gold jewellery only the processing value added is rebated
Primary law
- Caishui [2002] 142 point 3, replaced by Guoshuifa [2005] 125, Point 3
Import customs duty on unwrought gold (HS 7108)
Unverified
Import-stage VAT on gold and gold ore
Exempt Imported gold (incl. standard gold) and gold ore
Primary lawAmount not confirmed
- Caishui [2002] 142, Point 1
VAT on standard gold sold off-exchange
13% (standard VAT rate on goods) Standard gold not sold through SGE or SHFE
Primary lawAmount not confirmed
- MOF/SAT Announcement 2025 No. 11 point 2; VAT Law, 2025 No. 11 point 2; VAT Law art. 10(1)
Earlier VAT regime for SGE members' sales of standard gold (Caishui [2002] 142 point 2)
No physical delivery: exempt; physical delivery: the tax authority issued a special invoice at the actual price and VAT was levied and immediately refunded, with urban construction tax and education surcharges exempt (for sales through the exchange with its settlement voucher)
Primary law
- Caishui [2002] 142, Point 2
VAT on standard gold withdrawn by a member for investment use
VAT levied and immediately refunded to the exchange (即征即退), urban construction tax and education surcharges exempt; the exchange issues the member a special invoice (label 会员单位投资性黄金) whose VAT the member deducts; the member's onward sales carry ordinary invoices only Member withdrawals for direct sale or processing into 99.5%+ bars, ingots or legal gold coins
Primary law
- MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 points 1(1), 5; SAT No. 23 point 2
VAT on SGE / SHFE trades of standard gold without physical delivery
Exempt: the seller's sale to the exchange, and the exchange's sale while no physical delivery takes place; the buyer receives a settlement invoice (结算发票) Standard gold (AU99.99/99.95/99.9/99.5; 50 g, 100 g, 1 kg, 3 kg, 12.5 kg) traded on the exchange
Primary lawAmount not confirmed
- MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 point 1; SAT No. 23 point 1
VAT on standard gold withdrawn for non-investment use or by a client
Exempt at the exchange (ordinary invoice); general-taxpayer buyer deducts input VAT at 6%; onward sales taxed normally with special invoices Jewellery, industrial and other non-investment uses; all client withdrawals
Primary lawAmount not confirmed
- MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 point 1(2)-(3); SAT No. 23 points 3-4
VAT on producers' sales of non-standard gold and gold ore
Exempt Sales of gold other than standard gold, and gold ore (incl. associated gold), by gold producers and dealers
Primary lawAmount not confirmed
- Caishui [2002] 142, Point 1
VAT on gold producers' and dealers' sales of non-standard gold and gold ore (2026-2027)
Exempt Sales of gold other than standard gold (AU9999, AU9995, AU999, AU995 in 50 g, 100 g, 1 kg, 3 kg, 12.5 kg) and of gold ore (incl. associated gold) by gold producers and dealers
Primary lawAmount not confirmed
- MOF/SAT Announcement 2026 No. 10, 二(二)24

Controls

No permit is needed for processing trade, for movements between special customs supervision areas/bonded sites and abroad or between such areas, or for repair, return and temporary import/export; Customs supervises them.
Primary law
- Gold and Gold Products Import/Export Measures, Art. 20
Special preventive measures: for persons on the counter-terrorism list, the Foreign Ministry notices implementing UN Security Council targeted financial sanctions, and the PBoC high-risk list, institutions must immediately stop services and restrict transfers of funds and assets and report to the PB…
Primary law
- AML Law 2024; PBoC PM AML Measures; Anti-Foreign Sanctions Law, AML Law art. 40; Measures art. 27; AFSL arts. 11-12
Mining without a mining right: ordered to stop; confiscation of tools, equipment and the minerals taken; fine of 3 to 5 times the market value of the minerals illegally extracted, or RMB 100,000 to 1,000,000 where nothing was extracted or the value is under RMB 100,000; suspension if the activity co…
Primary law
- Mineral Resources Law 2024, Art. 64
Dealers in precious-metal spot trading are specific non-financial institutions (AML Law art. 64(3)). Under the PBoC Measures (in force 1 Aug 2025) they must run AML controls, assess risk at least every 3 years, carry out CDD incl. beneficial owners on cash of RMB 100,000 or more, report large cash t…
Cash of RMB 100,000 single or daily cumulative (Measures arts. 2, 15, 24)
Primary lawAmount not confirmed
- AML Law 2024; PBoC PM AML Measures; Import/Export Measures, AML Law arts. 34, 64; Measures arts. 2, 13-16, 24-26, 38; Import/Export Measures art. 22
SGE deposit and delivery accept only standard ingots/bars from SGE-accredited refiners, or from suppliers accredited by an SGE-recognised international market. The Delivery Rules (Annex 2) and the overseas criteria name LBMA Good Delivery refiners; overseas refiners can also be accredited directly (…
Official guidance
- SGE Detailed Delivery Rules; SGE Vault Measures; SGE Refiner Measures and Overseas Criteria, Delivery Rules Art. 11 and Annex 2; Vault Measures Art. 4; Overseas Criteria arts. 6, 19
Exports of unwrought gold are subject to the same PBoC qualification and per-batch permit; the export is VAT-exempt without refund (MOF/SAT 2026 No. 11 art. 6 and annex 8).
Primary law
- Gold and Gold Products Import/Export Measures, Arts. 3, 8
Foreign-exchange receipts and payments arising from gold imports and exports follow SAFE rules (Measures art. 23): current-account payments are unrestricted but need a genuine, lawful transaction basis checked by the bank and are made against valid documents (FX Regulations arts. 5, 12, 14); receipt…
Primary law
- Gold and Gold Products Import/Export Measures; FX Regulations, Measures art. 23; FX Regulations arts. 5, 9, 12, 14
Import and export of gold and gold products in the PBoC catalogue need a PBoC permit presented to Customs: one permit per batch, used within 40 working days, only for entities holding the PBoC qualification; the PBoC may restrict quantities for macro-economic reasons (art. 3). No other channel is la…
Every batch
Primary law
- Gold and Gold Products Import/Export Measures; Customs Law, Measures arts. 3, 4, 8, 17, 21; Customs Law art. 24
Gold carried into China by travellers is not limited in quantity but must be declared to Customs; gold may be carried out only against a PBoC certificate or up to the quantity declared on entry (Gold and Silver Regulations arts. 25-26). The Import/Export Measures (art. 4) leave rules for individuals…
Primary law
- Gold and Silver Regulations (rev. 2011); Import/Export Measures, Regulations arts. 25-26; Measures art. 4
Qualified importers/exporters must help balance domestic physical supply; imported gold must be registered and first traded on the State Council-approved gold spot exchange (SGE).
Primary law
- Gold and Gold Products Import/Export Measures, Art. 6
Import and export of national gold reserves are handled only by the PBoC; gold coins (incl. commemorative) only by an institution the PBoC designates (Measures art. 5). Gold coins are minted and issued only by the PBoC (Gold and Silver Regulations art. 21).
Primary law
- Gold and Gold Products Import/Export Measures, Art. 5

Leg 5: Switzerland

Back in the origin country: the proceeds of the export

49
Identify contracting party and beneficial owner; assess source of wealth/funds for the specific bullion; sanctions/PEP screening
Who
Swiss bank (bullion buyer)
Issues
Bank KYC file (CDB 20): name, date of birth, nationality, domicile and ID for natural persons; company name, registered office and proof for entities; Form A - declaration of the beneficial owner of the assets; Form K - controlling persons with 25%+ of an operating entity (CDB 20 Art. 20-21)
Standard
Downgraded 2026-09-28 from primary-law: the provisions cited are CDB 20 (a self-regulatory agreement of the SBA, held and read for Arts. 4, 7, 20-21, 27-28); the AMLA itself was not read for this step. The SBA says the revised CDB will not be available until 1 Jan 2027 at the earliest. [unconfirmed] Source-of-wealth assessment and sanctions/PEP screening were not found in the CDB 20 text read. [time-limited] The GwG consolidation of 1 Oct 2026 amends the AMLA widely; effects not assessed.
- AMLA; SBA Agreement on due diligence (CDB 20), CDB 20 Art. 4 (identification; precious-metals trading and cash transactions over CHF 15,000 are separate cases), Art. 7 (data recorded), Art. 20-21 (controlling persons 25%+, Form K), Art. 27-28 (beneficial owner, Form A)
50
Seller presents bar list, refiner's assay certificate, chain-of-custody documentation, commercial invoice, proof of title
Who
Swiss bank (bullion buyer)
Issues
Commercial invoice from the seller to the bank (VAT law requires one only if the buyer asks for it: MWSTG Art. 26(1); contents Art. 26(2); the sale of investment gold is VAT-exempt: Art. 23(2) Ziff. 12)
Secondary
A bar not from an LBMA Good-Delivery-listed refiner generally cannot be sold to a major bank without re-refining - this is market practice, not itself a statute Commercial invoice and delivery receipt are practice (no primary source); "proof of title" for allocated bars is the weight list plus the custody contract - no statutory title document found.
51
Verify bars against the bank's accepted-refiner list / Good Delivery List; settle loco Zurich or loco London, allocated or unallocated
Who
Swiss bank (bullion buyer)
Issues
Settlement confirmation / custody account entry; Allocated account weight list (specific bars = ownership) or unallocated account statement (contractual claim only)
Secondary
52
Record the transaction and the clarifications made; retain the records for at least ten years after the end of the business relationship or completion of the transaction
Who
Swiss bank (bullion buyer)
Primary law
The official fedlex consolidation of the GwG is now held on the server and the article was read there; this replaces the earlier reading on droit-bilingue.ch and fedlex by WebFetch. The ten-year retention is written in words in the law (zehn Jahren), so it is kept in words here and not as an amount: the verifier reads number words in English only.
- Anti-Money Laundering Act (AMLA/GwG) (articles in refs), GwG Art. 7 Abs. 1 (records of transactions and clarifications)
  “Der Finanzintermediär muss über die getätigten Transaktionen und über die nach diesem Gesetz erforderlichen Abklärungen Belege so erstellen, dass fachkundige Dritte sich ein zuverlässiges Urteil über die Transaktionen und Geschäftsbeziehungen sowie über die Einhaltung der Bestimmungen dieses Gesetzes bilden können.”
- Anti-Money Laundering Act (AMLA/GwG) (articles in refs), Art. 7 Abs. 3 (kept at least ten years)
  “Nach Beendigung der Geschäftsbeziehung oder nach Abschluss der Transaktion be- wahrt er die Belege mindestens während zehn Jahren auf.”
- Anti-Money Laundering Act (AMLA/GwG) (articles in refs), Art. 2 Abs. 2 Bst. a (banks are financial intermediaries)
  “Finanzintermediäre sind: a.10 die Banken nach Artikel 1a des Bankengesetzes”

Crossings between countries

Switzerland → United States Researched
Papers that cross: Passar export declaration (HS 7108); Veranlagungsverfuegung Ausfuhr; Air waybill (outbound)
United States → Hong Kong SAR China Not researched
Papers that cross: CBP Form 3461 entry / immediate delivery (or ACE electronic equivalent); CBP Form 7501 entry summary (HTSUS classification, origin, duties and fees); CBP release of entered goods (ACE cargo release); Delivery record airport to refinery or depository; Chain-of-integrity receipt at depository; Depository inspection, weight record and eligible-stock entry; EEI/ITN for re-export of foreign-origin gold
Hong Kong SAR China → China Researched
Papers that cross: Inbound air waybill; Hong Kong import declaration (Cap. 60E, lodged electronically within 14 days); CBNI advance electronic declaration (CDS) for cash moved as cargo; PBOC Gold and Gold Products Import/Export Permit (中国人民银行黄金及黄金制品进出口准许证); Hong Kong exporter's commercial invoice; Packing list; Outbound air waybill / cross-boundary transport document; Hong Kong export / re-export declaration (Cap. 60E, lodged within 14 days)