Guinea [Bureau d'Achat Agréé / approved comptoir (sole lawful exporter of artisanal gold, Code art. 60; D/2014/013 art. 8(7))] → Russian Federation → United Arab Emirates · Reconcile assays and pay the balance

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

Ask the research

Ask in your own words. The answer is the research itself: its records, word for word, with every source and how sure each one is.

The route, leg by leg

Each step, tax and control as the research records it, with its legal basis and how sure the research is.

Guinea (Doré bar - unstamped → Smelted button/bar) ⟶ Russia (Smelted button/bar) ⟶ United Arab Emirates (Smelted button/bar)

Not researched: Guinea → Russia

Leg 1: Guinea

Where the goods start

Doré bar - unstamped → Smelted button/bar

1
File the prior declaration of export with the BNE on the BNE form (exporter, date of exit, quantity and quality, value, carriers, consignee); the BNE forwards it within 24 hours to the BCRG, Customs and the LNG. Guinee7 describes this as the 'demande de réception et d'exportation', filed at least 72 hours before the gold arrives in Conakry, naming the flight, destination, MMG-approved receiving institution and NIF
Who
Purchaser in an accredited gold buying agency (comptoir d'achat et d'exportation d'or)
Needs
Tax Identification Number certificate; Arrêté authorising a Bureau d'Achat Agréé (gold comptoir)
Issues
Demande de réception et d'exportation (export request to the BNE)
Primary law
[summary] The 72-hour lead time and the flight/receiving-institution fields are from Guinee7 only. [conflict] gn.div-declaration-body.
- Décret D/2014/013/PRG/SGG, art. 6
2
Give prior declaration of the gold export to the BCRG; the export takes place in the presence of a Customs representative
Who
Purchaser in an accredited gold buying agency (comptoir d'achat et d'exportation d'or)
Issues
Prior declaration of gold export (to the BCRG under Code art. 186; on the BNE form under Décret D/2014/013 art. 6)
Primary law
[conflict] gn.div-declaration-body: D/2014/013 art. 6 routes the declaration through the BNE.
- Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT, art. 186
3
Attend the weighing of the lot by the LNG (with the BCRG and Customs) and sign the evaluation sheet
Who
BNE (national expertise bureau for gold and precious materials)
Needs
Demande de réception et d'exportation (export request to the BNE)
Issues
LNG identification sheet (fiche d'identification) of the ingot or lot
Primary law
[conflict] gn.div-export-fee: Guinee7's USD 750 BNE fee is not in any text held.
- Décret D/2014/013/PRG/SGG, art. 8(3)-(4)
4
Weigh the lot, determine its purity and value and send a copy of the signed evaluation sheet within one month to the Inspection Générale des Mines, the BES and the DNM
Who
Laboratoire National de Géologie
Issues
Certificate of analysis (Laboratoire National de Géologie)
Primary law
- Décret D/2014/013/PRG/SGG, art. 8(2)-(4)
5
Weigh the lot in the presence of the BCRG, Customs and the BNE, value it at the London fixing on the day of weighing, record it on the evaluation sheet signed by all four, and seal the parcel in a tamper-proof case stored at the BCRG
Who
Laboratoire National de Géologie
Needs
Prior declaration of gold export (to the BCRG under Code art. 186; on the BNE form under Décret D/2014/013 art. 6)
Issues
Fiche d'évaluation (weighing and valuation sheet) of the ingot or lot
Primary law
[conflict] gn.div-fixing: Code art. 164 takes the BCRG purchase price as the reference value.
- Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT; Décret D/2014/013/PRG/SGG, Code art. 164; Décret art. 8(2)-(5)
6
Pay the BCRG export fee. The 1% export tax on artisanal gold (Code art. 164), payable to the Receveur Spécial des Douanes, has not been collected since its suspension in 2016
Who
Purchaser in an accredited gold buying agency (comptoir d'achat et d'exportation d'or)
Needs
Fiche d'évaluation (weighing and valuation sheet) of the ingot or lot
Issues
Quittance libératoire / customs visa proving payment of the precious-metals or artisanal export tax
Official guidance
[conflict] gn.div-artisanal-tax (suspension date) and gn.div-export-fee (fee amount). [not-read] The suspension letter of 12 Feb 2016 is not held.
- Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT; Décret D/2014/013/PRG/SGG, Code arts. 164-165; Décret art. 8(6)-(8), (14)
7
The BCRG's Direction des Matières Précieuses checks the comptoir's shipment file (RCCM, articles, managers' ID, BNE authorisation, export licence, tax clearance), the source of the funds used to buy the gold, repatriation of earlier shipments within the legal time limit, a KYC form and the contract with the foreign partner; internal control approves before the shipment proceeds
Who
BCRG (central bank)
Needs
Arrêté authorising a Bureau d'Achat Agréé (gold comptoir); Export licence (licence d'exportation) of the comptoir
Issues
BCRG shipment file (dossier d'expédition) of an approved comptoir
Primary law
- BCRG Règlement N°103/2022/LBC-FT/CC/BCRG, arts. 3-5, 13
8
Lodge the export declaration (Bureau d'Achat, quantity and quality, HS code, copy of the evaluation sheet, carrier, destination, tax rate), visaed beforehand by the BNE; the Mines and Finance services must process it within 48 hours; Customs grants mainlevée and visas it after payment; the export takes place in the presence of Customs
Who
Purchaser in an accredited gold buying agency (comptoir d'achat et d'exportation d'or)
Needs
LNG identification sheet (fiche d'identification) of the ingot or lot; Certificate of analysis (Laboratoire National de Géologie); Fiche d'évaluation (weighing and valuation sheet) of the ingot or lot; Quittance libératoire / customs visa proving payment of the precious-metals or artisanal export tax
Issues
Export documents jointly signed by the exporter, BNE, LNG, Customs (DGD) and BCRG; Export customs declaration (DGD)
Primary law
[summary] Guinee7's joint co-signature is not in the decree.
- Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT; Décret D/2014/013/PRG/SGG; Customs Code, Code art. 186; Décret art. 8(11)-(18); Customs Code art. 132
9
Alert Customs and the anti-fraud brigade, which jointly monitor the export operation at the airport
Who
BCRG (central bank)
Needs
Export documents jointly signed by the exporter, BNE, LNG, Customs (DGD) and BCRG
Secondary
[summary] Airport alert from Guinee7 only.
10
Fly the gold from Conakry to the receiving institution abroad
Who
Airline carrying the gold from Conakry
Needs
Export documents jointly signed by the exporter, BNE, LNG, Customs (DGD) and BCRG; Export customs declaration (DGD)
Issues
Air waybill
Secondary
The air waybill is required in the BCRG file (Règlement 103/2022 art. 7); flight logistics from Guinee7.

Taxes and fees

Taxe à l'exportation sur la production artisanale d'or
1% (collection suspended since 2016) Artisanal gold exported by comptoirs
Primary lawAmount not confirmed
- Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT; Décret D/2014/013/PRG/SGG, Code art. 164; Décret art. 8
BCRG fee on gold exports (and reported BNE fee)
Reported variously: USD 500 per export operation (ITIE 2023 report, Tableau 24, citing a BCRG circular); 300 GNF per gram (same report, annex 12); USD 2,500 per export = BCRG USD 1,750 + BNE USD 750, with assay fees split BCRG 65% / BNE 35% (Guinee7) Every gold export; the fee covers reception, storage and secure transport to the airport (ITIE 2023)
SecondaryAmount not confirmed
- BCRG circular on the conditions for trading and exporting gold (Instruction N°037/BCRG du 04 février 2015, as cited); presidential decree (June 2020) and joint arrêté (April 2021) per Guinee7
Contribution au Développement Local (FODEL)
1% of annual turnover excluding tax for gold (0.5% only for category-1 substances, bauxite and iron) Industrial and semi-industrial gold mines
Primary lawAmount not confirmed
- Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT; Décret D/2017/285/PRG/SGG, Code art. 130; Décret arts. 2-4, 6
Taxe sur la production industrielle ou semi-industrielle des métaux précieux
5% Gold, silver and PGMs from industrial and semi-industrial mines; doré at export
Primary lawAmount not confirmed
- Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT; Décret D/2014/013/PRG/SGG, Code art. 161-I; Décret art. 7
Annual fees on gold comptoirs, buyers and collectors (redevance annuelle)
Comptoir GNF 25,000,000 a year; buyer (acheteur) GNF 5,000,000; collector GNF 2,500,000 Artisanal gold trade
Official guidanceAmount not confirmed
- Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT; Décret D/2014/013/PRG/SGG; Loi de finances 2011 (arts. 43-48, as cited), Code art. 159-II; Décret art. 2(2)
Profit tax (impôt sur les sociétés / BIC)
30% for holders of a mining exploitation title; ordinary law for comptoirs, collectors and balanciers
Primary lawAmount not confirmed
- Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT; Code Général des Impôts, Code art. 176; CGI arts. 87 bis, 92 bis

Controls

Approved comptoirs must repatriate the proceeds of precious-metal exports through the banking circuit within the legal time limit set by BCRG Instruction 037/2015; the BCRG may restrict a comptoir's next operations if proceeds are not repatriated within 45 days, and refuses further shipments of comp…
45 days from export
Primary lawAmount not confirmed
- BCRG Règlement N°098/2022/BCRG; Règlement N°103/2022/LBC-FT/CC/BCRG, Règl. 098 art. 8; Règl. 103 arts. 3-4, 13
Guinea's AML/CFT law of 2021 obliges financial institutions and designated non-financial businesses and professions to report cash transactions and incoming/outgoing wire transfers of GNF 150,000,000 or more to the CENTIF, and all operations with FATF high-risk countries (BCRG Instruction 111/2023).…
GNF 150,000,000 (cash transactions and wire transfers reported to the CENTIF)
Primary lawAmount not confirmed
- AML/CFT law 2021; BCRG Instruction N°111/DGSIF/DSB; BCRG Règlement N°103/2022; Décret D/2026/216; Code minier, Instr. 111 art. 2; Règl. 103 arts. 3, 9-10; D/2026/216 art. 7; Code art. 15
Refined gold for export must be 99.5%-99.99% fine, certified by a refinery authorised in Guinea, presented as a numbered ingot with the refinery's certificate of analysis (arts. 2, 3, 6). No Guinean refinery is known to be on the LBMA Good Delivery List, so exported bars are not Good Delivery.
Primary law
- Décret D/2026/216/PRG/SGG du 08 juillet 2026, arts. 2, 3, 6
Import and export of gold are subject to prior declaration to the BCRG and must take place in the presence of a representative of the Direction Générale des Douanes (Code art. 186). Décret D/2014/013 art. 6 instead requires prior declaration to the BNE on a BNE form, which the BNE forwards within…
Primary law
- Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT; Décret D/2014/013/PRG/SGG, Code art. 186; Décret art. 6
Gold is exported exclusively through Acheteurs organised in Bureaux d'Achat Agréés, whose opening is authorised by arrêté of the Minister on the BNE's proposal (Guinean and/or foreign persons); artisanal gold for export is bought from approved intermediaries (Code art. 60). Buying and selling ar…
Primary law
- Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT; Décrets D/2014/013, D/2014/012, D/2026/216, Code arts. 59-61; D/2014/013 art. 8; D/2014/012 art. 114; D/2026/216 art. 5
Gold for export is weighed and valued jointly: industrial ingots by the LNG with the BCRG in the presence of the BNE, Customs and Sécurité Minière; artisanal lots by the LNG in the presence of the BCRG, Customs and the BNE; the Brigade Anti-Fraude des Matières Précieuses may attend; results go …
Primary law
- Décret D/2014/013/PRG/SGG; Décret D/2026/216/PRG/SGG, D/2014/013 arts. 7-8; D/2026/216 art. 4
Titles and authorisations may be withdrawn by the issuing authority on the grounds listed in Code art. 88 (inactivity beyond 6/12 months, failure to start works, unpaid taxes, missing registers, unauthorised transfer, etc.) after formal notice (1 month for permits and authorisations, 45 days for ope…
Secondary
- Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT; Décret D/2014/012/PRG/SGG, Code art. 88; D/2014/012 art. 127
Every export of gold produced in Guinea must be preceded by compulsory local refining in a State-approved refinery (art. 3). Gold below 99.5% purity (ore, concentrate, doré or alloy) is 'or brut' and may not be exported; exported gold must be a numbered refined ingot of 99.5%-99.99% certified by a …
Gold below 99.5% purity (or brut)
Primary lawAmount not confirmed
- Décret D/2026/216/PRG/SGG du 08 juillet 2026, arts. 2, 3, 12-14
Every person subject to the 2026 gold decree must supply approved refineries established in Guinea in priority (Décret D/2026/216 art. 10, applying Code art. 139, which obliges companies mining raw ore to supply local processing units in priority); supply conditions are to be set by arrêté of the…
Primary law
- Décret D/2026/216/PRG/SGG; Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT, D/2026/216 arts. 10-11; Code art. 139
Holders of mining titles and their direct subcontractors must repatriate their foreign-currency receipts from mineral exports into BCRG accounts held with a first-rank foreign bank (Code art. 184); free transfer of dividends is guaranteed subject to this (art. 185). The Code sets no percentage: pres…
No share in the law; 50% (2023) and 60-70% (from March 2026) as reported
SecondaryAmount not confirmed
- Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT; Décret D/2026/216/PRG/SGG, Code arts. 184-185; Décret art. 6
A national gold traceability platform is to be set up by the Ministry of Mines to register producers, record declared production, follow movements of raw gold and generate certificates of origin; its procedure and rules are to be set by arrêté of the Minister (art. 8). All actors must apply respon…
Primary law
- Décret D/2026/216/PRG/SGG du 08 juillet 2026, arts. 7, 8

Leg 2: Russia

On the way

11
File the FPP import-control application in GIIS DMDK with the foreign-trade contract, specification, document on precious-metal content and special-registration record
Who
Importer of gold-bearing material for refining (refiner or special-registered company)
Needs
Special-registration register entry (FPP); Assay certificate (fineness and fine weight); Commercial invoice
Issues
FPP application for import control
Primary law
- EEC Board Decision 30, Annex 14, Annex 2 (Rules) para 4(a), Rules para 4(a)
12
State control at a specialised customs post (all goods except ores and concentrates), within 5 working days; act of state control
Who
Federal Assay Chamber
Needs
FPP application for import control
Issues
Act of state control on import
Primary law
- Presidential Decree 1137 para 19¹; EEC Board Decision 30, Annex 14, Annex 2 para 10, para 19¹
13
Declare the goods at a specialised customs post for release or processing, presenting the act of state control, and take delivery to the refinery
Who
Importer of gold-bearing material for refining (refiner or special-registered company)
Needs
Act of state control on import
Issues
EAEU goods declaration for import / customs processing
Primary law
[not-read] Import duty and import VAT treatment of gold-bearing material not read.
- EEC Board Decision 30, Annex 14 paras 4, 8, Regulation para 8
14
Screen buyer and destination: Russian-origin gold exported after the sanctions dates cannot be imported into the EU, UK, US, Switzerland or Japan, and Russian bars made from 7 Mar 2022 are not LBMA Good Delivery; sales go to non-sanctioning markets
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Primary law
15
Sign the export contract and issue the commercial invoice
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Issues
Export contract with foreign buyer; Commercial invoice
Primary law
16
Apply to Minpromtorg for an export licence (one-off for a contract, or a general licence under Decree 1126 or 867); Minfin approves the application in GIIS DMDK within 10 working days (Order 10n from 1 Sep 2026), except credit organisations' applications for refined gold, silver, platinum and palladium bars since 8 May 2026
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Needs
Export contract with foreign buyer; Special-registration register entry (FPP)
Issues
Minfin conclusion (permissive document) approving an export-licence application (Order 10n from 1 Sep 2026); EAEU export licence issued by Minpromtorg (one-off or general)
Primary law
Licence validity and issue time from EEC Council Decision 125 Rules paras 9 and 13: a one-off licence is valid up to 1 year from its start (may be limited to the contract term); a general licence up to 1 year; the licensing authority decides within 15 working days of receiving the documents unless the Commission decision introducing the measure sets another term. [unconfirmed] Decision 125's own in-force date depends on the Protocol of 25.05.2023 (see ru.law-eec-125).
- Presidential Decree 1137, Regulation paras 4 and 22; Minfin Order 10n, paras 4, 22
17
File the application letter for FPP state control through GIIS DMDK with: the export licence copy (table-1 goods), the contract, the specification, the invoice, the calculation of the value of the precious metals (within 5% of world prices), special-registration record or bank licence, proof of lawful ownership, the precious-metal content document, technical documentation, the subsoil licence (mining subjects) and the document on the State Fund's refusal to buy (mining and producing subjects)
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Needs
EAEU export licence issued by Minpromtorg (one-off or general); Export contract with foreign buyer; Commercial invoice; Document on the authorised bodies' refusal (non-exercise) to purchase; Passport for standard bar / certificate for measured bar of refined precious metal (FPP Order 154n; replaced by a single certificate under Order 144n from 1 Mar 2027)
Issues
Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK; Calculation of the value of precious metals in the consignment
Primary law
[transcription] EEC Board Decision 30 read in the ConsultantPlus copy published by the FPP; the FPP list reproduces the same paragraph.
- EEC Board Decision 30, Annex 14, Annex 2 (Rules) para 4(b); Minfin Order 11n (valuation), Rules para 4(b)
18
State control of the whole consignment within 5 working days: check against documents, origin, compliance with transaction rules, valuation, optional sampling; issue the act of state control (3 copies; the first for customs) or a refusal
Who
Federal Assay Chamber
Needs
Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK
Issues
Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber
Primary law
- EEC Board Decision 30, Annex 14, Annex 2 (Rules) paras 3, 8, 10; 41-FZ art. 26², Rules para 10
19
Lodge the export declaration at a specialised customs post, presenting the export licence and the act of state control
Who
Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
Needs
EAEU export licence issued by Minpromtorg (one-off or general); Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber; Commercial invoice
Issues
Export goods declaration (accepted and released by customs); Certificate of origin (general form) for non-EAEU destinations
Primary law
[not-read] The customs rules on the declaration itself were not read.
- EEC Board Decision 30, Annex 14 paras 4-5; Presidential Decree 1137 para 19¹, Regulation paras 4-5
20
Carry the sealed consignment to the airport and hand to the airline (valuable cargo)
Who
Secure carrier of valuables
Needs
Export goods declaration (accepted and released by customs)
Issues
Packing list; Air waybill
Unverified
The armed-escort rule (41-FZ art. 29(3)) covers transport to the airport; no rule on the hand-over to the airline was read.
- Federal Law 41-FZ, art. 29(3)

Taxes and fees

VAT on precious metals
0% on sales of precious metals by mining or producing taxpayers to the State Fund, regional funds, the Bank of Russia and banks (art. 164(1)(6)); 0% on goods exported under the export customs procedure (art. 164(1)(1)); 0% on ores and concentrates sold by miners to listed refiners for refining (art. 164(1)(6³)); exempt: sales of precious metals to the State Fund, CBR and banks by others, bank and CBR sales of bars to banks, sales of refined bars (except silver) by banks, refiners and Goznak to individuals, and bank sales of bars kept in the vault (art. 149(3)(9)); exempt: legal-tender precious-metal coins (art. 149(2)(11))
Primary lawAmount not confirmed
- Tax Code Part Two, ch. 21, arts. 149(2)(11), 149(3)(9), 164(1)(1), (6), (6³)

Controls

FPP state control of every import from and export to non-EAEU states of goods in tables 1 and 3 of section 2.10 (41-FZ art. 26²; Decree 1137 para 19(b)): the whole batch is presented (for ores and concentrates, HS 2616, the documents only) and controlled within 5 working days; checks of the batch a…
Primary law
- EEC Board Decision 30, Annex 14, Annex 2 (Rules) paras 3, 4, 7, 8, 10; Presidential Decree 1137 paras 19, 19¹, Rules paras 3, 10
From 1 May 2026 export from Russia of refined gold in bars with a total weight over 100 g by individuals, legal entities and entrepreneurs is prohibited, except (a) to EAEU member states through the international airports Moscow (Vnukovo), Moscow (Domodedovo), Moscow (Sheremetyevo) and Vladivostok (…
Total weight over 100 g
Primary lawAmount not confirmed
- Presidential Decree 193 of 25.03.2026; Government Decree 450 of 23.04.2026, para 2, para 4
Purchase and sale of precious metals (and jewellery and scrap) of RUB 1,000,000 or more is subject to mandatory control and reported to Rosfinmonitoring by the seller within 3 working days; individuals buying jewellery up to RUB 60,000 (RUB 400,000 with a personalised e-payment means) are not identi…
RUB 1,000,000
Primary lawAmount not confirmed
- Law 115-FZ, art. 6(1)(4) sixth paragraph; art. 7(1.4-2)
Only listed refiners, Goznak and credit organisations may sell refined (investment) bars to individuals, and retailers only bars received on commission or agency from them; buy-back dealers and pawnshops may pass bars bought from individuals only to refiners. Deals between individuals in precious me…
Primary law
- Government Decree 604 of 15.05.2024 (Rules paras 3-4, 8); 41-FZ art. 22(6), Rules para 4
No gold-specific cash-payment limit was found. The RUB 1,000,000 mandatory-control threshold applies whatever the means of payment.
Unverified
Export to non-EAEU states of goods in tables 1 and 2 of section 2.10 of the EAEU Single List (table 1 includes refined gold in bars, plates, powder and granules, unique and non-refinable nuggets, other unwrought gold incl. dore, scrap, ores and concentrates) requires a licence issued by Minpromtorg …
Primary law
- Presidential Decree 1137 (Regulation paras 4, 22, 23); EEC Board Decision 30, Annex 14 para 5; Minfin Order 10n, paras 4, 22, 23
Residents must receive export proceeds on their accounts in authorised banks (173-FZ art. 19(1)(1)). Under art. 19(8) this does not apply to contracts priced or payable in foreign currency, except for goods listed there; the list includes HS 7101-7103 and 7112 but not 7108 (gold). Where art. 19 appl…
Primary law
- Federal Law 173-FZ art. 19; Presidential Decrees 79 (para 2) and 430, art. 19(1), (8)
Traceability: participants must record precious-metal operations in GIIS DMDK, with UINs and electronic accompanying documents between participants; refiners report receipt and shipment of metal in any form.
Primary law
- 41-FZ art. 12², art. 20(2); Government Decree 270 of 26.02.2021, art. 12²
Refined metal in standard form must, before it enters circulation, be offered by a purchase proposal to the State Fund institution under Minfin and to the authority of the mining region (where a regional fund exists) - for the next year by 31 December, with an additional proposal within 10 working d…
Primary law
- Federal Law 41-FZ, art. 2(5), art. 20(4)-(5)
LBMA suspended six Russian refiners on 7 Mar 2022; their bars produced from that date are not Good Delivery; Russian bars already in loco London/Swiss before then remain Good Delivery, with clearing banks attesting conformity.
Standard
Mined and produced precious metals (except nuggets) must, after the necessary processing, go for refining to organisations on the Government list (41-FZ art. 20(1)); only listed organisations may refine (art. 4(4)); the refining agreement's mandatory terms and the refiner's reporting duties are set …
Primary law
- Federal Law 41-FZ, art. 20(1)
Switzerland: purchase, import, transit and transport into and through Switzerland of gold under Annex 26 (includes HS 7108) originating in Russia and exported from Russia after 4 August 2022 are prohibited (Art. 14d(1)); the same applies to such gold processed in a third country (Art. 14d(2)) and, s…
Primary law
- Swiss Ukraine Ordinance SR 946.231.176.72 (Stand 21.09.2026), Art. 14d
EU: it is prohibited to purchase, import or transfer, directly or indirectly, gold listed in Annex XXVI (HS 7108; 7112 91 gold waste and scrap; ex 7118 90 gold coins) that originates in Russia and was exported from Russia into the Union or to any third country after 22 July 2022 (art. 3o(1)); the sa…
Primary law
- Regulation (EU) 833/2014 as amended by 2022/1269, art. 3o
Japan: import of precious metals originating in Russia and shipped from Russia on or after 1 August 2022 requires the Minister of Finance's permission under FEFTA art. 19(2) (MOF Notice No 443 of 2006 as amended 25 July 2022, item 4); the government announced it on 5 July 2022 as an import ban.
Primary law
- MOF Notice No 443 of 2006 as amended 25 Jul 2022, item 4
UK: import of gold originating in Russia and exported from Russia on or after 21 July 2022 is prohibited (reg 46Z11, Chapter 4J inserted by SI 2022/850, in force 21 Jul 2022), with prohibitions on acquisition with intent to import, supply and delivery, technical assistance, financial services and br…
Primary law
- Russia (Sanctions) (EU Exit) Regulations 2019, regs 46Z11-46Z16, 46Z16A-46Z16C
US: import of gold of Russian Federation origin is prohibited from 28 Jun 2022, except gold located outside Russia before that date (OFAC determination under E.O. 14068 s. 1(a)(i)(A), amended version of 22 Dec 2023). U.S. persons may not deal with the Central Bank, the National Wealth Fund or the Mi…
Primary law
- E.O. 14068 and the OFAC determination; E.O. 14024 as amended by E.O. 14114, E.O. 14068 s. 1(a)(i)(A); E.O. 14024 s. 11
  “the importation into the United States of … products of Russian Federation origin”
Temporary ban from 1 June to 30 November 2026 on export from Russia of precious-metal waste and scrap (HS 7112) and electrical and electronic waste used mainly to recover precious metals (8549 21 000 0, 8549 29 000 0), with exceptions for samples of up to 500 g per batch exported by listed refiners …
Primary law
- Government Decree 558 of 16.05.2026, para 1
Legal entities, entrepreneurs and artist-jewellers operating with precious metals must be on the FPP special register kept in GIIS DMDK; those that should be registered and are not may not carry out operations (41-FZ art. 13¹(2)). Registration within 30 calendar days of state registration (Rules pa…
Primary law
- 41-FZ art. 13¹; Government Decree 1052 (Rules paras 2, 5), art. 13¹
Precious metals and products from them are transported by air, sea, inland water, rail or specialised equipped road vehicles under armed escort; raw materials with less than 1% gold (or 5% silver), jewellery, investment metals (within a weight limit set by the Government) and some other items may mo…
Primary law
- Federal Law 41-FZ, art. 29(3)

Leg 3: United Arab Emirates

Where the goods arrive

21
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)
22
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)
23
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)
24
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)
25
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.
26
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: Guinea

Back in the origin country: the proceeds of the export

27
Pay the export proceeds to the exporter's account
Who
Receiving institution abroad (refiner or buyer on the MMG-approved list)
Issues
Bank transfer record
Secondary
28
Repatriate foreign-currency export receipts into BCRG accounts held with a first-rank foreign bank (Code art. 184); the government's reported shares are 50% (enforced from 2023) and 60-70% through local banks from March 2026, with DDI-DDE filings
Who
Industrial or semi-industrial mining-title holder
Issues
DDI-DDE export intention / export declaration filings (2026 FX measures)
Secondary
[unconfirmed] The shares and the DDI-DDE requirement are from press; the obligation itself is primary law (art. 184).
- Code minier 2011 (L/2011/006/CNT) as amended by L/2013/053/CNT, art. 184, 185
29
Repatriate the export proceeds through the banking circuit within 45 days, the SWIFT message quoting the shipment file number; the BCRG releases the funds after checking the SWIFT copy, the shipment file and earlier repatriations, and the comptoir may sell the currency only to BCRG-listed compliant exchange bureaux
Who
Purchaser in an accredited gold buying agency (comptoir d'achat et d'exportation d'or)
Primary law
- BCRG Règlements N°098/2022 and N°103/2022, Règl. 098 art. 8; Règl. 103 arts. 4, 7-13

Crossings between countries

Guinea → Russia Not researched
Papers that cross: LNG identification sheet (fiche d'identification) of the ingot or lot; Certificate of analysis (Laboratoire National de Géologie); Fiche d'évaluation (weighing and valuation sheet) of the ingot or lot; Export documents jointly signed by the exporter, BNE, LNG, Customs (DGD) and BCRG; Export customs declaration (DGD); Air waybill
Russia → United Arab Emirates Researched
Papers that cross: FPP application for import control; Act of state control on import; EAEU goods declaration for import / customs processing; Minfin conclusion (permissive document) approving an export-licence application (Order 10n from 1 Sep 2026); EAEU export licence issued by Minpromtorg (one-off or general); Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK; Calculation of the value of precious metals in the consignment; Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber; Export goods declaration (accepted and released by customs); Certificate of origin (general form) for non-EAEU destinations; Packing list; Air waybill

Paperwork gaps

ru.st-31 expects Commercial invoice; the earlier legs don't model this paper