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Russian Federation [Raw-material export with Minfin inexpediency conclusion] → Australia (refine) → Turkey (Türkiye) · Exchange trade, bank and retail sale

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

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Russia (Doré bar - unstamped → Concentrate / black sand) ⟶ Australia (Concentrate / black sand → 999.9 kilobar) ⟶ Türkiye (999.9 kilobar)

Not researched: Russia → Australia, Australia → Türkiye

Leg 1: Russia

Where the goods start

Doré bar - unstamped → Concentrate / black sand

  1. 1

    Extract gold ore or placer sands within the licensed plot

    Who
    Subsoil user (gold mining company)
    Needs
    Subsoil-use licence (electronic); Special-registration register entry (FPP)
    Form
    Ore (in situ / run-of-mine) → Concentrate / black sand
    Primary law
    • Law 'On Subsoil', art. 11

  2. 2

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

    Who
    Subsoil user (gold mining company)
    Issues
    Batch number / GIIS UIN of the dore lot
    Form
    Concentrate / black sand → Doré bar - unstamped
    Primary law

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

    • Federal Law 41-FZ, art. 20(1)

  3. 3

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

    Who
    Subsoil user (gold mining company)
    Issues
    Refining (tolling) agreement miner-refiner
    Primary law
    • Government Decree 972, Procedure para 3, para 3

  4. 4

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

    Who
    Subsoil user (gold mining company)
    Needs
    Batch number / GIIS UIN of the dore lot; Refining (tolling) agreement miner-refiner
    Issues
    ESD for dispatch of dore/placer gold to the refiner
    Official guidance

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

    • Government Decree 270 of 26.02.2021

  5. 5

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

    Who
    Secure carrier of valuables
    Needs
    ESD for dispatch of dore/placer gold to the refiner
    Primary law
    • Federal Law 41-FZ, art. 29(3)

  6. 6

    Obtain the Minfin conclusion on the (in)expediency of industrial extraction in Russia: file through GIIS DMDK the sampling act, an accredited-laboratory test protocol on precious and associated metals, and a justification with the value of recoverable metals and processing and transport costs; Minfin decides within 10 working days

    Who
    Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
    Issues
    Minfin conclusion on the inexpediency of industrial extraction of precious metals from raw materials in Russia; Test protocol on precious-metal content
    Primary law
    • Minfin Order 10n, Annex 2; Presidential Decree 1137 para 23, Annex 2 paras 3, 5

  7. 7

    Obtain the export licence and FPP control (for ores and concentrates HS 2616 the FPP checks documents only, not the goods)

    Who
    Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
    Needs
    Minfin conclusion on the inexpediency of industrial extraction of precious metals from raw materials in Russia; Test protocol on precious-metal content
    Issues
    EAEU export licence issued by Minpromtorg (one-off or general); Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber
    Primary law
    • EEC Board Decision 30, Annex 14, Annex 2 (Rules) para 10; Presidential Decree 1137 para 23(a), Rules para 10

  8. 8

    Clear customs; between 1 Oct 2023 and 31 Dec 2024 the exchange-rate-linked export duty (0-7%) applied to precious-metal ores and concentrates (HS 2616)

    Who
    Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
    Needs
    Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber; EAEU export licence issued by Minpromtorg (one-off or general)
    Issues
    Export goods declaration (accepted and released by customs)
    Primary law

    [unconfirmed] No duty on HS 2616 after 31 Dec 2024 was found.

    • Government Decree 1538, para 1 and para 12, para 1

Taxes and fees

  • Exchange-rate-linked export duty on gold

    0% (average USD/RUB below 80), 4% (80-85), 4.5% (85-90), 5.5% (90-95), 7% (95 and above) of the customs value

    Primary lawAmount not confirmed
    • Government Decree 1538 of 21.09.2023, para 1; Decree 532 of 25.04.2024, para 1

  • Export duty on gold-bearing concentrates

    Same exchange-rate-linked bands (0-7%) as Decree 1538 para 1 - group 26 (except 2609 00 000 0) is in the list, which covers precious-metal ores and concentrates (HS 2616) Precious-metal ores and concentrates (HS 2616) exported outside the EAEU

    Primary lawAmount not confirmed
    • Government Decree 1538 of 21.09.2023, para 1, para 1

  • Mineral extraction tax (NDPI) on gold

    6.0% (art. 342(2)(5): "концентратов и других полупродуктов, содержащих в себе один или несколько драгоценных металлов"), times the rent coefficient KRENTA = 1 for these minerals (art. 342⁸(3)(2)) and the territory coefficient Ktd (art. 342(2²)) Gold-bearing semi-products at the end of the extraction operations (dore/ligature gold, placer and native gold, concentrates)

    Primary lawAmount not confirmed
    • Tax Code Part Two, ch. 26, arts. 337(2)(13), 340(5), 342(2)(5), 342⁸(3)(2)

  • NDPI surcharge on gold (2024)

    RUB 78,000 per kg of gold contained in the extracted semi-product (КДРМ = VДРМ x 78 000) Tax periods beginning 1 June - 31 December 2024; gold in semi-products under art. 337(2)(13) extracted on licensed plots

    Primary lawAmount not confirmed
    • Federal Law 96-FZ of 22.04.2024, art. 1(7), adding Tax Code art. 343(21), art. 343(21) (2024 wording)

  • NDPI surcharge on gold from 2025

    КДРМ = 0.1 x (ЦЗ / 1000 - 61 000) x VДРМ x Р: 10% of the excess of the month's average world gold price in USD per kg (ЦЗ is USD per tonne, art. 342¹⁰(1)) over USD 61,000 per kg, times the kg of gold contained, times the month's average USD/RUB rate

    Primary lawAmount not confirmed
    • Tax Code art. 343(21) as restated by Federal Law 176-FZ of 12.07.2024, art. 343(21)

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 2: Australia

On the way

Concentrate / black sand → 999.9 kilobar

  1. 9

    Onboard the foreign supplier: KYC, origin and chain-of-custody documents, export authorisation of the origin country, under LBMA RGG

    Who
    Australian gold refiner (LBMA Good Delivery-listed)
    Issues
    Supplier KYC pack for imported doré/scrap
    Standard

    RGG duties inferred from GD status; no Australian statute imposes refiner origin checks.

  2. 10

    Screen for Russian-origin gold: import, purchase or transport of Russian gold exported after 30 Sep 2022 is prohibited without a sanctions permit

    Who
    Importer of doré or bullion (usually the refiner or a dealer)
    Issues
    Screen for Russian-origin gold
    Primary law
    • Autonomous Sanctions Regulations 2011 regs 4A, 12A, 18(1)(b); Import Sanctioned Goods-Russia Designation 2022 Sch 1 item 16

  3. 11

    Lodge the import declaration (entry for home consumption) in the Integrated Cargo System for consignments above the entry thresholds; customs duty Free for 7108 and 7112.91; importation of precious metal (99.5%+, investment form) is a non-taxable importation for GST; dore is a taxable importation (GST 10% of the value of the taxable importation)

    Who
    Licensed customs broker
    Needs
    Screen for Russian-origin gold; Export customs declaration accepted by the dispatching country's customs; Air waybill; Commercial invoice
    Issues
    Import declaration, HS 7108 / 7112.91
    Primary law

    [inferred] GST on imported dore follows from ss.13-5/13-10 with the precious-metal definition; [not-read] duty rate from the ABF tariff page, not the Act.

    • Customs Act 1901 ss.68, 71A; Customs Tariff Act 1995 Sch 3; GST Act 1999 ss.13-5, 13-10, 13-20

  4. 12

    Refine doré to 999.9 kilobars/minted bars or 995+ Good Delivery bars; cast, mark (refiner mark, serial, fineness) and record

    Who
    Australian gold refiner (LBMA Good Delivery-listed)
    Needs
    Outturn / assay statement
    Issues
    Bar list for refined bars
    Form
    Doré bar - unstamped → 999.9 kilobar
    Industry practice
  5. 13

    Maintain LBMA Good Delivery and RGG compliance; publish the annual RGG compliance report with independent assurance

    Who
    Australian gold refiner (LBMA Good Delivery-listed)
    Issues
    Refiner RGG report and assurance
    Secondary
  6. 14

    Report suspicious matters to AUSTRAC (refiner bullion business is a reporting entity)

    Who
    Australian gold refiner (LBMA Good Delivery-listed)
    Issues
    Suspicious matter report
    Primary law

    [inferred] The refiner is a reporting entity because it buys and sells bullion in a bullion-dealing business (s.6 table 2 item 1); the Perth Mint enforceable undertaking confirms it for that refiner.

    • AML/CTF Act 2006, s.6(3) table 2 item 1; s.41

  7. 15

    Hold bars in allocated or unallocated metal accounts; for the Perth Mint, metal liabilities carry the WA Treasurer's guarantee

    Who
    Depository / vault operator (metal accounts)
    Needs
    Bar list for refined bars
    Issues
    Metal account statement
    Industry practice

    Metal-account practice from the Perth Mint pages; the guarantee itself read in s.22 (cash equivalent of gold due, payable and deliverable under the Act and currency-dealing moneys).

    • Gold Corporation Act 1987 (WA), s.22

  8. 16

    Keep origin records for imported material: under LBMA RGG the mine remains the origin of gold refined in Australia

    Who
    Australian gold refiner (LBMA Good Delivery-listed)
    Needs
    Supplier KYC pack for imported doré/scrap
    Standard

    RGG origin rule not re-read here.

  9. 17

    Prepare commercial invoice and bar list; no export permit or licence is required for gold

    Who
    Exporter of bars (refiner, dealer or miner selling offshore)
    Needs
    Bar list for refined bars
    Issues
    Commercial invoice (GST-free / input-taxed treatment stated)
    Primary law

    [inferred] Absence of a gold export permit read from the Regulations as a whole; commercial invoice and bar list are commercial practice.

    • Customs (Prohibited Exports) Regulations 1958 (no gold item)

  10. 18

    Lodge the export declaration in the Integrated Cargo System (required for consignments above $2,000 FOB) and obtain the export entry advice (authority to deal) with its number before loading; a declaration may be refused if the intended export day is more than 6 months ahead; if not exported within 30 days of the intended day, withdraw or amend within 7 days; keep commercial documents 5 years

    Who
    Licensed customs broker
    Needs
    Commercial invoice (GST-free / input-taxed treatment stated)
    Issues
    Export declaration and export entry advice (authority to deal, with export entry advice number)
    Primary law
    • Customs Act 1901, ss.113, 114, 114C, 116, 240(1A); Customs Regulation 2015 r. 82

      “an FOB value not exceeding $2,000 or such other amount as is prescribed”

  11. 19

    Obtain a certificate of origin only if the buyer or the destination requires one (e.g. to claim an FTA preference); an exporter claiming Australian origin for a preferential tariff in China, Hong Kong or the UK may be required by the ABF to produce origin records and answer questions for verification by the importing customs

    Who
    Exporter of bars (refiner, dealer or miner selling offshore)
    Issues
    Certificate of origin (on request)
    Primary law

    [not-read] Issuing bodies and forms for certificates of origin not researched (au.gap-cert-origin); no Australian export rule requires one for gold.

    • Customs Act 1901, Divisions 4J, 4K, 4M (ss.126AOA-126AOD, 126APA-126APD, 126ARA-126ARD)

  12. 20

    Ship by secure air freight under air waybill

    Who
    Secure precious-metals carrier / airline
    Needs
    Export declaration and export entry advice (authority to deal, with export entry advice number)
    Issues
    Air waybill
    Industry practice

    Carrier practice not documented in the sources read.

Taxes and fees

  • GST - first supply of precious metal after refining

    GST-free (0%, input credits allowed) First supply of precious metal after its refining by, or on behalf of, the supplier, where the refiner is a "refiner of precious metal" and the recipient a "dealer in precious metal" (each: an entity that satisfies the Commissioner of the activity - s.195-1)

    Primary lawAmount not confirmed
    • A New Tax System (Goods and Services Tax) Act 1999, s.38-385; s.195-1

  • GST on importation of precious metal

    Non-taxable importation (precious metal); otherwise GST 10% of the value of the taxable importation (customs value plus international transport and insurance, s.13-20) Imported gold that meets the precious-metal definition is a non-taxable importation because its supply would be input taxed or GST-free (s.13-10(b)); dore and other gold outside the definition is a taxable importation

    Primary lawAmount not confirmed
    • A New Tax System (Goods and Services Tax) Act 1999, ss.13-5, 13-10(b), 13-20

  • GST - other supplies of precious metal

    Input taxed (no GST charged; no input tax credits) Gold (in an investment form) of at least 99.5% fineness (s.195-1 precious metal); "investment form" is not defined in the Act - the ATO describes it as a coin, wafer, bar or other tradeable form with an internationally accepted hallmark (LBMA-approved for gold)

    Primary law
    • A New Tax System (Goods and Services Tax) Act 1999, s.40-100; s.195-1

  • GST reverse charge on supplies of goods containing valuable metal

    10% of the price, payable by the recipient A taxable supply of goods consisting wholly or partly of valuable metal (gold, silver, platinum) to a recipient registered or required to be registered, where the market value of the goods does not exceed the valuable metal threshold (i.e. is not at least 10% above the value of the metal in them) or the parties agree in writing - e.g. scrap, dore and other non-investment gold

    Primary lawAmount not confirmed
    • A New Tax System (Goods and Services Tax) Act 1999, Division 86 (ss.86-5, 86-10, 86-25); s.195-1 valuable metal

  • Customs duty on gold

    Free HS 7108.11.00, 7108.12.00, 7108.13.00, 7108.20.00 and 7112.91.00 (general rate Free; the rate footnote: FTA originating goods Free unless otherwise shown)

    Official guidanceAmount not confirmed
    • Customs Tariff Act 1995, Schedule 3

Controls

  • Buying or selling bullion (gold, silver, platinum or palladium as a bar, coin, ingot, plate, wafer or like form, bearing a mark guaranteeing fineness and traded by reference to the spot price) in the course of carrying on a bullion-dealing business is a designated service: enrolment, AML/CTF program…

    Primary law
    • AML/CTF Act 2006, s.5 (bullion); s.6(3) table 2 item 1; ss.39E, 41, 43, 51B

  • Buying or selling precious metal (gold, silver, platinum-group metals, or an alloy with at least 2% of them, manufactured or not), precious stones or precious products in the course of carrying on a business, where the purchase involves physical currency and/or virtual assets totalling $10,000 or mo…

    $10,000 in physical currency and/or virtual assets

    Primary law
    • AML/CTF Act 2006 as amended by the AML/CTF Amendment Act 2024, s.5A; s.6(3) table 2 item 2; Amendment Act s.2 and Sch 3 Pt 4 items 11-12

      “buying or selling one or more of the following items in the course of carrying on a business, where the purchase involves the transfer of physical currency or virtual assets (or a combination of physical currency and virtual assets) with a total value of not less than $10,000, whether the purchase is made in a single transaction or in several transactions that are linked or appear to be linked: (a) precious metal; (b) precious stones; (c) precious products”

  • Export markets accept Australian bars through the refiner's LBMA Good Delivery listing and exchange accreditations (CME, SGE, OSE, DGCX for the Perth Mint).

    Industry practice
  • No economy-wide cap on cash payments was found. Reporting entities must report threshold transactions (transfers of $10,000 or more in physical currency) to AUSTRAC within 10 business days (s.43; s.5). Moving monetary instruments worth $10,000 or more into or out of Australia must be reported (s.53)…

    $10,000 (reporting, not a limit)

    Primary law
    • AML/CTF Act 2006, ss.5, 43, 53

      “monetary instrument means any of the following: (a) physical currency; (b) a bearer negotiable instrument; (c) a thing prescribed by the AML/CTF Rules.”

  • No foreign-exchange control or repatriation requirement on gold export proceeds was identified.

    Unverified
  • No export permit or licence for gold (it is not a prohibited export). The owner must enter goods for export by an export declaration and may not load them without an authority to deal (export entry advice); consignments with an FOB value of $2,000 or less are exempt unless a permission is required. …

    FOB value above $2,000

    Primary law
    • Customs Act 1901, ss.113(1)-(2A), 113AA, 114, 114C, 116

      “an FOB value not exceeding $2,000 or such other amount as is prescribed”

  • Origin and CAHRA due diligence on supplies is imposed on Australian refiners by the LBMA RGG as a Good Delivery condition, not by Australian statute.

    Secondary
  • Importing, purchasing or transporting gold (HS 7108) that was exported from Russia after 30 Sep 2022 is a sanctioned import (Designation Sch 1 item 16; AS Regulations reg 4A(1)-(3)) and an offence unless authorised by a permit of the Minister for Foreign Affairs under reg 18(1)(b) (reg 12A); it exte…

    Primary law
    • Autonomous Sanctions (Import Sanctioned Goods-Russia) Designation 2022 Sch 1 item 16; Autonomous Sanctions Regulations 2011 regs 4A, 12A, 18; Autonomous Sanctions Act 2011 s.16

  • Supplying, selling or transferring an item of gold, precious metals and diamonds so that it is transferred to the Government of Syria (or its public bodies, agents or controlled entities) is a sanctioned supply, and importing or purchasing such an item from them is a sanctioned import; both are offe…

    Primary law
    • Autonomous Sanctions Regulations 2011, regs 4(4), 4A(4), 12, 12A, 18

Leg 3: Türkiye

Where the goods arrive

  1. 21

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

    Who
    Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)
    Needs
    Ministry operating licence - precious-metals intermediary institution (Faaliyet İzin Belgesi); Borsa İstanbul Membership Certificate (Borsa Üyelik Belgesi); Refiner's certificate for the bars it produced (serials, fineness, weights, year); Refiner's responsible-sourcing / due-diligence compliance report or audit; Bar list (serials, weights, fineness)
    Issues
    Customer identification and KYC file (Law 5549 Art 3; ROM Art 5; zero-tolerance know-your-counterparty rule of the exchange)
    Primary law
    • Tebliğ 2008-32/34 Art 6(4); Procedure 31.PRO.11 s. 2.2.2, 2.2.6.1, Tebliğ 2008-32/34 Art 6(4)

  2. 22

    Confirm the month's import quota allocation covers the shipment

    Who
    Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)
    Needs
    Monthly unwrought-gold import quota allocation
    Official guidance

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

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

  3. 23

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

    Who
    Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)
    Needs
    Customer identification and KYC file (Law 5549 Art 3; ROM Art 5; zero-tolerance know-your-counterparty rule of the exchange)
    Issues
    Borsa İstanbul Pre-importation Notification Form (Procedure Annex-3) submitted via the Single Window System (TPS)
    Primary law
    • Regulation of 2007 Art 12/A(1); Procedure 31.PRO.11 s. 2.2, 2.2.2, 2.2.3.3, Regulation Art 12/A(1)

  4. 24

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

    Who
    Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)
    Needs
    Borsa İstanbul Pre-importation Notification Form (Procedure Annex-3) submitted via the Single Window System (TPS)
    Issues
    Bank transfer record
    Primary law
    • Tebliğ 2008-32/34 Art 6(6)-(7); Regulation of 2007 Art 12/A(4)-(7), Tebliğ 2008-32/34 Art 6(6); Regulation Art 12/A(5)-(6)

  5. 25

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

    Who
    Secure logistics carrier / customs broker
    Needs
    Borsa İstanbul Pre-importation Notification Form (Procedure Annex-3) submitted via the Single Window System (TPS); Air waybill; Commercial invoice; Packing list; Export customs declaration accepted by the dispatching country's customs
    Issues
    Turkish customs import declaration (HS 7108)
    Primary law

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

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

  6. 26

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

    Who
    Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)
    Needs
    Turkish customs import declaration (HS 7108)
    Issues
    Allocated-account weight list or unallocated account statement
    Primary law
    • Decree 32 Art 7(2)(b); Procedure 31.PRO.11 s. 2.2.6-2.2.7, Art 7(2)(b)

  7. 27

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

    Who
    Borsa Istanbul Precious Metals and Diamond Market (clearing house for metal, custody vault)
    Needs
    Turkish customs import declaration (HS 7108)
    Issues
    Borsa Istanbul vault Control Form (Annex-1) and vault deposit entry; Mint (Darphane) assay report (ayar raporu / calibration analysis report) for non-standard unwrought metal
    Primary law
    • Regulation of 2007 Art 12/A(3); Procedure 31.PRO.11 s. 2.2.2, 2.2.6.2; Tebliğ 2008-32/34 Art 6(3), Regulation Art 12/A(3)

  8. 28

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

    Who
    Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)
    Needs
    Borsa Istanbul vault Control Form (Annex-1) and vault deposit entry
    Issues
    Borsa İstanbul Post-import Notification Form (Procedure Annex-2) - non-standard metal
    Official guidance
    • Procedure 31.PRO.11 s. 2.2.6.2

  9. 29

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

    Who
    Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)
    Needs
    Allocated-account weight list or unallocated account statement
    Issues
    Borsa Istanbul trade and settlement record (metal via exchange clearing, money via Takasbank)
    Primary law
    • Decree 32 Art 7(6); Procedure 31.PRO.11 s. 2.2.6, Art 7(6)

  10. 30

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

    Who
    Borsa Istanbul Precious Metals and Diamond Market (clearing house for metal, custody vault)
    Needs
    Borsa Istanbul custody vault agreement (Annexes 13, 16-17)
    Issues
    Allocated-account weight list or unallocated account statement
    Official guidance
    • Directive on Precious Metals Market Art 47; Regulation of 2007 Art 13(1)(e), Directive Art 47(1)

  11. 31

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

    Who
    Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)
    Needs
    Allocated-account weight list or unallocated account statement
    Issues
    ELTAS electronic instruction (vault deposit, withdrawal, transfer)
    Official guidance
    • Directive on Precious Metals Market

  12. 32

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

    Who
    Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)
    Issues
    Borsa İstanbul Precious Metals Customs Warehouse / Free Zone Entry Form (Procedure Annex-39)
    Primary law
    • Decree 32 Art 7(2)(e)-(f); Procedure 31.PRO.11 s. 2.2 (Annex-39), Art 7(2)(e)-(f)

  13. 33

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

    Who
    Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)
    Needs
    Allocated-account weight list or unallocated account statement
    Issues
    Borsa Istanbul trade and settlement record (metal via exchange clearing, money via Takasbank); Allocated-account weight list or unallocated account statement
    Official guidance
    • Directive on Precious Metals Market

  14. 34

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

    Who
    Bank that is a Borsa Istanbul Precious Metals Market member
    Issues
    Customer identification and KYC file (Law 5549 Art 3; ROM Art 5; zero-tolerance know-your-counterparty rule of the exchange)
    Primary law
    • Law 5549 Art 3; ROM Art 5(1); BDDK regulation on banks' precious-metals trading Art 4, ROM Art 5(1); BDDK regulation Art 4

  15. 35

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

    Who
    Authorised jewellery business (kuyum işletmesi with a Ministry of Trade yetki belgesi) - manufacturer, exporter or retailer
    Needs
    KMTS security label/mark and unique KMTS code; Jewellery trade authorisation certificate (kuyum ticareti yetki belgesi)
    Issues
    Commercial invoice; Bank transfer record
    Primary law
    • VUK General Communiqué No. 459 s. 4.1, 4.2(h); Kuyum Ticareti Yönetmeliği Art 5, VUK 459 s. 4.1

  16. 36

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

    Who
    Precious-metals intermediary institution (Ministry-licensed, Borsa Istanbul Precious Metals Market member)
    Issues
    Suspicious Transaction Report Form (Şüpheli İşlem Bildirim Formu) to MASAK
    Primary law
    • Law 5549 Arts 4, 8; ROM Arts 27-29, 46, ROM Art 28(2); Law 5549 Art 8

Taxes and fees

  • Customs duty on unwrought gold (HS 7108)

    0% statutory rate (kanuni vergi haddi) for all HS 7108 lines in the 2026 tariff schedule; applied rate not read Unwrought gold imported by the Central Bank or intermediaries

    Primary lawAmount not confirmed
    • Türk Gümrük Tarife Cetveli 2026 (CK 10781), column 4, page 430; Decree 32 Art 7(2)(a), Tariff schedule 7108.11-7108.20

  • VAT on gold bullion (import, delivery to the exchange, transfers between members, deliveries)

    Exempt Deliveries of gold bullion (külçe altın) and the import of bullion

    Primary lawAmount not confirmed
    • VAT Law 3065, Art 17(4)(g) (delivery); Art 16(1)(a) (import of goods whose delivery is exempt)

  • Borsa Istanbul membership and market fees

    Membership: entrance 520,000 TL, Precious Metals Market operation 2,100,000 TL, annual 75,000 TL (2026). Trading: exchange share on gold 1 bps between different members, 4 bps where buyer and seller are the same; custody of gold 1 bps; withdrawal of standard gold 2 bps, non-standard gold 2 bps; transfer without trade 2 bps

    Official guidanceAmount not confirmed
    • Borsa İstanbul Ücretlendirme Tablosu (KMKTP section; 1.5 membership fees)

Controls

  • Dealers in precious metals, stones and jewellery and precious-metals intermediaries are obliged parties: identification before the transaction (any amount in a continuing relationship, 185,000 TL or more otherwise), STR to MASAK within 10 business days at any amount, records kept 8 years. FATF (2019…

    Primary law
    • Law No. 5549 Arts 2(1)(d), 3, 4, 8; ROM Arts 4(1)(k),(m), 5, 28, 46, ROM Art 4(1)(k), 5(1), 28(2), 46

  • Collections and payments above 30,000 TL by taxpayers - and, since 18 Oct 2024, by non-taxpayers buying from them, e.g. a consumer buying gold from a jeweller - must go through a bank, payment institution or PTT; each party is fined separately for a breach. This is the general Tax Procedure Law rule…

    30,000 TL

    Primary lawAmount not confirmed
    • VUK General Communiqué No. 459, s. 4.1, 4.2(f), 4.2(h), 5

  • In Türkiye only banks, licensed refineries, precious-metals intermediaries, authorised institutions and Ministry of Trade-authorised jewellery businesses may buy and sell standard unwrought and printed precious metals; non-standard unwrought metal may not be sold to resident individuals other than …

    Primary law
    • Decree 32 Art 7(4)(a)-(f); Kuyum Ticareti Yönetmeliği Art 5, Decree 32 Art 7(4)(b)-(c)

  • Export proceeds must be brought to Türkiye through the intermediary bank within 180 days of actual export; until 31 Jan 2027 at least 35% of proceeds tied to an İBKB or DAB are sold to the bank and on to the CBRT (earlier: 40% from Jan 2022, 30% from June 2024, 25% from March 2025, 35% from May 20…

    180 days; 35% surrender

    Primary lawAmount not confirmed
    • Decree 32 Art 8; Tebliğ 2018-32/48 Art 3(1); TCMB Export Circular Art 4, Ek Madde 1-3, Geçici Madde 2-4, Tebliğ 2018-32/48 Art 3(1); Circular Geçici Madde 4

  • Only the CBRT and Ministry-licensed precious-metals intermediary institutions (Borsa İstanbul members) may import standard and non-standard unwrought precious metals, and they must deliver them to Borsa İstanbul within 3 business days; under inward processing, standard metal is also imported only …

    3 business days

    Primary lawAmount not confirmed
    • Decree No. 32; Tebliğ 2008-32/34, Decree 32 Art 7(2)(b)-(d); Tebliğ 2008-32/34 Art 6(8)

  • Unwrought precious metals may be imported only cash-in-advance, against goods, or free of payment - the last only for inward processing, capital contribution, or offset against export proceeds; payment documents go to the exchange (cash-in-advance by the declaration closing date; against goods withi…

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

  • Quota on unwrought gold imports of 12 tonnes a month from 7 Aug 2023, introduced because of the rise in imports and its effect on the trade and payments balances (Ministry letter). From April 2024 part of it goes to Ziraat Bankası and Vakıf Katılım to supply authorised jewellers. Press reports g…

    12 tonnes per month

    Official guidanceAmount not confirmed
    • Ministry quota decision under Tebliğ 2008-32/34 Art 6(11) and Regulation of 2007 Art 24

  • KMTS: every standard unwrought bar (except granulated silver) and printed product made by a Turkish refinery carries a Mint security label with a unique code and is recorded in KMTS; stock movements are recorded at the time of movement against dispatch notes; products not registered cannot be sold. …

    Primary law
    • Tebliğ 2023/1 Art 17, 18(21); Tebliğ 2026/1; KMTS procedures s. 5, 7, Tebliğ 2023/1 Art 17(2)-(4)

  • Acting without the required Ministry permission (e.g. as a Precious Metals Market member or a refinery) is fined 50,000-250,000 TL with a one-month closure of the premises; unauthorised export or import of precious metals is fined half to twice their value unless it is a smuggling offence; failing t…

    Primary law
    • Law 1567 Arts 3-4, Art 3

  • Imports of non-standard unwrought precious metal (doré, scrap, granules below standard) must present a Mint assay report to customs; only the Mint may issue it, except that private assay-house reports may be accepted for inward-processing imports up to 5 kg.

    Primary law
    • Tebliğ 2008-32/34 Art 6(3), Art 6(3)

  • Until 31 Dec 2026, processed gold (jewellery etc.) may be imported only against goods, by deferred letter of credit or by acceptance credit (free of payment only as the Ministry determines); for processed precious metals generally six payment methods are allowed.

    Primary law
    • Tebliğ 2008-32/34 Art 6(12) and Geçici Madde 2 (added by Tebliğ 2025-32/76); Decree 32 Art 7(7)(a) as amended by CK 10039, Geçici Madde 2

  • Standard gold is at least 995/1000. Imported standard bars (outside inward processing) must come from refineries on the Borsa İstanbul Refinery List and bear their mark; only standard metal made by the Mint, Ministry-licensed refineries and listed foreign refineries may be traded domestically. Fore…

    995/1000 minimum for gold

    Primary lawAmount not confirmed
    • Decree 32 Art 2(j), 7(4)(a); Tebliğ 2008-32/34 Art 6(4); Tebliğ 2023/1 Art 13(6)-(7), Tebliğ 2008-32/34 Art 6(4)

  • Intermediaries and Turkish refineries prepare a yearly supply-chain compliance report (by end of March) and have it audited by an authorised independent firm giving reasonable assurance (report by end of June), published and sent to the Ministry and the exchange. Without it, or with an adverse or di…

    Primary law
    • Tebliğ 2023/1 Arts 16, 18; Regulation of 2007 Arts 16, 21(6); Directive on the Responsible Supply Chain Assurance Engagement Arts 33-34; Procedure s. 3.7, Tebliğ 2023/1 Art 16(4), (7); Regulation Art 16(2)-(3)

  • US secondary-sanctions exposure: in Oct 2019 the US DOJ indicted state-owned Halkbank over a scheme (c. 2012-2016) in which Iranian oil and gas proceeds held at the bank were used to buy gold for Iran, or gold not exported to Iran, and fake food/medicine transactions, moving about USD 20 bn; the US …

    Secondary
  • The CBRT, and if it does not use it the Mint, has a pre-emption right on precious metals produced from domestic ore; the CBRT does not use it for ore gold below 1 kg.

    Primary law
    • Tebliğ 2023/1 Art 14(3); Procedure 31.PRO.11 s. 9.3, Tebliğ 2023/1 Art 14(3)

  • Travellers may bring in and take out non-commercial jewellery of precious metals and stones worth up to USD 15,000; taking out more requires that it was declared on entry or bought in Türkiye. Unwrought gold may only be imported through the licensed channel.

    USD 15,000

    Primary lawAmount not confirmed
    • Decree No. 32, Art. 7(5)

      “Yolcular, beraberlerindeki kendilerine ait değeri 15.000 ABD dolarını aşmayan ve ticari amaç taşımayan ziynet eşyası niteliğinde kıymetli madenlerden ve taşlardan yapılmış eşyaları yurda getirebilirler ve yurtdışına çıkarabilirler.”

Leg 4: Russia

Back in the origin country: the proceeds of the export

  1. 37

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

    Who
    Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
    Issues
    Receipt of export proceeds
    Primary law

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

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

Crossings between countries

  • Russia → Australia Not researched

    Papers that cross: Minfin conclusion on the inexpediency of industrial extraction of precious metals from raw materials in Russia; Test protocol on precious-metal content; EAEU export licence issued by Minpromtorg (one-off or general); Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber

  • Australia → Türkiye Not researched

    Papers that cross: Import declaration, HS 7108 / 7112.91; Bar list for refined bars; Commercial invoice (GST-free / input-taxed treatment stated); Export declaration and export entry advice (authority to deal, with export entry advice number); Certificate of origin (on request); Air waybill

Paperwork gaps

  • au.st-21 expects Air waybill; the earlier legs don't model this paper

  • au.st-21 expects Commercial invoice; the earlier legs don't model this paper

  • tr.st-05 expects Packing list; the earlier legs don't model this paper

Russian Federation [Raw-material export with Minfin inexpediency conclusion] → Australia (refine) → Turkey (Türkiye) · Exchange trade, bank and retail sale — Research · Nelum