Australia (refine) → Kazakhstan → United Kingdom · Retail investment-gold sale by a dealer (HVD rules for cash)

Enrol with AUSTRAC within 28 days of starting a designated service and adopt an AML/CTF program (bullion dealing; from 31 Mar 2026 also buying or selling precious metal for $10,000 or more in physical currency or virtual assets, with obligations from 1 Jul 2026)

执行方

Bullion dealer / dealer in precious metal

出具

AUSTRAC enrolment; AML/CTF program

• AML/CTF Act 2006, s.6(3) table 2 items 1-2; ss.26B, 51B

  “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”

Carry out customer due diligence before providing the designated service; enhanced due diligence in higher-risk cases

执行方

Bullion dealer / dealer in precious metal

所需

AUSTRAC enrolment

出具

Customer due diligence file

• AML/CTF Act 2006, s.28 (initial CDD); s.39E item 11 (bullion under $5,000)

  “A reporting entity must not commence to provide a designated service to a customer if the reporting entity has not established on reasonable grounds each of the matters in subsection (2)”

Sell or buy bars: input-taxed supply of precious metal (no GST charged, no input credits), or GST-free if it is the refiner's first supply after refining to a dealer

执行方

Bullion dealer / dealer in precious metal

所需

Customer due diligence file

出具

Commercial invoice (GST-free / input-taxed treatment stated)

• A New Tax System (Goods and Services Tax) Act 1999, s.40-100; s.38-385

Report each threshold transaction (transfer of $10,000 or more in physical currency) to AUSTRAC within 10 business days

执行方

Bullion dealer / dealer in precious metal

出具

Threshold transaction report

• AML/CTF Act 2006, s.43; s.5 threshold transaction

Report suspicious matters to AUSTRAC (within 3 business days, or 24 hours for terrorism financing suspicions)

执行方

Bullion dealer / dealer in precious metal

出具

Suspicious matter report

• AML/CTF Act 2006, s.41

Hold a granted mining lease (or state equivalent) with approvals to mine

执行方

Mining tenement holder (mining lease) operating a gold mine and mill

所需

Mining lease

[not-read] Mining proposal and closure plan approvals not read.

• Mining Act 1978 (WA), ss.71, 78, 85

Mine ore, process (CIL/gravity), and pour doré bars at the mine site; mark each bar

执行方

Mining tenement holder (mining lease) operating a gold mine and mill

出具

Mine doré bar number and mine mark

形态

Ore (in situ / run-of-mine) → Doré bar - unstamped

Mine-site processing described only generally.

Collect doré under secure transport and deliver to the refinery

执行方

Secure precious-metals carrier / airline

所需

Refining (toll) agreement between miner and refiner

Receive, weigh and sample the doré; issue receipt. For WA royalty, gold metal is taken to be produced on delivery to the refinery if delivered within 3 months of the gold-bearing material being obtained; otherwise on the day after the 3-month period

执行方

Australian gold refiner (LBMA Good Delivery-listed)

出具

Refinery receipt and weigh-in of doré

• Mining (Royalties) Regulations 2025 (WA), rr. 29, 31-32

Assay the doré and issue the outturn statement; credit the miner's metal account with fine gold (or buy the gold outright)

执行方

Australian gold refiner (LBMA Good Delivery-listed)

所需

Refinery receipt and weigh-in of doré

出具

Outturn / assay statement; Metal account statement

First sale of refined gold: GST-free where it is the first supply after refining by or on behalf of the supplier, by a refiner of precious metal, to a dealer in precious metal; otherwise the supply of precious metal is input taxed

执行方

Mining tenement holder (mining lease) operating a gold mine and mill

所需

Metal account statement

出具

Commercial invoice (GST-free / input-taxed treatment stated)

[conflict] au.div-gst-scrap (refining from scrap).

• A New Tax System (Goods and Services Tax) Act 1999, s.38-385; s.40-100; s.195-1

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

执行方

Australian gold refiner (LBMA Good Delivery-listed)

所需

Outturn / assay statement

出具

Bar list for refined bars

形态

Doré bar - unstamped → 999.9 kilobar

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

执行方

Australian gold refiner (LBMA Good Delivery-listed)

出具

Refiner RGG report and assurance

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

执行方

Australian gold refiner (LBMA Good Delivery-listed)

出具

Suspicious matter report

[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

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

执行方

Exporter of bars (refiner, dealer or miner selling offshore)

所需

Bar list for refined bars

出具

Commercial invoice (GST-free / input-taxed treatment stated)

[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)

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

执行方

Licensed customs broker

所需

Commercial invoice (GST-free / input-taxed treatment stated)

出具

Export declaration and export entry advice (authority to deal, with export entry advice number)

• 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”

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

执行方

Exporter of bars (refiner, dealer or miner selling offshore)

出具

Certificate of origin (on request)

[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)

Ship by secure air freight under air waybill

执行方

Secure precious-metals carrier / airline

所需

Export declaration and export entry advice (authority to deal, with export entry advice number)

出具

Air waybill

Carrier practice not documented in the sources read.

Present the whole batch with contract and content documents for an act of state control on each import batch

执行方

Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)

所需

Notification of start/cessation of activity with precious metals (import/export); Commercial invoice

出具

Act of state control of precious metals, issued per shipment

• Order of the Minister of Industry and Construction No. 375 of 29.10.2024, paras 8, 21

Control-test samples if content documents do not match the contract

执行方

National Bank of Kazakhstan (state buyer, priority right)

出具

NBK control test result on samples (Cash Operations and Valuables Storage Centre)

• Law 444-V 'On precious metals and precious stones', art. 7(1)

Lodge the import declaration and clear customs

执行方

Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)

所需

Act of state control of precious metals, issued per shipment

出具

EAEU goods declaration for import (ДТ)

Import VAT treatment of gold not researched.

Sign the foreign-trade contract with a specification (full assortment, quantity, mass) and issue the invoice or value-confirmation document with the precious-metal content calculation

执行方

Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)

出具

Foreign-trade contract with specification (submitted for licence and state control act); Invoice or value-confirmation document

• Order of the Minister of Industry and Construction No. 375 of 29.10.2024, para. 18

Obtain the document confirming the NBK's refusal to exercise the priority right on the refined gold

执行方

Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)

所需

Document confirming NBK refusal to exercise the priority right on refined gold

出具

Document confirming NBK refusal to exercise the priority right on refined gold

• Order of the Minister of Industry and Construction No. 375 of 29.10.2024, para. 19

Obtain a laboratory document on precious-metal content from an accredited testing laboratory

执行方

Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)

出具

Accredited testing laboratory document on precious-metal content

• Order of the Minister of Industry and Construction No. 375 of 29.10.2024, para. 18

Obtain an export licence for the foreign-trade contract from the authorised body

执行方

Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)

所需

Notification of start/cessation of activity with precious metals (import/export); Foreign-trade contract with specification (submitted for licence and state control act)

出具

Export licence for precious metals / raw materials (per foreign-trade contract)

Issuing procedure and EAEU basis (EEC Decision 30) not read.

• Order of the Minister of Industry and Construction No. 375 of 29.10.2024, paras 17-18

Assign a registration number to the currency contract where it meets the NBK monitoring criteria

执行方

Kazakh commercial bank servicing the currency contract

出具

Registration (accounting) number of a currency contract

Threshold is set in NBK rules, not read.

• Law 167-VI, arts 13-14

Apply through the e-government portal for the act of state control, presenting the whole batch and the licence, contract, specification, invoice, content calculation, notification, ownership documents and laboratory document

执行方

Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)

所需

Export licence for precious metals / raw materials (per foreign-trade contract); Foreign-trade contract with specification (submitted for licence and state control act); Invoice or value-confirmation document; Accredited testing laboratory document on precious-metal content; Notification of start/cessation of activity with precious metals (import/export); Document confirming NBK refusal to exercise the priority right on refined gold

• Order of the Minister of Industry and Construction No. 375 of 29.10.2024, paras 9, 18, 19, 21

Carry out control testing of samples when the content documents do not match the contract or technical documentation

执行方

National Bank of Kazakhstan (state buyer, priority right)

出具

NBK control test result on samples (Cash Operations and Valuables Storage Centre)

• Law 444-V 'On precious metals and precious stones', art. 7(1)

Issue the act of state control for the shipment (content, source, market valuation, compliance with contract); refuse if documents incomplete or price below metal value

执行方

Authorised body for precious metals (Ministry of Industry and Construction)

出具

Act of state control of precious metals, issued per shipment

• Order of the Minister of Industry and Construction No. 375 of 29.10.2024, para. 10

Obtain a certificate of origin if the buyer or destination requires it

执行方

Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)

出具

Certificate of origin (general form) for exported goods

Not researched; included because hand-off checks may ask for it.

Lodge the export goods declaration with the state control act and export licence; customs releases the goods

执行方

Exporter of precious metals or raw materials (notified entity holding a per-contract export licence)

所需

Act of state control of precious metals, issued per shipment; Export licence for precious metals / raw materials (per foreign-trade contract)

出具

EAEU goods declaration for export (ДТ)

• Order of the Minister of Industry and Construction No. 375 of 29.10.2024, para. 17

Ship the bars to the foreign buyer

执行方

Secure carrier (cash-in-transit / valuables logistics)

所需

EAEU goods declaration for export (ДТ)

出具

Air waybill for export shipment

Order 375 governs release; carriage arrangements are industry practice.

Apply customer due diligence to the foreign seller before buying (identity, beneficial owner, purpose, risk assessment, sanctions/PEP screening)

执行方

Bullion dealer / trader (importer of record, usually an LBMA member)

出具

Supplier KYC pack received by the UK buyer; MLR customer due diligence file

[unconfirmed] Whether a non-bank wholesale bullion trader paid by wire is within the MLR at all (e.g. as a financial institution under reg 10) - consolidated MLR not held. [not-read] Reg 27 quoted via WebFetch; MLR not held.

• Money Laundering Regulations 2017, reg 27

Establish that the gold is not Russian-origin gold exported from Russia on or after 21 Jul 2022, not relevant processed gold incorporating such gold, and not Russian gold jewellery exported on or after 29 Oct 2022; check where the goods were originally consigned or exported from; if Russian origin is possible, apply to DBT's Import Sanctions Team for a licence or contact it; declare document code 9022 (not subject to / exempt from sanctions) or 9011 (licence) on CDS and keep the evidence to produce on demand

执行方

Bullion dealer / trader (importer of record, usually an LBMA member)

所需

Export customs declaration accepted by the dispatching country's customs

出具

Importer's Russia-sanctions origin evidence file

[inferred] The guidance and tariff do not list specific evidence documents; the required kinds are this module's inference.

• Russia (Sanctions) (EU Exit) Regulations 2019 as amended by SI 2022/850 and SI 2022/1110, regs 46Z11, 46Z16B, 46Z16C

Fly the bars into the UK as valuable cargo (typically Heathrow) under an air waybill

执行方

Secure valuables carrier

出具

Air waybill, inbound valuables consignment

UK valuables-cargo handling not researched in this pass.

Submit a full import declaration on CDS (procedure code, commodity code 7108 12 00 00 for unwrought gold, DUCR, consignor/consignee, value, licences; EORI); declare sanctions document code 9022 or 9011; claim the investment-gold VAT exemption with additional code VATE where the bars are 995+ of a weight accepted by the bullion markets

执行方

Customs agent / declarant using CDS software

所需

EORI number of importer/exporter; Importer's Russia-sanctions origin evidence file; Air waybill, inbound valuables consignment; Air waybill; Commercial invoice; Bar list (serials, weights, fineness)

出具

CDS full import declaration

[conflict] gb.div-cpc-chief - VAT Notice 701/21 s.8.1 still gives CHIEF CPC 40 00 073; the tariff (28 Sep 2026) shows the exemption as additional code VATE. [not-read] The CDS procedure code and DE 1/10-1/11 entries for investment gold not read (UK Trade Tariff Vol. 3 listed in gb-fetch.tsv).

Account for import VAT: exempt for investment gold (additional code VATE); 20% standard rate (code 03020) on non-investment gold (dore, grain, scrap, sub-995 bars, non-qualifying coins); customs duty 0.00% (third-country rate on 7108 12, S.I. 2020/1430)

执行方

Bullion dealer / trader (importer of record, usually an LBMA member)

所需

CDS full import declaration

• VAT Act 1994 Sch 9 Group 15; VAT Notice 701/21, Notice s8.1, s10.7

Clear the goods (CDS message when cleared), or ask for supporting documents for a customs check; for 7108 the Russia/Belarus measures read "Import allowed after control"; HMRC enforces trade sanctions at the border

执行方

HMRC (customs and VAT authority)

所需

CDS full import declaration

出具

CDS clearance notification (goods released)

Register with HMRC as a high value dealer before accepting or making any cash payment of GBP 10,000 or more (single or linked); pay annual fee

执行方

Retail bullion dealer accepting cash (high value dealer)

出具

HMRC MLR registration as high value dealer

[conflict] gb.div-hvd-guidance-lag. Registration requirement ("must not accept or make a high value cash payment until you have registered") from the HMRC page; the MLR registration regulation not read.

• MLR 2017 as amended by SI 2026/621, reg 14 (definition)

Apply CDD to any occasional cash transaction of GBP 10,000 or more

执行方

Retail bullion dealer accepting cash (high value dealer)

所需

HMRC MLR registration as high value dealer

出具

MLR customer due diligence file

[not-read] Reg 27(3) quoted via WebFetch; amount confirmed by SI 2026/621 reg 14(c) (held).

• MLR 2017, reg 27(3)

Sell investment gold VAT-exempt to the retail customer: identity evidence (one List 1 and one List 2 document), invoice and records where the thresholds are met

执行方

Retail bullion dealer accepting cash (high value dealer)

所需

MLR customer due diligence file

出具

Investment gold invoice (VAT tertiary legislation s.3 / VAT Regs reg 31A); Investment gold customer records and identity evidence

• VAT Notice 701/21; VAT Regs 1995 reg 31A, Notice s7.1

Price the sale against the LBMA Gold Price (commonly in AUD) or a forward/hedge contract

执行方

Mining tenement holder (mining lease) operating a gold mine and mill

出具

LBMA Gold Price PM (AUD) reference

Commercial pricing practice not documented; the LBMA PM fix is the statutory WA royalty reference.

Transfer metal from the miner's metal account to the buyer, or deliver bars, against payment

执行方

Australian gold refiner (LBMA Good Delivery-listed)

出具

Payment for gold sold