Canada (refine) → Russian Federation → United Kingdom · Loco London OTC sale and settlement

Obtain a prospector's licence online in the Ontario Mining Lands Administration System (MLAS): 18 or older, after completing the Mining Act awareness program within the prior 60 days; valid five years

执行方

Prospector / mining-claim or exclusive-exploration-right holder

出具

Ontario prospector's licence

• Ontario Mining Act, ss.18, 19

Register a cell mining claim online in MLAS (no ground staking)

执行方

Prospector / mining-claim or exclusive-exploration-right holder

所需

Ontario prospector's licence

出具

Registered mining claim (MLAS)

• Ontario Mining Act, s.38(2)

Acquire a Quebec exclusive exploration right by filing a notice of map designation and having it registered (3-year first term, 2-year renewals subject to work)

执行方

Prospector / mining-claim or exclusive-exploration-right holder

出具

Registered exclusive exploration right (Quebec)

• Quebec Mining Act, ss.47, 61

Ontario: obtain a mining lease (entitled on compliance and first year's rent, after the fifth unit of assessment work; 21 years) and, before mine production, file the Notice of Project Status, give public notice, complete Aboriginal consultation, submit a closure plan with financial assurance (O. Reg. 35/24) and receive the Minister's written confirmation of filing

执行方

Industrial mine operator (mining-lease holder)

所需

Registered mining claim (MLAS)

出具

Mining lease; Filed closure plan with financial assurance

• Ontario Mining Act; O. Reg. 35/24, Mining Act s.81(1)-(3), s.141(1)

Quebec: obtain a mining lease before mining (rehabilitation plan approved, financial guarantee, certified feasibility study, environmental authorization, market/processing study where required, rental paid); 20-year term renewable for 10-year periods

执行方

Industrial mine operator (mining-lease holder)

所需

Registered exclusive exploration right (Quebec)

出具

Mining lease

• Quebec Mining Act, ss.100, 101, 104

Mine lode ore on the leased land

执行方

Industrial mine operator (mining-lease holder)

所需

Mining lease; Filed closure plan with financial assurance

Mill and leach the ore on site and smelt the recovered gold into doré bars

执行方

Industrial mine operator (mining-lease holder)

形态

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

Process route is industry practice; Customs Tariff separately identifies doré (7108.12.00.22).

Number, weigh and sample each doré bar; record mine assay and seal for shipment

执行方

Industrial mine operator (mining-lease holder)

出具

Doré bar number and mine weight/assay record

形态

Doré bar - unstamped → Doré bar - stamped/exporter-sealed

Ship doré under a refining agreement by secure carrier to a Canadian refiner (Royal Canadian Mint or a private GD refiner); for ore or minerals from Ontario mining lands, refining abroad breaches the s.91 condition unless the Lieutenant Governor in Council has exempted the lands

执行方

Industrial mine operator (mining-lease holder)

所需

Doré bar number and mine weight/assay record

出具

Refining (toll) agreement, mine - Canadian refiner

[inferred] Refining route and carriers are industry practice; the Ontario limitation is s.91(1) and (3); Quebec has no equivalent condition in the sections read (s.101(5) only requires a study on processing in Quebec for regulated substances).

Onboard the supplier: KYC, OECD five-step risk assessment, sanctions/PEP/adverse-media screening, confirm gold is not imported, purchased or acquired from Russia or a person in Russia

执行方

Private LBMA Good Delivery refiner in Canada

所需

Refining (toll) agreement, mine - Canadian refiner; Origin country's export authorisation for the gold (permit, licence or clearance issued by the mining or trade authority)

出具

Supplier KYC pack and acknowledgement of the refiner's procurement policy; Onboarding and daily screening record; non-Russian origin confirmation

[inferred] SEMA element is law; KYC and OECD process are LBMA/refiner practice, not a Canadian statute for refiners.

• SEMA (Russia) Regulations s.3.11; LBMA RGG; OECD DDG, s.3.11

Receive, weigh, melt and sample the lot; assay in the refinery lab and issue the outturn

执行方

Private LBMA Good Delivery refiner in Canada

所需

Supplier KYC pack and acknowledgement of the refiner's procurement policy; Onboarding and daily screening record; non-Russian origin confirmation

出具

Refiner outturn assay and settlement statement

Refine to 999.9 (or 999.99) and cast LBMA Good Delivery 400 oz bars, 100 oz or 1 kg bars bearing the refiner's mark

执行方

Private LBMA Good Delivery refiner in Canada

出具

Bar list of refined bars (GD 400 oz, 100 oz, kilobars)

形态

Doré bar - stamped/exporter-sealed → LBMA Good Delivery 400oz bar

Settle outturn with the supplier: credit fine metal to its metal account or buy the metal, with final invoice

执行方

Private LBMA Good Delivery refiner in Canada

所需

Refiner outturn assay and settlement statement

出具

Refiner's final invoice / metal-account credit against outturn

First supply of the refined bars by the refiner (or the owner on whose behalf they were refined) is zero-rated for GST/HST; refining fees charged to the metal owner are generally taxable

执行方

Private LBMA Good Delivery refiner in Canada

出具

Invoice for sale of refined bars (zero-rated first supply by the refiner / exempt resale)

Refining-fee taxability is CRA guidance (17-1 para 35), not a specific statutory provision.

• Excise Tax Act, s.123(1) 'precious metal'; Sched VI Part IX s.3

For any purchase or sale of $10,000 or more as a dealer in precious metals: verify identity, keep records, report cash of $10,000+ (LCTR), virtual currency (LVCTR) and suspicious transactions

执行方

Private LBMA Good Delivery refiner in Canada

出具

Record of $10,000+ purchase or sale and client identification; Large cash transaction report; Suspicious transaction report; Large virtual currency transaction report

s.65(2) excludes purchases/sales in connection with extracting precious metals from a mine or manufacturing a product; its application to refiners buying doré is not settled in the texts read.

• PCMLTF Regulations, ss.65, 66, 126, 148

Confirm no export permit is needed: gold is not on the Export Control List (EIPA s.13 requires a permit only for listed goods or Area Control List countries) and there is no gold export licence, state buyer or export duty; unwrought and semi-manufactured gold (710812, 710813) may not be exported to Russia or a person in Russia (SEMA (Russia) s.3.08, Schedule 6 Part 1 items 176-177); check buyer sanctions

执行方

Exporter of record (mine, refiner or bullion trader)

[not-read] Area Control List and sanctions regimes other than Russia not read.

• Export and Import Permits Act; Export Control List; SEMA (Russia) Regulations, EIPA s.13; SEMA (Russia) s.3.08

Invoice the non-resident buyer. Refined bars ('precious metal'): zero-rated when the exporter is the refiner or the person for whom they were refined (ETA Sched VI Part IX s.3); otherwise an exempt financial service (Sched V Part VII s.1), zero-rated under Part IX s.1 only when supplied by a financial institution to a non-resident. Doré and other gold that is not 'precious metal': taxable, zero-rated as an export when the Sched VI Part V s.1 conditions are met

执行方

Exporter of record (mine, refiner or bullion trader)

出具

Commercial invoice to the foreign buyer

CRA 17-1 paras 34 and 37 match this reading of Part IX ss.1 and 3. [inferred] Application of Sched VI Part V s.1 (export of tangible personal property) to doré is our reading of the provision.

• Excise Tax Act, s.123(1); Sched V Part VII s.1; Sched VI Part IX ss.1, 3; Sched VI Part V s.1

Report the export to CBSA through the CERS portal or G7 EDI (goods of CAD 2,000+ to any country other than the US), not less than 2 hours before loading on an aircraft; obtain the proof of report number

执行方

Exporter of record (mine, refiner or bullion trader)

所需

Commercial invoice to the foreign buyer

出具

CERS export declaration and proof of report number

• Customs Act Part V; Reporting of Exported Goods Regulations, Customs Act s.95(1); REGR ss.3(1), 6(b)

For exports to the United States: no Canadian export declaration is required for non-restricted goods such as gold

执行方

Exporter of record (mine, refiner or bullion trader)

REGR s.7 exempts exports covered by a written arrangement under which the other country collects the data as imports and shares it; D20-1-1 para 25 applies it to non-restricted goods to the US and para 76 names the Memorandum of Agreement on the Exchange of Import Data between Canada and the United States. Consequence for routes: a Canada-to-US shipment carries no Canadian export declaration to fulfil ref.dk-export-declaration.

• Reporting of Exported Goods Regulations, s.7

Carrier obtains the proof of report number from the exporter and flies the bars or doré under air waybill with bar list

执行方

Secure precious-metals carrier / airline

所需

CERS export declaration and proof of report number; Bar list of refined bars (GD 400 oz, 100 oz, kilobars)

出具

Air waybill

File the FPP import-control application in GIIS DMDK with the foreign-trade contract, specification, document on precious-metal content and special-registration record

执行方

Importer of gold-bearing material for refining (refiner or special-registered company)

所需

Special-registration register entry (FPP); Assay certificate (fineness and fine weight); Commercial invoice

出具

FPP application for import control

• EEC Board Decision 30, Annex 14, Annex 2 (Rules) para 4(a), Rules para 4(a)

State control at a specialised customs post (all goods except ores and concentrates), within 5 working days; act of state control

执行方

Federal Assay Chamber

所需

FPP application for import control

出具

Act of state control on import

• Presidential Decree 1137 para 19¹; EEC Board Decision 30, Annex 14, Annex 2 para 10, para 19¹

Declare the goods at a specialised customs post for release or processing, presenting the act of state control, and take delivery to the refinery

执行方

Importer of gold-bearing material for refining (refiner or special-registered company)

所需

Act of state control on import

出具

EAEU goods declaration for import / customs processing

[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

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

执行方

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

Sign the export contract and issue the commercial invoice

执行方

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

出具

Export contract with foreign buyer; Commercial invoice

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

执行方

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

所需

Export contract with foreign buyer; Special-registration register entry (FPP)

出具

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)

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

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)

执行方

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

所需

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)

出具

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

[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)

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

执行方

Federal Assay Chamber

所需

Application (zayavka / letter-application) for FPP state control on export or import, filed in GIIS DMDK

出具

Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber

• EEC Board Decision 30, Annex 14, Annex 2 (Rules) paras 3, 8, 10; 41-FZ art. 26², Rules para 10

Lodge the export declaration at a specialised customs post, presenting the export licence and the act of state control

执行方

Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)

所需

EAEU export licence issued by Minpromtorg (one-off or general); Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber; Commercial invoice

出具

Export goods declaration (accepted and released by customs); Certificate of origin (general form) for non-EAEU destinations

[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

Carry the sealed consignment to the airport and hand to the airline (valuable cargo)

执行方

Secure carrier of valuables

所需

Export goods declaration (accepted and released by customs)

出具

Packing list; Air waybill

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)

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)

Give the custodian written notice of the deposit (amount, Availability Date, and the carrier and packing for physical delivery, or the source account for book-entry); advise the vault manager of the vehicle registration and driver's identity

执行方

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

所需

CDS clearance notification (goods released)

出具

Deposit notice to London custodian

• LPMCL Allocated Account Agreement; LBMA Good Delivery Rules, Allocated cl. 3.3 (Unallocated cl. 3.2); GD Rules Annex B s.2

Weigh the bars under the London weighing procedures (the receiving party may charge for weighing if not weighed by an Approved Weigher) and produce the machine-readable, dated weight list stating whether an Approved Weigher weighed the metal; a copy travels with the bars

执行方

LBMA Approved Weigher

出具

Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)

• LBMA Good Delivery Rules, Annex B

Receive bars on pallets; before crediting, verify compliance with the Rules and weigh them per LBMA practice against the notified amount; the vault manager may refuse bars not meeting Good Delivery standards and may ask LBMA to appoint independent inspectors

执行方

London commercial vault / custodian (typically a clearing or custodian bank)

所需

Deposit notice to London custodian; Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)

• LPMCL Allocated/Unallocated Account Agreements; LBMA Good Delivery Rules, Allocated cl. 3.1(b), 3.4, 3.5; Unallocated cl. 3.1(b), 3.3, 3.4; GD Rules 2.4 and Annex B

For bars of the six suspended Russian refiners: accept only bars produced while the refiner was listed and already in the loco London/Swiss markets before 7 Mar 2022; clearing banks attest conformity

执行方

London commercial vault / custodian (typically a clearing or custodian bank)

所需

Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)

Separately, UK law bans import of Russian gold exported from Russia on or after 21 Jul 2022. [unconfirmed] GD Rules 2026 s.1.4 says bars of a refiner moved to the Former List for sanctions reasons may lose Good Delivery status; LBMA's specific Russian-bars page keeps pre-7 Mar 2022 loco London/Swiss stocks as Good Delivery - the model follows the specific page.

• LBMA Good Delivery List suspension notice (7 Mar 2022)

Credit the client: an allocated account (specific bars, title stays with client, weight list issued) or an unallocated account (a metal debt claim on the custodian); statements at least annually

执行方

London commercial vault / custodian (typically a clearing or custodian bank)

所需

Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)

出具

Allocated weight list (bar number, gross weight, fineness, fine weight, brand) or unallocated balance statement

• LPMCL Account Agreements, Allocated cl. 2.3, 7.3 and Schedule (bar numbers, purity, gross and fine weight, brand); Unallocated cl. 1.1, 2.3, 3.3

Central-bank channel: hold Good Delivery bars in an allocated account at the Bank of England (off the Bank's balance sheet)

执行方

Bank of England (gold custodian)

形态

LBMA Good Delivery 400oz bar → Monetary gold (central bank reserve)

Monetary state applies when held as reserves by a monetary authority.

Report month-end holdings to LBMA (London vault data) and, from Dec 2026, aggregated vault data into the Gold Bar Integrity database (bar-level reporting planned from 2027)

执行方

London commercial vault / custodian (typically a clearing or custodian bank)

出具

Custodian holdings return to LBMA (London vault data / GBI)

Onboard the counterparty: MLR customer due diligence and sanctions representations in the account agreement

执行方

LPMCL clearing member bank

出具

MLR customer due diligence file

[not-read] MLR reg 27 quoted via WebFetch; MLR not held.

• MLR 2017; LPMCL account agreements, MLR reg 27; LPMCL Allocated cl. 10 / Unallocated cl. 8

Agree the OTC trade (spot/forward) under the 1994 International Bullion Master Agreement (IBMA) or an ISDA Master Agreement with the 1997 ISDA Bullion Definitions; LBMA Members must comply with the Global Precious Metals Code

执行方

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

所需

MLR customer due diligence file

出具

OTC bullion trade confirmation (IBMA 1994 / ISDA Bullion Definitions 1997)

Apply the VAT treatment: investment gold between LBMA members is zero-rated (TMO); gold held in the UK between central banks, or between a central bank and an LBM member, is zero-rated (VATA Sch 8 Group 10); investment gold between an LBMA member and a taxable non-member is standard-rated under the special accounting scheme (the buyer accounts for the VAT); to private individuals it is exempt; other investment gold is exempt unless the supplier has opted to tax; standard-rated gold (fine gold, grain, scrap, opted investment gold) between VAT-registered traders goes under the compulsory special accounting scheme

执行方

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

所需

OTC bullion trade confirmation (IBMA 1994 / ISDA Bullion Definitions 1997)

[conflict] gb.div-tmo-member-category. [not-read] TMO arts 3-7 and VATA s.55 not held; the member/non-member rule is from VGOLD1600 ("Supplies of investment gold between members and non-members who are taxable persons are now standard-rated") and Notice 701/21 ss. 11.2, 11.5.

• VAT (Terminal Markets) Order 1973; VATA 1994 s.55, Sch 8 Group 10, Sch 9 Group 15

Settle loco London: book transfer between unallocated accounts through LPMCL members (client instructions by 16:00, inter-member by 16:30 London), or transfer of specific allocated bars

执行方

LPMCL clearing member bank

所需

OTC bullion trade confirmation (IBMA 1994 / ISDA Bullion Definitions 1997); Allocated weight list (bar number, gross weight, fineness, fine weight, brand) or unallocated balance statement

出具

Loco London settlement: transfer between unallocated accounts via LPMCL members, or allocated bar transfer

Cut-offs (client instructions until 4.00pm, LPMCL members until 4.30pm London time) confirmed in the held 2017 OTC Guide; the current web section not held.

Pay the cash leg against metal settlement

执行方

LPMCL clearing member bank

所需

Loco London settlement: transfer between unallocated accounts via LPMCL members, or allocated bar transfer

出具

Cash-leg payment for the metal

Cash-leg timing and DvP arrangements not documented in the sources read.

For exempt investment gold: issue an invoice with a unique number and the prescribed details for each sale over GBP 5,000 (or smaller sales once a customer passes GBP 10,000 in 12 months); keep the accounting and customer records (identity from one List 1 and one List 2 document) for at least 6 years; notify HMRC in writing within 28 days of the first exempt supply over GBP 5,000 or when supplies to one customer exceed GBP 10,000 in 12 months; failures attract a penalty normally of 17.5% of the transactions' value

执行方

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

所需

Loco London settlement: transfer between unallocated accounts via LPMCL members, or allocated bar transfer

出具

Investment gold invoice (VAT tertiary legislation s.3 / VAT Regs reg 31A); Investment gold customer records and identity evidence; Notification to HMRC of exempt investment gold dealing (within 28 days)

Tertiary legislation (force of law, held). [unconfirmed] The general 6-year retention and the 17.5% penalty are in Notice 701/21 ss. 7.7 and 9.4, outside the passages marked as having force of law.

• VAT Regulations 1995; VAT tertiary legislation (gold), reg 31A

Keep MLR records 5 years; nominated officer files a suspicious activity report where there is suspicion

执行方

LPMCL clearing member bank

所需

MLR customer due diligence file

出具

Suspicious activity report to the National Crime Agency

MLR record-keeping regulation not held; 5 years from the end of the relationship or completion of the transaction per HMRC guidance.

Buy refined bars from the refiner (zero-rated first supply) or from another holder (exempt resale); non-qualifying forms (granules, below 99.5%) are taxable

执行方

Bullion dealer (dealer in precious metals and precious stones)

出具

Invoice for sale of refined bars (zero-rated first supply by the refiner / exempt resale)

• Excise Tax Act, s.123(1); Sched VI Part IX s.3

Identify the counterparty and keep the $10,000+ record; report cash of $10,000+ (LCTR), virtual currency (LVCTR), suspicious or sanctions-evasion activity

执行方

Bullion dealer (dealer in precious metals and precious stones)

出具

Record of $10,000+ purchase or sale and client identification; Large cash transaction report; Large virtual currency transaction report; Suspicious transaction report

• PCMLTF Regulations, ss.65, 66, 126, 148

Settle by bank wire or by transfer between metal accounts (e.g. at the Royal Canadian Mint); no foreign-exchange surrender or repatriation step

执行方

Canadian bank (bullion desk / payments)

出具

Settlement confirmation / metal-account transfer

Absence of exchange control is background knowledge; no official statement was read.