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Russian Federation [Raw-material export with Minfin inexpediency conclusion] → Singapore (refine) → United Arab Emirates · Reconcile assays and pay the balance

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俄罗斯 (Doré bar - unstamped → Concentrate / black sand) ⟶ 新加坡 (Concentrate / black sand → 999.9 kilobar) ⟶ 阿拉伯联合酋长国 (999.9 kilobar)

未研究:俄罗斯 → 新加坡, 新加坡 → 阿拉伯联合酋长国

第 1 段:俄罗斯

货物起点

Doré bar - unstamped → Concentrate / black sand

  1. 1

    Extract gold ore or placer sands within the licensed plot

    执行方
    Subsoil user (gold mining company)
    所需
    Subsoil-use licence (electronic); Special-registration register entry (FPP)
    形态
    Ore (in situ / run-of-mine) → Concentrate / black sand
    法律原文
    • 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

    执行方
    Subsoil user (gold mining company)
    出具
    Batch number / GIIS UIN of the dore lot
    形态
    Concentrate / black sand → Doré bar - unstamped
    法律原文

    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

    执行方
    Subsoil user (gold mining company)
    出具
    Refining (tolling) agreement miner-refiner
    法律原文
    • 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

    执行方
    Subsoil user (gold mining company)
    所需
    Batch number / GIIS UIN of the dore lot; Refining (tolling) agreement miner-refiner
    出具
    ESD for dispatch of dore/placer gold to the refiner
    官方指引

    [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

    执行方
    Secure carrier of valuables
    所需
    ESD for dispatch of dore/placer gold to the refiner
    法律原文
    • 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

    执行方
    Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
    出具
    Minfin conclusion on the inexpediency of industrial extraction of precious metals from raw materials in Russia; Test protocol on precious-metal content
    法律原文
    • 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)

    执行方
    Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
    所需
    Minfin conclusion on the inexpediency of industrial extraction of precious metals from raw materials in Russia; Test protocol on precious-metal content
    出具
    EAEU export licence issued by Minpromtorg (one-off or general); Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber
    法律原文
    • 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)

    执行方
    Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
    所需
    Act of state control (akt gosudarstvennogo kontrolya) of the Federal Assay Chamber; EAEU export licence issued by Minpromtorg (one-off or general)
    出具
    Export goods declaration (accepted and released by customs)
    法律原文

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

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

税费

  • 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

    法律原文金额未确认
    • 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

    法律原文金额未确认
    • 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)

    法律原文金额未确认
    • 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

    法律原文金额未确认
    • 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

    法律原文金额未确认
    • Tax Code art. 343(21) as restated by Federal Law 176-FZ of 12.07.2024, art. 343(21)

管制

  • 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…

    法律原文
    • 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

    法律原文金额未确认
    • 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

    法律原文金额未确认
    • 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…

    法律原文
    • 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.

    未经核实
  • 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 …

    法律原文
    • 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…

    法律原文
    • 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.

    法律原文
    • 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…

    法律原文
    • 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.

    标准
  • 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 …

    法律原文
    • 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…

    法律原文
    • 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…

    法律原文
    • 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.

    法律原文
    • 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…

    法律原文
    • 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…

    法律原文
    • 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 …

    法律原文
    • 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…

    法律原文
    • 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…

    法律原文
    • Federal Law 41-FZ, art. 29(3)

第 2 段:新加坡

途经

Concentrate / black sand → 999.9 kilobar

  1. 9

    Screen the foreign supplier and its owners against MHA terrorist-designation lists, MAS targeted financial sanctions lists and UN lists (myPal); apply enhanced checks if the supplier is in a FATF call-for-action or increased-monitoring jurisdiction; record in the supplier file

    执行方
    Registered bullion dealer / trader (PSPM registered dealer)
    所需
    Certificate of registration as a regulated dealer (PSPM Act); ML/TF/PF enterprise risk assessment and IPPC (internal policies, procedures and controls)
    出具
    Supplier KYC file (incl. sanctions screening); Sanctions/terrorist-designation screening record (MHA lists, MAS TFS lists, myPal)
    官方指引

    [inferred] PSPM CDD is triggered by designated transactions and prescribed circumstances (cash/cash equivalent, or gold/DPT payment, above S$20,000), which bank-paid wholesale imports usually are not; supplier screening rests on the entity-level risk assessment (reg 14) and the targeted-financial-sanctions duty (reg 16), and the Guidelines' supplier red flags.

    • PMLTFPF Regulations 2019 regs 14, 16; ACD Guidelines v5.1

  2. 10

    Ship bars by secure air freight to Changi with commercial invoice, packing list and bar list naming the producing refiner

    执行方
    Foreign supplier (refiner, bank or trader abroad)
    所需
    Export customs declaration accepted by the dispatching country's customs; Refiner's certificate for the bars it produced (serials, fineness, weights, year)
    出具
    Inbound air waybill; Foreign supplier's commercial invoice; Packing list; Bar list from the foreign supplier (serials, weights, fineness, refiner)
    官方指引
  3. 11

    File a TradeNet In-Non-Payment (GST Relief) permit: declaration type GTR, place of receipt IGPM, HS 7108.13.00 (bars/wafers) or 7108.12.10 (ingots), CA/SC product code BAR/INGOT/WAFER, purity in CA/SC code 1, and the producing refiner's name as supplier

    执行方
    Declaring agent (TradeNet)
    所需
    Foreign supplier's commercial invoice; Packing list; Inbound air waybill; Commercial invoice; Packing list; Air waybill
    出具
    TradeNet In-Non-Payment (GST Relief) permit for IPM (declaration type GTR, place of receipt IGPM)
    官方指引
    • GST Act 1993; RIER, s.8(4), s.22(1A); RIER reg 3(1), (2A)

  4. 12

    Clear the consignment at Changi against the approved permit; no customs duty (gold is not a dutiable good) and no import GST for qualifying IPM

    执行方
    Singapore Customs
    所需
    TradeNet In-Non-Payment (GST Relief) permit for IPM (declaration type GTR, place of receipt IGPM)
    官方指引
  5. 13

    Receive the bars, check serials, weights and hallmarks against the bar list, and book them to the depositor's allocated account

    执行方
    Vault operator / precious-metals custodian (incl. in the Changi FTZ Freeport)
    所需
    Bar list from the foreign supplier (serials, weights, fineness, refiner); TradeNet In-Non-Payment (GST Relief) permit for IPM (declaration type GTR, place of receipt IGPM)
    出具
    Inbound weight and serial check; Vault deposit receipt and allocated weight list
    行业惯例
  6. 14

    Keep the import permit, purchase order, invoice and delivery note to support the exempt import; exempt IPM imports are not reported in the GST return

    执行方
    Registered bullion dealer / trader (PSPM registered dealer)
    所需
    TradeNet In-Non-Payment (GST Relief) permit for IPM (declaration type GTR, place of receipt IGPM); Foreign supplier's commercial invoice
    官方指引
    • IRAS IPM e-Tax Guide (20th ed.) para 8.2; Customs: keep trade documents 5 years

  7. 15

    Weigh in the lots and record gross weight per lot against the supplier's packing list

    执行方
    Refinery in Singapore (LBMA Good Delivery listed; ARCS Approved Refiner)
    所需
    Refining Agreement (fee schedule, assay/settlement formula)
    出具
    Refinery weigh-in record
    行业惯例
  8. 16

    Melt, sample and assay; issue the outturn statement with fine gold content

    执行方
    Refinery in Singapore (LBMA Good Delivery listed; ARCS Approved Refiner)
    所需
    Refinery weigh-in record
    出具
    Refiner outturn statement (weigh-in, assay, fine gold credited)
    形态
    Doré bar - stamped/exporter-sealed → Smelted button/bar
    行业惯例
  9. 17

    Refine to 999.9 and cast kilobars/small bars (or 995+ 400oz bars), stamp with the refiner's hallmark, serial, fineness and weight

    执行方
    Refinery in Singapore (LBMA Good Delivery listed; ARCS Approved Refiner)
    所需
    Refiner outturn statement (weigh-in, assay, fine gold credited)
    出具
    Singapore refiner's bar list / product certificate (serial, fine weight, fineness, hallmark)
    形态
    Smelted button/bar → 999.9 kilobar
    行业惯例
  10. 18

    Settle with the supplier: credit fine gold to its metal account or buy the gold (first sale of newly refined IPM is exempt); issue debit/credit note between provisional and final assay; charge refining fee (9% GST if supplied locally, zero-rated if to an overseas customer)

    执行方
    Refinery in Singapore (LBMA Good Delivery listed; ARCS Approved Refiner)
    所需
    Refiner outturn statement (weigh-in, assay, fine gold credited); Refining Agreement (fee schedule, assay/settlement formula)
    出具
    Allocated or unallocated metal account statement; Debit/credit note (provisional vs final assay reconciliation); Invoice for an exempt supply of IPM
    官方指引
    • GST Act 1993 Fourth Schedule Part 1 para 1A; GST (General) Regulations reg 46A; IRAS ARCS e-Tax Guide paras 4.7, 4.21

  11. 19

    Account for ARCS goods: track material from import through refining to customer; report imports under the scheme (Box 9), exempt IPM sales (Box 3) and zero-rated exports (Box 2) in the GST return

    执行方
    Refinery in Singapore (LBMA Good Delivery listed; ARCS Approved Refiner)
    所需
    IRAS ARCS approval letter (Approved Refiner / Approved Consolidator)
    出具
    GST return (GST F5) reporting IPM exempt supplies, zero-rated exports and imports under ARCS (Box 9)
    官方指引
    • IRAS ARCS e-Tax Guide paras 5.3, 8.2-8.11, App. 1

  12. 20

    Open a custody account after KYC of the depositor; agree allocated (serial-numbered) or pooled storage, insurance and audit rights

    执行方
    Vault operator / precious-metals custodian (incl. in the Changi FTZ Freeport)
    出具
    Vault deposit receipt and allocated weight list
    行业惯例
  13. 21

    Hold bars in the allocated register and issue periodic weight-list statements

    执行方
    Vault operator / precious-metals custodian (incl. in the Changi FTZ Freeport)
    所需
    Vault deposit receipt and allocated weight list
    出具
    Allocated or unallocated metal account statement
    行业惯例
  14. 22

    Store non-IPM gold (or goods not entered for home use) in a free trade zone or a licensed zero-GST warehouse with GST suspended until the goods enter customs territory for local use; storing gold as a "listed good" in a zero-GST warehouse needs Customs' written approval and beneficial-owner records

    执行方
    Vault operator / precious-metals custodian (incl. in the Changi FTZ Freeport)
    法律原文

    [summary] the listed-goods approval and beneficial-owner records are Customs ZGS scheme conditions (official guidance), not statute.

    • Free Trade Zones Act 1966 ss.2, 5; GST Act 1993 s.37(1); GST (General) Regulations 1993 reg 94; Singapore Customs FTZ and Zero-GST Warehouse guidance

  15. 23

    Hold foreign central banks' and sovereign entities' gold under the MAS central bank gold vaulting service; MAS also extends gold accounts to selected Singapore bullion banks to manage those holdings

    执行方
    Monetary Authority of Singapore (central bank gold custody service)
    官方指引

    [unconfirmed] launch not confirmed as of 28 Sep 2026; terms of the service not published in the texts held.

  16. 24

    Release bars on the account holder's instruction against a delivery order to a carrier or another vault account

    执行方
    Vault operator / precious-metals custodian (incl. in the Changi FTZ Freeport)
    所需
    Allocated or unallocated metal account statement
    出具
    Outbound bar list
    行业惯例
  17. 25

    Screen the buyer and destination: UNSC sanctions (gold may not be traded with the DPRK), FATF call-for-action jurisdictions, and designated persons

    执行方
    Registered bullion dealer / trader (PSPM registered dealer)
    所需
    ML/TF/PF enterprise risk assessment and IPPC (internal policies, procedures and controls)
    出具
    Sanctions/terrorist-designation screening record (MHA lists, MAS TFS lists, myPal)
    法律原文
    • RIER regs 5A, 6(2)(c) and Seventh Schedule; PMLTFPF Regulations regs 7, 16

  18. 26

    Apply for a UNSC-sanctions permit at least 3 working days before shipment

    执行方
    Declaring agent (TradeNet)
    出具
    TradeNet permit for goods to/from a UNSC-sanctioned country
    官方指引

    [unconfirmed] the 3-working-day lead time is Customs guidance, not in the RIER text.

    • RIER, regs 5A, 6(1)(b)

  19. 27

    Obtain the TradeNet export permit before the cargo is lodged with the air cargo handler

    执行方
    Declaring agent (TradeNet)
    所需
    Singapore seller's export commercial invoice; Outbound bar list
    出具
    TradeNet export (Out) permit
    法律原文
    • RIER, reg 3(1)(b), (3)

  20. 28

    Where the buyer or the importing country asks for it, obtain an ordinary (non-preferential) certificate of origin from Singapore Customs or an authorised chamber, or issue one on the exporter's own account; the origin stated is the country where the bars were produced (refined), not Singapore, unless they were substantially transformed in Singapore

    执行方
    Registered bullion dealer / trader (PSPM registered dealer)
    所需
    Singapore seller's export commercial invoice; Outbound bar list
    出具
    Ordinary (non-preferential) certificate of origin
    法律原文

    [inferred] that refined bars re-exported from Singapore carry the origin of the refining country follows from Circular 06/2025 (wholly obtained or substantially transformed); no gold-specific ruling was found.

    • Regulation of Imports and Exports Regulations Part III, regs 23, 24, 24A; Fifth Schedule

  21. 29

    Invoice the foreign buyer as a zero-rated export and keep the export permit and shipping documents as evidence

    执行方
    Registered bullion dealer / trader (PSPM registered dealer)
    出具
    Singapore seller's export commercial invoice
    法律原文
    • GST Act 1993 s.21(1)-(2); IRAS IPM e-Tax Guide para 5.2

  22. 30

    Collect the bars from the vault, lodge them at Changi and fly them out under the AWB

    执行方
    Secure logistics carrier
    所需
    TradeNet export (Out) permit
    出具
    Outbound air waybill
    官方指引

税费

  • Customs duty on gold

    None All gold (HS 7108 etc.); only liquor, tobacco, motor vehicles and petroleum products are dutiable

    官方指引金额未确认
  • Import GST suspension under ARCS

    Suspended Materials imported by Approved Refiners/Consolidators for refining into IPM; supplies between ARCS persons (except refining services)

    法律原文
    • GST (General) Regulations, reg 46A(8), (12)

  • GST on exports of gold

    0% (zero-rated) Export of IPM and non-IPM gold with export documentation

    法律原文金额未确认
    • GST Act 1993, s.21(1)-(2)

  • Import GST - IPM exemption

    Exempt Gold bars, ingots, wafers of 99.5%+ from current/former LBMA GD refiners (or ESG-endorsed), with hallmark; prescribed coins; not decorative/collector bars

    法律原文金额未确认
    • GST Act 1993, s.8(4), s.22(1A); Fourth Schedule Part 2 paras 1(a), 1A; Part 3 para 2

  • GST on non-IPM gold

    9% Import and supply of doré, scrap, jewellery, non-qualifying bars (e.g. from non-LBMA refiners, decorative)

    法律原文金额未确认
    • GST Act 1993, s.16(cb)

  • GST on non-IPM gold (2023 rate)

    8% Import and supply of doré, scrap, jewellery, non-qualifying bars

    法律原文金额未确认
    • GST Act 1993, s.16(ca)

  • GST on refining services

    9% local; zero-rated to overseas customers Refining/toll-refining fees

    官方指引金额未确认
  • GST on local supply of IPM

    Exempt Sale of qualifying IPM in Singapore

    法律原文金额未确认
    • GST Act 1993, s.22(1); Fourth Schedule Part 1 para 1A

  • Regulated dealer registration fees

    S$120 application fee (not on renewal since 10 Apr 2021); S$250 (Class A) or S$350 (Class B) per year per place of business

    法律原文金额未确认
    • PMLTFPF Regulations 2019, regs 17-18

管制

  • Cash transaction report on Form NP 784 to a Suspicious Transaction Reporting Officer for every designated transaction, not later than 15 business days after the date the transaction is entered into; a copy goes to the Registrar at the time of submission or immediately after (e-filing through SONAR f…

    Cash or cash equivalent exceeding S$20,000 (payments in gold other than jewellery, or in digital payment tokens, are prescribed circumstances for CDD, not designated transactions, and need no CTR)

    法律原文
    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.17(1)

      “A regulated dealer who enters into any designated transaction must submit to a Suspicious Transaction Reporting Officer, within the prescribed time, a cash transaction report relating to that transaction in the prescribed form and manner.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.17(1A)

      “A regulated dealer must not, without reasonable excuse, submit a cash transaction report under subsection (1) that is incomplete or inaccurate.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.17(2)

      “A regulated dealer must keep a copy of each cash transaction report submitted under subsection (1) for the prescribed period.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.17(3)

      “A regulated dealer must, at the time of submitting a cash transaction report under subsection (1) or immediately thereafter, submit a copy of the cash transaction report to the Registrar.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.17(4)

      “A regulated dealer who fails to comply with subsection (1), (1A), (2) or (3) shall be guilty of an offence and shall be liable on conviction to a fine not exceeding $20,000 or to imprisonment for a term not exceeding 2 years or to both.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.15 "designated transaction" (a)

      “a sale of any precious stone, precious metal, precious product or asset-backed token by a regulated dealer to a customer, for which cash or a cash equivalent exceeding the threshold amount is received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.15 "threshold amount"

      “"threshold amount" means $20,000 or its equivalent in value, or an amount prescribed in substitution.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PMLTFPF Regulations reg 4A(1)(a): gold payment is a prescribed circumstance for CDD (s.16(1)(d)), not a designated transaction

      “for which gold (except in the form of jewellery) the value of which exceeds the threshold amount is received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 4A(1)(c)

      “for which digital payment tokens the value of which exceeds the threshold amount are received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PMLTFPF Regulations reg 12(1)(a)

      “the prescribed form for a cash transaction report is Form NP 784 as set out at the website at https://www.police.gov.sg; and”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 12(1)(b)

      “the prescribed time for the submission of a cash transaction report is not later than 15 business days after the date on which the designated transaction is entered into.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 12(2)

      “For the purposes of section 17(2) of the Act, the period for which a copy of a cash transaction report must be kept is 5 years after the date of submission of the cash transaction report.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), STRO Cash Transaction Reporting page

      “When you e-file through SONAR, your CTR will automatically be forwarded to ACD on your behalf.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), ACD Compliance Toolkit, footnote 6 (conflicting definition)

      “The dealer sells or barters a precious stone, precious metal, precious product or asset-backed token and receives payment in cash or cash equivalent or gold (except in the form of jewellery) or digital payment tokens, where the value exceeds S$20,000 in total value.”

  • Enhanced CDD (senior-management approval, income, source of wealth and funds, enhanced monitoring) where the customer, principal or beneficial owner is a PEP or family/associate, resides in or originates from a FATF call-for-action jurisdiction (DPRK, Iran countermeasures; Myanmar enhanced due dilig…

    法律原文
    • PMLTFPF Regulations 2019, reg 7(2)(a)(ii), (3), (4)

  • IPM imports need an In-Non-Payment (GST relief) permit: air freight above S$400 CIF (non-controlled air imports up to S$400 need no permit, RIER reg 3(2A)), all sea and land freight, all commercial hand-carry, and personal hand-carry above 0.5 kg; parcel post needs no permit (reg 3(2)(b)).

    S$400 CIF (air); 0.5 kg (personal hand-carry)

    官方指引金额未确认
    • Regulation of Imports and Exports Regulations, reg 3(1), (2)(b), (2A)

  • Code of Practice issued by the Registrar of Regulated Dealers under the PSPM Act codes-of-practice power (issued 2 April 2026): dealers apply the A.C.T. framework (Add immediate intervention, Check the customer's behaviour against anti-scam information, Tell the customer to call the ScamShield Helpl…

    S$20,000

    官方指引
    • PSPM Act, codes of practice power (section in refs), CoP para 1.1

      “This Code of Practice ("CoP") is issued by the Registrar of Regulated Dealers under section 35(1) of the Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act 2019 ("PSPM Act").”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.1

      “PSMDs should apply the A.C.T. framework at paragraph 5.2 when encountering customers making purchases under the following circumstances, regardless of payment mode:”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.1(a)

      “Single transaction of more than S$20,000; or”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.1(b)

      “Multiple transactions below S$20,000 that collectively exceed S$20,000, whether conducted on the same day or over a few days.”

    • PSPM Act, codes of practice power (section in refs), CoP Annex B-2 item 7 (A.C.T.)

      “A - Add immediate intervention by asking the customer for reasons behind the purchase.”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.2 (C)

      “Check for the customer's”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.2 (T): call the ScamShield Helpline

      “Tell the customer that”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.3(a)

      “Conduct enhanced customer due diligence in accordance with the Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Regulations 2019;”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.3(e)

      “Escalate the matter to the supervisor or senior management and document the customer's behaviour and the basis for proceeding with the transaction;”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.3(f)

      “Call the police at 999 if the customer chooses to proceed with the purchase despite repeated warnings that red flags are present; and”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.3(g)

      “File a Suspicious Transaction Report ("STR").”

    • PSPM Act, codes of practice power (section in refs), CoP para 5.4

      “For online sales, in-person collection should be required for purchases above S$20,000.”

    • PSPM Act, codes of practice power (section in refs), ACD News: issuance of the CoP

      “2 April 2026 ## Issuance of Code of Practice on AML Measures for PSMDs to Combat Scam Related Money Laundering Cases”

    • PSPM Act, codes of practice power (section in refs), PSPM Act s.35(5)

      “Any code of practice, guideline or standard of performance has no legislative effect.”

    • PSPM Act, codes of practice power (section in refs), PSPM Act s.35(6)

      “Any failure by a regulated dealer to comply with any code of practice, guideline or standard of performance applicable to the regulated dealer does not of itself render the regulated dealer liable to criminal proceedings, but the failure may, in any proceedings (criminal or otherwise), be relied on by any party to those proceedings as tending to establish or negate any liability which is in question in those proceedings.”

    • PSPM Act, codes of practice power (section in refs), PSPM Act s.35(1)

      “The Registrar may issue, approve, amend or revoke one or more codes of practice, guidelines or standards of performance for all or any of the following purposes:”

  • STR to a Suspicious Transaction Reporting Officer as soon as reasonably practicable on knowledge or reasonable grounds to suspect (CDSA), or the TSOFA disclosure where it applies, with a copy to the Registrar at the time of disclosure or immediately after (PSPM Act); records of every designated tran…

    法律原文
    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), CDSA s.45(1) (parsed into section a1-s-42 of this record)

      “Where a person knows or has reasonable grounds to suspect that any property -”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), CDSA s.45(1)

      “the person must disclose the knowledge or suspicion or the information or other matter on which that knowledge or suspicion is based to a Suspicious Transaction Reporting Officer as soon as is reasonably practicable after it comes to the person's attention.”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.21(1)

      “A regulated dealer must, if circumstances exist that require the regulated dealer to do so, make a disclosure under whichever of the following is applicable:”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.21(2)

      “A regulated dealer must, at the time of disclosing a matter under subsection (1) or immediately thereafter, submit a copy of the information so disclosed to the Registrar.”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.18(1)(a)

      “a record of every designated transaction (whether or not completed) and every other transaction for which the customer due diligence measures mentioned in section 16 must be performed, containing the prescribed information on that transaction;”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.18(1)(b)

      “a record of all information relating to a customer which is obtained through the customer due diligence measures performed under section 16;”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.18(1)(c)

      “a copy of each supporting document relied on in support of any information referred to in paragraph (b);”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.19(1)

      “A regulated dealer must, in relation to the regulated dealer's business of regulated dealing or business as an intermediary for regulated dealing, implement adequate programmes and measures to prevent money laundering, terrorism financing and the financing of proliferation of weapons of mass destruction.”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), PMLTFPF Regulations reg 13(1)

      “For the purposes of section 18(1) or (1A) of the Act, the period for which the documents and information in that section must be kept is 5 years after whichever of the following dates is applicable:”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 13(3)(f)

      “a record of the following information for each period of 6 months beginning on 1 January or 1 July of any year:”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 13(5)

      “the prescribed manner of making any record kept under paragraph (3)(f) available to the Registrar is by submitting the record to the Registrar through the electronic system of the Ministry of Law at https://acd.mlaw.gov.sg.”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 14(1)(b)(i)

      “document the risk assessments;”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 14(1)(c)

      “develop and implement internal policies, procedures and controls, which must be approved by its senior management, to manage and effectively mitigate the risks of money laundering, terrorism financing and proliferation financing identified by it or notified to it by the Registrar, including -”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 14(1)(c)(i)

      “making appropriate compliance management arrangements, including the appointment of a compliance officer; and”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 14(1)(c)(ii)

      “applying adequate screening procedures when hiring employees;”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 14(1)(e)

      “have an ongoing programme to train employees on the internal policies, procedures and controls in sub-paragraph (c); and”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), reg 14(2)

      “A regulated dealer that carries out one or more designated transactions must, in addition to the matters mentioned in paragraph (1), have an independent audit function to test the internal policies, procedures and controls in paragraph (1)(c).”

    • CDSA; PSPM Act; PMLTFPF Regulations (sections in refs), Guidelines v5.1 para 12.2.1

      “is required to submit an STR to STRO as soon as reasonably practicable upon the establishment of suspicion (i.e. no longer than 5 business days).”

  • Before dealing, dealers must assess whether the customer, principal or beneficial owner is a terrorist or terrorist entity (TSOFA), a designated person under UN Act regulations, or a Registrar-notified person; if suspected they must decline or terminate the transaction, report to the police and copy…

    法律原文
    • PMLTFPF Regulations 2019 reg 16; TSOFA s.8

  • CDD before any designated transaction (sale for cash or cash equivalent above S$20,000, single or same-day aggregate; purchase by a secondhand-goods dealer from a non-dealer for cash above S$20,000; token redemptions for cash above S$20,000), on suspicion of ML/TF/PF, or on doubts about earlier CDD;…

    S$20,000

    法律原文
    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.16(1)(a)

      “before entering into a designated transaction;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.16(1)(b)

      “where the regulated dealer has reason to suspect money laundering, terrorism financing or the financing of proliferation of weapons of mass destruction;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.16(1)(c)

      “where the regulated dealer has reason to doubt the veracity or adequacy of information obtained from earlier customer due diligence measures;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.16(1)(d)

      “under circumstances prescribed for the purposes of this section.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.16(5)(a)

      “decline to enter into any transaction with the customer;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.16(5)(b)

      “terminate any transaction entered into with the customer;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.16(5)(c)

      “determine whether to make a disclosure under section 45 of the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 or section 8 or 10 of the Terrorism (Suppression of Financing) Act 2002;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PSPM Act s.15 "designated transaction" (a)

      “a sale of any precious stone, precious metal, precious product or asset-backed token by a regulated dealer to a customer, for which cash or a cash equivalent exceeding the threshold amount is received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.15 (b)

      “2 or more sales of any precious stone, precious metal, precious product or asset-backed token in a single day by a regulated dealer to the same customer, or to customers whom the regulated dealer knows act on behalf of the same person, for which cash or a cash equivalent in total exceeding the threshold amount is received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.15 (c)

      “a purchase of any precious stone, precious metal or precious product from a customer (who is not a regulated dealer) by a regulated dealer (who is a secondhand goods dealer), for which cash or a cash equivalent exceeding the threshold amount is received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), s.15 "threshold amount"

      “"threshold amount" means $20,000 or its equivalent in value, or an amount prescribed in substitution.”

    • PSPM Act; PMLTFPF Regulations (sections in refs), PMLTFPF Regulations reg 4(1)(a)

      “a redemption of an asset-backed token from a customer (who is not a regulated dealer) by a regulated dealer, for cash or a cash equivalent exceeding the threshold amount;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 4(1)(c)

      “2 or more redemptions of any asset-backed token in a single day by a regulated dealer from the same customer”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 4A(1)

      “For the purpose of section 16(1)(d) of the Act, each of the following circumstances are circumstances in which a regulated dealer must perform the prescribed customer due diligence measures in regulations 5 and 6”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 4A(1)(a)

      “for which gold (except in the form of jewellery) the value of which exceeds the threshold amount is received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 4A(1)(c)

      “for which digital payment tokens the value of which exceeds the threshold amount are received as payment;”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 5(1)

      “the customer due diligence measures to be performed by a regulated dealer before entering into any designated transaction with a customer who is an individual are all of the following:”

    • PSPM Act; PMLTFPF Regulations (sections in refs), reg 6(1)

      “the customer due diligence measures to be performed by a regulated dealer before entering into any designated transaction with a customer who is an entity or a legal arrangement are all of the following:”

  • Anyone moving physical currency or bearer negotiable instruments above the prescribed amount (S$20,000, CMR Regulations reg 2A) into or out of Singapore must report it: travellers on Form NP 727 within 72 hours before immigration clearance; senders and commercial carriers of cash by post or courier …

    S$20,000

    法律原文金额未确认
    • CDSA 1992 Part 6A; CDSA (Cross Border Movements of Physical Currency and Bearer Negotiable Instruments) Regulations 2007, CDSA ss.59-62; regs 2A, 3, 4, 4A, 5

  • Anyone carrying on a business of manufacturing, importing or possessing for sale, selling or offering for sale, or buying for resale any precious metal (gold, silver, platinum group metals, and alloys with at least 2% in weight of them, in manufactured or unmanufactured state), precious stone or pre…

    No value floor for bullion; unregistered dealing: fine up to S$75,000 or imprisonment up to 3 years or both, plus up to S$7,500 for every day of a continuing offence

    法律原文
    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), PSPM Act s.6(1)

      “A person must not act as or hold out to be a regulated dealer unless the person is a registered dealer.”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), PSPM Act s.6(2)

      “A person who contravenes subsection (1) shall be guilty of an offence and shall be liable on conviction to a fine not exceeding $75,000 or to imprisonment for a term not exceeding 3 years or to both and, in the case of a continuing offence, to a further fine not exceeding $7,500 for every day or part of a day during which the offence continues after conviction.”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), s.2 "regulated dealing" (a)

      “manufacturing any precious stone, precious metal or precious product;”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), (b)

      “importing or possessing for sale any precious stone, precious metal or precious product;”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), (c)

      “selling or offering for sale any precious stone, precious metal or precious product;”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), (d)

      “selling or redeeming asset-backed tokens;”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), (e)

      “purchasing any precious stone, precious metal or precious product for the purposes of resale;”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), s.2 "regulated dealer" (b)

      “business as an intermediary for regulated dealing, but excludes a pawnbroker and any other person as may be prescribed;”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), s.2 "precious metal"

      “"precious metal" means any precious metal specified in Part 1 of the Schedule in a manufactured or unmanufactured state;”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), the Schedule Part 1 item 9 (items 1-8: gold, silver, platinum, iridium, osmium, palladium, rhodium, ruthenium)

      “An alloy with at least 2% in weight of any substance mentioned in items 1 to 8”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), ACD Regulatory Regime page

      “"Precious metals" include gold, silver, platinum, iridium, osmium, palladium, rhodium, ruthenium, and alloys with at least 2% in weight of any of the metals stated above.”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), Exempt Persons Order para 3

      “Every financial institution that carries on a business of regulated dealing, or business as an intermediary for regulated dealing, in Singapore is exempt from -”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), Order para 4(1)

      “A foreign dealer carrying on a business of regulated dealing, or business as an intermediary for regulated dealing, in Singapore on a transitory basis, is exempt from -”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), Order para 4(2)

      “A foreign dealer carries on business in Singapore on a transitory basis if the foreign dealer carries on business in Singapore for not more than a total of 90 days in a year.”

    • PSPM Act (definitions, registration duty, the Schedule); Exempt Persons Order (sections in refs), PSPM Act Legislative History item 1

      “Commencement : 10 April 2019”

  • Gold may not be imported, transhipped or brought in transit from the DPRK (Seventh Schedule, prohibited imports item (9)), nor exported, transhipped or brought in transit to the DPRK (luxury items, prohibited exports item (5)(k) "gold, silver and platinum"); any goods for trade with a person in the …

    法律原文
    • Regulation of Imports and Exports Regulations, regs 5A, 6(1)(b), 6(2)(c); Seventh Schedule item 2 (DPRK)

  • GST-exempt status depends on the bar: gold of at least 99.5% purity in bar, ingot or wafer form, refined by a refiner who is or was on the LBMA Good Delivery list (or an Enterprise Singapore-endorsed intending refiner — none endorsed on 28 Sep 2026), bearing a mark internationally accepted as guar…

    法律原文
    • GST Act 1993, Fourth Schedule, Part 2 paras 1(a), 1A; Part 3 para 2

  • No Singapore statute requires importers, dealers or refiners to verify mine origin or apply OECD/CAHRA due diligence: the PSPM Act and Regulations impose customer (not supplier-origin) due diligence, the GST investment-precious-metal exemption turns on form, purity, a refiner on the LBMA Good Delive…

    法律原文
    • PSPM Act s.2 "customer"

      “"customer" means a person with whom a regulated dealer enters into or intends to enter into a transaction;”

    • PSPM Act s.16(1): CDD is on the customer

      “a regulated dealer must perform the prescribed customer due diligence measures in any of the following circumstances:”

    • PMLTFPF Regulations reg 5(1)

      “the customer due diligence measures to be performed by a regulated dealer before entering into any designated transaction with a customer who is an individual are all of the following:”

    • reg 6(1)

      “the customer due diligence measures to be performed by a regulated dealer before entering into any designated transaction with a customer who is an entity or a legal arrangement are all of the following:”

    • GST Act Fourth Schedule Part 2 para 1(a)(i) (parsed into section sch-3 of this record)

      “is in the form of a bar, an ingot or a wafer;”

    • para 1(a)(ii)

      “is of a purity of at least 99.5%; and”

    • Fourth Schedule Part 2 para 2(a)(i)

      “in the case of gold or silver, a refiner who is or was in the "Good Delivery" list of the London Bullion Market Association;”

    • para 2(b)

      “it bears a mark or characteristic that is internationally accepted as guaranteeing its quality.”

    • Singapore Customs IPM page, permit field "Supplier name"

      “Name of refiner who produced the bar/wafer/ingot”

    • Guidelines v5.1 Annex D, red flag indicators

      “Supplier/ introducer is evasive when being asked about the source of its gold supply.”

  • Singapore's Russia measures ban the export, transhipment and transit to Russia of military goods and of dual-use goods in Categories 3 (electronics), 4 (computers) and 5 (telecommunications and information security) of the Strategic Goods (Control) Order 2021 as in force on 16 Mar 2022 (RIER reg 6(2…

    法律原文
    • Regulation of Imports and Exports Regulations, reg 6(2B); Eighth Schedule

  • Goods to or from UNSC-sanctioned countries need a TradeNet permit applied for at least 3 working days before shipment. Iran lists cover nuclear, arms and S/2015/546 items, not gold.

    官方指引
    • Regulation of Imports and Exports Regulations, regs 5A, 6(1)(b), 6(2)(c)

  • Zero-GST warehouse licensees may store "listed goods" (incl. HS 7108 gold, silver, platinum and precious stones) only with Singapore Customs' written approval, at least a Type II licence, and records of the persons controlling and beneficially owning the goods, screened and kept up to date (since 1 …

    官方指引

第 3 段:阿拉伯联合酋长国

货物终点

  1. 31

    Pre-contract KYC on the Nigerian exporter: corporate docs, UBO, MBC/export-permit evidence, mine-of-origin declaration

    执行方
    DMCC importer / trader
    所需
    Bank-to-bank reference confirmation (not a public letter) on the Nigerian exporter
    出具
    Importer's KYC/due-diligence pack on the Nigerian exporter; Evidence pack from the Nigerian exporter: export licence/permit, mine location, legal existence of the ASM operation
    官方指引

    [conflict] For an ordinary DMCC trader the binding CDD duties are those of CR 134/2025 (Arts. 5-14); DMCC RBD-GPM binds only its Accredited Members (see ae.div-dmcc-role). [inferred] "Highest-scrutiny category" for ASM is the model's reading of Rule 1.6, not a phrase in the Rules.

    • DMCC RBD-GPM Rules v2/2020; Cabinet Resolution 134/2025, DMCC Rules 1.4-1.8 (KYC; Rule 1.6 specific requirements for ASM supply), Rules 2.4-2.8 (red flags); CR 134 Art. 25(1) (records at least 5 years)

  2. 32

    File the Dubai Customs declaration on Mirsal 2 with invoice, packing list, certificate of origin and air waybill (for a free-zone consignee the Customer Guide's 'FZ Transit In' type appears to apply, not import to local); disclose the precious metals crossing the border

    执行方
    DMCC importer / trader
    所需
    Air waybill; Certificate of origin; Origin country's export authorisation for the gold (permit, licence or clearance issued by the mining or trade authority); Commercial invoice; Packing list
    出具
    Dubai Customs declaration filed online (for goods entering a free zone: "FZ Transit In"); Disclosure of precious metals crossing the UAE border (cargo included)
    官方指引

    No UAE import permit for gold: Dubai Customs lists DMCC as restricting authority only for "Pearls, Diamonds, Rough Diamonds etc." (Customer Guide App. I). FZ Transit In (s.15.12.2): "foreign goods originated from any country may be brought into the free zones without being subject to customs duties or taxes. The owner of the goods in the Documents shall be a Free Zone Licensee"; documents MAWB/HAWB, commercial invoice, certificate of origin, packing list, delivery order. Mainland duty: the GCC exempted list's gold line is printed "71060000" (silver's heading) [summary][blocked]. Cross-border disclosure: see ae.doc-pm-disclosure-ae. [unconfirmed] Neither Dubai Customs guide names the declaration type for gold into a DMCC company or the DMCC Vault. [conflict] Supporting documents are due within 14 days (Customer Guide s.15.7) or 30 days (Service Guide v9 App. A) - see ae.div-customs-doc-deadline. KPMG (secondary): periodic "Goods Consumption within FZ" declaration under Dubai Customs Notice 17/2020.

    • Dubai Customs Customer Guide v3.03; Dubai Customs Service Guide v9; Federal Decree-Law 10/2025, Customer Guide s.15.12.2 (FZ Transit In), App. J (DMCC declarations at the Customer Service Center at DMCC); FDL 10/2025 Art. 10 (cross-border disclosure)

  3. 33

    Import VAT: registered importer accounts for VAT on its own return (reverse charge); investment-grade gold is zero-rated, doré is not

    执行方
    DMCC importer / trader
    出具
    Import VAT accounted on the importer's own VAT return (registered importer)
    法律原文

    Investment precious metals = gold, silver or platinum of 99% purity or more, in a form tradeable in global bullion markets (ER Art. 36(2), not amended in the consolidation to CD 100/2025); their supply or import is zero-rated (Art. 45(8)). [inferred] Doré below 99% does not qualify. [unconfirmed] DMCC's absence from the Designated Zones was checked only against the 2017 list (secondary copy). [not-read] FDL 16/2025 amendments (from 1 Jan 2026) not held.

    • Federal Decree-Law 8/2017 on VAT; Executive Regulation (Cabinet Decision 52/2017, as amended; consolidated to CD 100/2025), Law Art. 45(8), 48(1), 49; ER Art. 36(2), 48(1), 48(5), 50(1)

  4. 34

    If the importer sells the doré to the refiner (rather than toll-refining it): refiner gives two written statements before supply; importer issues a tax invoice without VAT (reverse charge)

    执行方
    DMCC importer / trader
    出具
    Refiner's two written statements: VAT-registered, and buying to resell or use in production; Tax invoice without VAT for the importer-to-refiner sale
    法律原文

    [inferred] Conditional: the model reads the reverse charge as not applying where the refiner only toll-refines metal the importer keeps title to; the sources read do not address toll refining.

    • Cabinet Decision 127/2024; VAT Executive Regulation, CD 127 Art. 2(1), 2(3) (two written declarations before supply; supplier keeps them and verifies registration), 2(4) (no declarations: no reverse charge); ER Art. 59(1)(l)

  5. 35

    Deposit refined bars into DMCC Vault (operated by Brink's)

    执行方
    DMCC Vault (operated by Brink's)
    所需
    Manufacturer certificate accompanying UAEGD bars (states year of manufacture if not stamped)
    出具
    DMCC Vault deposit/withdrawal receipt; DMCC Tradeflow warrant (optional; used for pledging and title transfer)
    官方指引

    DMCC: the Vault is "Owned by DMCC and operated by Brink's Global Services" and "DMCC can assist with all customs processes". [not-read] Deposit/withdrawal documents and any bonded status of the Vault are not published; the receipt document is inferred.

  6. 36

    Reconcile the provisional (origin) assay against the Dubai refiner's outturn assay: within the contract's splitting limit the two assays are commonly averaged; beyond it an umpire assay decides (the assay closer to the umpire's is used, and the party further from it pays the umpire); settle the difference and pay the final balance

    执行方
    DMCC importer / trader
    所需
    Refiner outturn/assay report; Commercial invoice
    出具
    Final invoice from the Nigerian exporter (against Dubai outturn assay); Reconciliation of provisional vs outturn assay; Balance/final payment wire; DPMSR filed in goAML for the final settlement
    二手资料

    [unconfirmed] Debit and credit notes are not described in the two contracts read; the Johnson Matthey contract settles by metal credit, adjusted after the umpire result.

    • Refining/sale contract settlement clause -- splitting limit + umpire assay if the two figures diverge beyond it

税费

  • Customs duty on gold imports

    0% for goods entering a free zone (FZ Transit In); mainland imports of gold: 0% under the GCC exempted-commodities list (read via WebFetch only) Unwrought and semi-manufactured gold

    官方指引金额未确认
    • Dubai Customs Customer Guide v3.03; GCC common customs law; UAE list of exempted commodities, Customer Guide s.9 (duty suspended for goods admitted into free zones), s.15.12.2

  • Domestic reverse charge on precious metals and precious stones between registered businesses

    Recipient accounts for VAT Supplies of gold, silver, platinum, palladium, precious stones and jewellery made of them, for resale or production, between VAT-registered persons, with the buyer's written declaration (CD 127/2024, replacing CD 25/2018)

    法律原文
    • Cabinet Decision 127/2024; FTA VATP043, Art. 1 (Goods: precious metals - gold, silver, palladium, platinum - precious stones and jewellery mostly of them), Art. 2(1)-(4), Art. 4 (repeals CD 25/2018)

      “Precious Metals, Precious Stones and jewelry made of any Precious Metals or Precious Stones”

  • Special reverse charge on gold and diamonds between registrants (Cabinet Decision 25/2018)

    Registered recipient accounts for VAT Gold and products mostly of gold not qualifying for zero-rating, and diamonds, supplied between registrants; exports of gold items and investment precious metals outside its scope (VATP029)

    官方指引
    • Cabinet Decision No. 25 of 2018

  • Import VAT

    5% standard; 0% for investment precious metals (99%+ purity, tradeable form) Doré is not investment gold, so it is standard-rated; refined bars of 99%+ are zero-rated

    法律原文金额未确认
    • Federal Decree-Law 8/2017 on VAT; Executive Regulation, Art. 3 (5%), 45(8), 48(1), 49; Exec. Reg. Art. 36(2), 48, 50(1)

      “a standard rate of 5% Tax shall be imposed on any supply or Import”

管制

  • Precious metals crossing the UAE border must be disclosed; declarations are also required for precious metals over AED 60,000 crossing through cargo, mail or shipments, cargo being declared through the official customs systems.

    AED 60,000

    法律原文金额未确认
    • Federal Decree-Law 10/2025; CBUAE Regulation on the Declaration of Currencies, BNIs, and Precious Metals and Stones (OG 703, 31 May 2021), FDL 10/2025 Art. 10 (duty to disclose, per the disclosure system issued by the ICP with the Central Bank), Art. 41(3) (regulations under FDL 20/2018 remain effective insofar as not conflicting), Art. 34 (penalty)

      “Any person entering into or departing from the State shall be under the obligation to make a disclosure whenever they carry currencies, bearer negotiable instruments, precious metals, or valuable stones, in accordance with the disclosure system issued by the Federal Authority for Identity, Citizenship, Customs and Port Security, in coordination with the Central Bank”

  • Dealers in precious metals and stones are DNFBPs for any single cash transaction, or linked transactions, of AED 55,000 or more (CR 134/2025 Art. 3 item 3), and keep records for at least 5 years (Art. 25). The DPMSR report, including for dealings with companies of AED 55,000 or more paid in cash or …

    AED 55,000

    法律原文
    • Cabinet Resolution 134/2025; MoET Supplemental Guidance for DPMS 2026, CR 134 Art. 3(3), Art. 25(1); Guidance s.1.4.1

      “when carrying out any single cash transaction or several transactions that appear to be linked and whose value equals or exceeds fifty-five thousand dirhams (AED 55,000)”

  • Supply-chain entities and precious-metals dealers must have due-diligence management systems, identify and assess supply-chain risks and adopt a risk-management strategy (Decree Art. 1(A)); refiners must also appoint an independent third-party auditor and submit a due-diligence report (Art. 1(B)), u…

    法律原文
    • Ministerial Decree 68/2024; MoE Due Diligence Regulations v1 (2022), Decree Art. 1(A), 1(B), Art. 3 (penalties under the AML law)

第 4 段:俄罗斯

回到原产国:出口收益

  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)

    执行方
    Licensed exporter (mining company, refiner or bank holding a Minpromtorg export licence)
    出具
    Receipt of export proceeds
    法律原文

    [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

国家之间的衔接

  • 俄罗斯 → 新加坡 未研究

    随货跨境的文件: 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

  • 新加坡 → 阿拉伯联合酋长国 未研究

    随货跨境的文件: Inbound air waybill; Foreign supplier's commercial invoice; Packing list; Bar list from the foreign supplier (serials, weights, fineness, refiner); TradeNet In-Non-Payment (GST Relief) permit for IPM (declaration type GTR, place of receipt IGPM); Refinery weigh-in record; Refiner outturn statement (weigh-in, assay, fine gold credited); Singapore refiner's bar list / product certificate (serial, fine weight, fineness, hallmark); TradeNet permit for goods to/from a UNSC-sanctioned country; TradeNet export (Out) permit; Ordinary (non-preferential) certificate of origin; Outbound air waybill

文件缺口

  • sg.st-02 expects Refiner's certificate for the bars it produced (serials, fineness, weights, year); the earlier legs don't model this paper