Switzerland → Russian Federation → China (mainland) (refine) · Deposit, trade and withdrawal on the Shanghai Gold Exchange

Screen the bars, buyer and destination against Swiss sanctions before release: no purchase, import, transit or related services (including brokerage and financing) for gold of Russian origin exported after 4 Aug 2022 or gold processed from it in third countries

执行方

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

[transcription] Art. 14d paras 1-4 read in an unofficial third-party English translation (as at 22 Mar 2024, held in laws/); Annex 26 covers 7108, 7112 91 and ex 7118 90 gold coins; Annex 27 ex 7113 and ex 7114. [unconfirmed] The official consolidation is now Stand 21 Sep 2026 and was not read (the fetch tool truncates before Art. 14d); changes after March 2024 are not ruled out. The ordinance contains no explicit ban on selling gold to Russia; the export-side effect is through the services ban.

• Ordinance of 4 March 2022 on measures in connection with the situation in Ukraine (SR 946.231.176.72), Art. 14d

Release the bars from the refinery vault or free port against the owner's instruction and prepare the weight list (bar list), commercial invoice and packing list for the shipment

执行方

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

出具

Outbound weight list / bar list; Commercial invoice to the foreign buyer; Packing list

The weight list is sourced to LBMA Annex C; commercial invoice and packing list are standard export practice, not read in a Swiss source.

• LBMA Good Delivery Rules, Annex C (weight lists); Customs Act Arts. 62-66 (free ports)

Lodge the electronic export declaration in Passar (HS 7108; e-dec Export was usable only to end-2025); the declarant must make it binding and physically export the goods within 120 days of its acceptance in the IT system

执行方

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

出具

Passar export declaration (HS 7108)

R-10-10 (valid 1 Jan 2026) cites Art. 25-29 ZG and Art. 79-83 ZV for the declaration duty, says declarations are electronic in principle, and sets the 120-day limit from acceptance in the IT system. R-10-10 held and read in full on 2026-09-28; the Customs Act and Ordinance texts themselves were not read. R-10-10 has no gold-specific rule.

• Customs Act (ZG, SR 631.0); BAZG R-10-10, ZG Arts. 25-29 (as cited in R-10-10)

Receive the export assessment notice (Veranlagungsverfuegung Ausfuhr), the evidence that the goods were properly cleared for export

执行方

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

出具

Veranlagungsverfuegung Ausfuhr

R-10-10 cites Art. 38 and 69 ZG and Art. 92 ZV for the export assessment notice and says it is evidence of proper assessment and of export for VAT. R-10-10 held and read in full on 2026-09-28.

• Customs Act (ZG); BAZG R-10-10, ZG Arts. 38 and 69; ZV Art. 92 (as cited in R-10-10)

Treat the sale as a VAT-exempt export (supply of goods directly transported abroad) and keep the export assessment notice as evidence

执行方

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

所需

Veranlagungsverfuegung Ausfuhr

Art. 23(2) no. 1 read in the held MWSTG (Stand 1 Jan 2025, German wording current). Art. 23(3): direct export includes export into an open customs warehouse or a free port. Investment gold of at least 995 fineness is separately exempt with credit under Art. 23(2) no. 12 (see ch.tax-import-vat).

• Federal VAT Act (MWSTG, SR 641.20), Art. 23(2) no. 1

Hand the sealed consignment to a secure valuables carrier and fly it out (Zurich or Geneva) under an air waybill

执行方

Swiss refiner (melter/trade-assayer licence, LBMA Good Delivery-listed)

出具

Air waybill (outbound)

Carrier practice. Cantonal licensing: in the Canton of Zurich "Sicherheitstransporte von Personen, Gütern und Wertsachen" require a licence under the Polizeigesetz, 9. Abschnitt (cantonal page, read by WebFetch 2026-09-28; PolG text not read). Geneva and other cantons not checked. No Swiss source read describes the outbound air leg for gold.

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)

Hold the PBoC gold import/export qualification (bank that is an SGE financial member or market maker, or qualified mining group or refiner)

执行方

Bank holding PBoC gold import/export qualification (SGE financial member or market maker)

• Gold and Gold Products Import/Export Measures, Arts. 7, 8, 10

Apply to the PBoC for a permit for the batch: application form, import contract and (on repeat applications) nothing further unless details changed

执行方

Bank holding PBoC gold import/export qualification (SGE financial member or market maker)

出具

Gold and Gold Products Import/Export Application Form (《黄金及黄金制品进出口申请表》) with contract; Gold import/export contract (required with the permit application)

• Gold and Gold Products Import/Export Measures, Art. 10

Examine (verification by two or more staff where needed) and decide within 20 working days; issue the permit, one per batch, usable within 40 working days

执行方

People's Bank of China (permit issuer and reserve holder)

所需

Gold and Gold Products Import/Export Application Form (《黄金及黄金制品进出口申请表》) with contract; Gold import/export contract (required with the permit application)

出具

PBoC permit (import batch)

• Gold and Gold Products Import/Export Measures, Arts. 3, 14-17

Pay the foreign seller through the bank under foreign-exchange rules

执行方

Bank holding PBoC gold import/export qualification (SGE financial member or market maker)

所需

Gold import/export contract (required with the permit application)

出具

Import payment through an FX-authorised bank

[not-read] SAFE detailed goods-trade FX rules (current-account guidelines) not held; the FX Regulations require a genuine transaction basis checked by the bank.

• Gold and Gold Products Import/Export Measures; FX Regulations, Measures art. 23; FX Regulations arts. 12, 14

Declare the gold to Customs (HS 7108) presenting the PBoC permit; import-stage VAT is exempt for gold (incl. standard gold) and gold ore

执行方

Bank holding PBoC gold import/export qualification (SGE financial member or market maker)

所需

PBoC permit (import batch); Export customs declaration accepted by the dispatching country's customs; Air waybill; Refiner's certificate for the bars it produced (serials, fineness, weights, year); Commercial invoice

出具

Customs import declaration (进口货物报关单), HS 7108

[unconfirmed] Import duty rate for 7108 not held (cn.gap-tariff). [unconfirmed] Continuation of the import-stage VAT exemption after 1 Jan 2026 (cn.gap-import-vat-2026; MOF/GAC/SAT 2026 No. 17 read only in summary [summary]).

• Gold and Gold Products Import/Export Measures; Customs Law; Caishui [2002] 142, Measures arts. 3, 17; Customs Law art. 24; Caishui 142 point 1

Register the imported gold on SGE and complete its first trade there (duty to balance domestic physical supply)

执行方

Bank holding PBoC gold import/export qualification (SGE financial member or market maker)

所需

Customs import declaration (进口货物报关单), HS 7108

出具

SGE registration and first-trade record of imported gold; SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)

• Gold and Gold Products Import/Export Measures, Art. 6

Report execution of the permit to the PBoC

执行方

Bank holding PBoC gold import/export qualification (SGE financial member or market maker)

所需

PBoC permit (import batch)

出具

Report to PBoC on use of the import/export permit

• Gold and Gold Products Import/Export Measures, Art. 19

Receive and assay doré or raw gold under the refining or purchase agreement

执行方

SGE-accredited refiner (standard gold ingot / bar refiner)

所需

Refining Agreement (fee schedule, assay/settlement formula); VAT-exempt sales invoice for non-standard gold or gold ore (producer sale)

Chinese refiner intake practice not documented in sources read.

Refine into SGE standard ingots or bars (Au99.99 1 kg; Au99.95 3 kg; Au99.5 12.5 kg; Au100g/Au50g at 999.9) under the refiner's SGE accreditation

执行方

SGE-accredited refiner (standard gold ingot / bar refiner)

形态

Doré bar - unstamped → 999.9 kilobar

• SGE Detailed Delivery Rules; SGE Refiner Measures 2025, Delivery Rules Art. 11 and Annex 1; Refiner Measures arts. 2, 26-27

Issue the certificate of quality and packing list (bar list) for the bars

执行方

SGE-accredited refiner (standard gold ingot / bar refiner)

出具

Refiner's certificate of quality and packing list for SGE standard bars; Bar list (serials, weights, fineness)

• SGE Detailed Delivery Rules, Art. 30

Open an FT account at a margin custodian bank and trade International Board contracts (iAu99.99, iAu99.5) in offshore RMB

执行方

SGE international member or international client (SGEI, Shanghai FTZ)

出具

Free Trade (FT) account statement in offshore RMB (SGEI)

• SGE Member Management Measures (2026); SGEI Business Management Measures, Member Measures Arts. 3-4; SGEI Measures arts. 4, 20-21

Bring bars from abroad into an International Board vault (Customs-supervised, bonded) without a PBoC permit (exempt channel), through the vault's designated carrier and customs broker, giving SGE the invoice (incl. origin), packing list, bar list and non-wood packaging declaration; load-in needs SGE authorisation and bars from SGE-accredited or recognised international suppliers

执行方

SGE international member or international client (SGEI, Shanghai FTZ)

所需

Air waybill; Refiner's certificate for the bars it produced (serials, fineness, weights, year)

出具

IB vault entry papers; SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)

[not-read] Customs' own entry formalities for the bonded zone (declaration form, supervision code) not held; the SGE guidelines say the vault's appointed customs broker files them.

• Gold and Gold Products Import/Export Measures; SGE IB Vault Guidelines; SGE Vault Measures; Delivery Rules, Measures art. 20(2); Guidelines arts. 4-9; Vault Measures arts. 4, 12; Delivery Rules Art. 27 and Annex 2

Hold the bars in an International Board vault (3 bonded vaults: trading vaults in Shanghai (2) and Shenzhen (1); safekeeping vault in Shanghai). SGE's January 2026 fee schedule lists IB storage rates, while the IB page says storage and in/out fees are currently waived

执行方

SGE designated vault / International Board certified vault operator

[conflict] cn.div-conflict-ib-fees: fee schedule rates versus the waiver stated on the IB page.

• SGE Vault Measures; SGE fee schedule (Jan 2026), Vault Measures Art. 3

Withdraw for re-export abroad (exempt channel: invoice and SGE withdrawal papers; carrier appointed by the vault) or for entry into the domestic market (only by a member or client holding the gold import/export qualification, with the PBoC permit copy 1 and a customs import declaration); the destination is reported to SGE and Customs

执行方

SGE international member or international client (SGEI, Shanghai FTZ)

出具

SGE Application for Load-Out and Application of Take-delivery

• Gold and Gold Products Import/Export Measures; SGE IB Vault Guidelines; Delivery Rules; Vault Measures, Measures arts. 4, 20; Guidelines arts. 10-12, 17-19; Delivery Rules Art. 42; Vault Measures Arts. 17-18

Deposit bars at an SGE designated vault through a registered designated deposit person, with the Load-In application (3 copies), quality certificate and packing list; the vault checks gross weight (tolerance ±0.1 g for ingots, ±0.05 g for bars) and accepts only bars from SGE-accredited refiners or suppliers accredited by an SGE-recognised international market

执行方

SGE comprehensive member (producer, processor, jeweller or trader)

所需

Refiner's certificate of quality and packing list for SGE standard bars; Bar list (serials, weights, fineness)

出具

SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)

• SGE Detailed Delivery Rules; Vault Measures, Delivery Rules Arts. 11, 29-31; Vault Measures Art. 4

Sell standard gold on SGE; the seller's sale is VAT-exempt (it invoices the exchange with an ordinary invoice against the exchange's settlement invoice); while no physical delivery out of the vault takes place, the exchange's sale is also exempt and the buyer receives a settlement invoice (结算发票) only

执行方

SGE comprehensive member (producer, processor, jeweller or trader)

所需

SGE Application for Load-In (Delivery Rules Annex 4 / Vault Measures Annex 3)

出具

SGE trade and clearing record

• MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 point 1; SAT No. 23 point 1

Buyer (member or client) applies through the member platform to take delivery and presents the Load-Out application, take-delivery application and withdrawer's ID at the vault

执行方

SGE institutional client (e.g. jewellery manufacturer) trading through a member

所需

SGE trade and clearing record

出具

SGE Application for Load-Out and Application of Take-delivery

• SGE Detailed Delivery Rules, Arts. 37, 43, 45

On delivery out of the vault to a member that declared investment use on the delivery-out slip, the exchange's sale is subject to VAT levied and immediately refunded to the exchange (urban construction tax and education surcharges exempt) and SGE issues the member a VAT special invoice labelled 会员单位投资性黄金

执行方

Shanghai Gold Exchange (and SGEI)

所需

SGE Application for Load-Out and Application of Take-delivery

出具

SGE VAT special invoice labelled 会员单位投资性黄金 (member withdrawal for investment use)

• MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 points 1(1), 5, 7; SAT No. 23 point 2(1)-(2)

Deduct the input VAT shown on the SGE special invoice after use confirmation on the tax platform; onward sales of the gold, or of investment gold products made from it, are invoiced with ordinary invoices only (no special invoices, except legal gold coins)

执行方

SGE comprehensive member (producer, processor, jeweller or trader)

所需

SGE VAT special invoice labelled 会员单位投资性黄金 (member withdrawal for investment use)

出具

Member's input-VAT deduction on the SGE special invoice (VAT return schedule 2, after use confirmation)

• SAT Announcement 2025 No. 23; MOF/SAT Announcement 2025 No. 11, SAT No. 23 point 2(3)-(4); 2025 No. 11 point 1(1)

On delivery out of the vault for non-investment use (declared on the delivery slip), or to a client, the exchange's sale is exempt and SGE issues an ordinary invoice labelled 会员单位非投资性黄金 or 客户标准黄金; a general-taxpayer buyer computes input VAT at 6% of the invoice amount

执行方

Shanghai Gold Exchange (and SGEI)

所需

SGE Application for Load-Out and Application of Take-delivery

出具

SGE VAT ordinary invoice labelled 会员单位非投资性黄金 or 客户标准黄金 (non-investment use or client withdrawal)

• MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 point 1(2)-(3); SAT No. 23 points 3-4

Report the change of use to the exchange before it happens and apply, once, within 6 months, to change the declared use; red-letter invoice reversal and re-issue

执行方

SGE comprehensive member (producer, processor, jeweller or trader)

出具

Application to change declared use (investment / non-investment), once within 6 months

• MOF/SAT Announcement 2025 No. 11, Point 8

Sell onward (bars or jewellery) charging VAT at 13%; gold jewellery also bears consumption tax of 5% at retail, on the sales value excluding VAT

执行方

SGE institutional client (e.g. jewellery manufacturer) trading through a member

[unconfirmed] Later changes to the consumption-tax rate table not checked.

• VAT Law; Consumption Tax Regulations; Caishui [1994] 95, VAT Law art. 10(1); Consumption Tax rate table item 4.1; Caishui [1994] 95 points 1-2, 7

Identify contracting party and beneficial owner; assess source of wealth/funds for the specific bullion; sanctions/PEP screening

执行方

Swiss bank (bullion buyer)

出具

Bank KYC file (CDB 20): name, date of birth, nationality, domicile and ID for natural persons; company name, registered office and proof for entities; Form A - declaration of the beneficial owner of the assets; Form K - controlling persons with 25%+ of an operating entity (CDB 20 Art. 20-21)

Downgraded 2026-09-28 from primary-law: the provisions cited are CDB 20 (a self-regulatory agreement of the SBA, held and read for Arts. 4, 7, 20-21, 27-28); the AMLA itself was not read for this step. The SBA says the revised CDB will not be available until 1 Jan 2027 at the earliest. [unconfirmed] Source-of-wealth assessment and sanctions/PEP screening were not found in the CDB 20 text read. [time-limited] The GwG consolidation of 1 Oct 2026 amends the AMLA widely; effects not assessed.

• AMLA; SBA Agreement on due diligence (CDB 20), CDB 20 Art. 4 (identification; precious-metals trading and cash transactions over CHF 15,000 are separate cases), Art. 7 (data recorded), Art. 20-21 (controlling persons 25%+, Form K), Art. 27-28 (beneficial owner, Form A)

Seller presents bar list, refiner's assay certificate, chain-of-custody documentation, commercial invoice, proof of title

执行方

Swiss bank (bullion buyer)

出具

Commercial invoice from the seller to the bank (VAT law requires one only if the buyer asks for it: MWSTG Art. 26(1); contents Art. 26(2); the sale of investment gold is VAT-exempt: Art. 23(2) Ziff. 12)

A bar not from an LBMA Good-Delivery-listed refiner generally cannot be sold to a major bank without re-refining - this is market practice, not itself a statute Commercial invoice and delivery receipt are practice (no primary source); "proof of title" for allocated bars is the weight list plus the custody contract - no statutory title document found.

Verify bars against the bank's accepted-refiner list / Good Delivery List; settle loco Zurich or loco London, allocated or unallocated

执行方

Swiss bank (bullion buyer)

出具

Settlement confirmation / custody account entry; Allocated account weight list (specific bars = ownership) or unallocated account statement (contractual claim only)

Record the transaction and the clarifications made; retain the records for at least ten years after the end of the business relationship or completion of the transaction

执行方

Swiss bank (bullion buyer)

The official fedlex consolidation of the GwG is now held on the server and the article was read there; this replaces the earlier reading on droit-bilingue.ch and fedlex by WebFetch. The ten-year retention is written in words in the law (zehn Jahren), so it is kept in words here and not as an amount: the verifier reads number words in English only.

• Anti-Money Laundering Act (AMLA/GwG) (articles in refs), GwG Art. 7 Abs. 1 (records of transactions and clarifications)

  “Der Finanzintermediär muss über die getätigten Transaktionen und über die nach diesem Gesetz erforderlichen Abklärungen Belege so erstellen, dass fachkundige Dritte sich ein zuverlässiges Urteil über die Transaktionen und Geschäftsbeziehungen sowie über die Einhaltung der Bestimmungen dieses Gesetzes bilden können.”

• Anti-Money Laundering Act (AMLA/GwG) (articles in refs), Art. 7 Abs. 3 (kept at least ten years)

  “Nach Beendigung der Geschäftsbeziehung oder nach Abschluss der Transaktion be- wahrt er die Belege mindestens während zehn Jahren auf.”

• Anti-Money Laundering Act (AMLA/GwG) (articles in refs), Art. 2 Abs. 2 Bst. a (banks are financial intermediaries)

  “Finanzintermediäre sind: a.10 die Banken nach Artikel 1a des Bankengesetzes”