Canada (refine) → United States → 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

Screen the supplier and the gold: KYC, OFAC sanctions lists, and confirm the gold is not of Russian Federation origin (unless it was outside Russia before 28 June 2022); apply CAHRA red flags from the 2023 Africa Gold Advisory

执行方

Importer of record (bullion bank, trader, refiner or dealer)

所需

Commercial invoice; Bar list (serials, weights, fineness)

出具

Importer's supplier KYC and OFAC / Russian-origin screening file

• E.O. 14068; OFAC Determination (effective 28 Jun 2022, amended 22 Dec 2023), E.O. 14068 s.1(a)(i); determination under s.1(a)(i)(A), 1(b) and 5; delegation 31 CFR 587.802

File entry (CBP Form 3461 or electronic equivalent) with evidence of the right to make entry, commercial invoice and packing list, and the entry summary (CBP Form 7501) classifying the gold under HTSUS 7108 with country of origin; deposit any duty (heading 7108 free except 4.1% on 7108.12.50 and 7108.13.70 for non-preference origins) and the 0.3464% merchandise processing fee; shipments of $2,500 or less may use informal entry

执行方

Licensed customs broker

所需

Importer's supplier KYC and OFAC / Russian-origin screening file; Commercial invoice; Packing list; Air waybill

出具

CBP Form 3461 entry / immediate delivery (or ACE electronic equivalent); CBP Form 7501 entry summary (HTSUS classification, origin, duties and fees)

• 19 CFR 142.3; 19 CFR 143.21; 19 CFR 24.23; HTSUS 7108

Review, examine if selected, and release the goods; CBP enforces the Russian-origin gold ban and any withhold release order on gold made with forced labour

执行方

US Customs and Border Protection

所需

CBP Form 3461 entry / immediate delivery (or ACE electronic equivalent)

出具

CBP release of entered goods (ACE cargo release)

• 19 CFR 142.3; E.O. 14068 gold determination; 19 U.S.C. 1307 and 19 CFR 12.42

Deliver released gold directly to the refinery or to a COMEX-approved depository (for COMEX, bars must come directly from an approved producer or assayer with certificates, or from another depository)

执行方

Secure logistics carrier (armoured / valuables; COMEX-approved carrier where relevant)

所需

CBP release of entered goods (ACE cargo release)

出具

Delivery record airport to refinery or depository

Deliver bars into a COMEX-approved depository directly from the approved producer with refiner certificates, from an approved assayer with assay certificates, or from another approved depository

执行方

Secure logistics carrier (armoured / valuables; COMEX-approved carrier where relevant)

所需

Refiner certificate for bars produced (brand, serial, weight, fineness)

出具

Chain-of-integrity receipt at depository

Inspect and weigh the bars and record them as eligible stock

执行方

COMEX-approved depository / bullion vault

所需

Chain-of-integrity receipt at depository; Bar list (serials, weights, fineness)

出具

Depository inspection, weight record and eligible-stock entry

Issue an electronic warrant in the name of the clearing member, referencing bar serials and the approved producer; the metal becomes registered (deliverable) stock

执行方

COMEX-approved depository / bullion vault

所需

Depository inspection, weight record and eligible-stock entry

出具

COMEX gold warrant (electronic UCC Article 7 document of title)

• COMEX Rulebook; UCC Article 7, Rule 705.A; 113108

Report eligible, pledged and registered stocks to the exchange registrar daily by 2:00 p.m.

执行方

COMEX-approved depository / bullion vault

Optionally pledge the warrant to CME as collateral (title to CME, first-priority security interest, 15% haircut)

执行方

Futures clearing member / bullion bank

所需

COMEX gold warrant (electronic UCC Article 7 document of title)

Release the bars from the depository (load-out after warrant cancellation if on COMEX warrant) to the carrier

执行方

COMEX-approved depository / bullion vault

所需

Depository inspection, weight record and eligible-stock entry

File EEI in AES for the foreign-origin gold and give the ITN to the carrier (same rules as export; BIS licence for Russia/Belarus)

执行方

US principal party in interest (USPPI) / exporter

出具

EEI/ITN for re-export of foreign-origin gold

• Foreign Trade Regulations, 15 CFR 30.2, 30.4

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.