Introduction: compliance is your real “spread”
When you buy or import gold, the most expensive mistake isn’t a few dollars over spot it’s a paperwork gap that stalls a shipment or triggers an investigation. Key markets now expect OECD-style due diligence, clean provenance, and full declarations. Below is a practical map of the UAE, US, EU and China so you can plan procurement, routing, and settlement with confidence.
First principles for every route
- Provenance on paper: Chain-of-custody, export permits, invoices, packing lists, and independent refinery assays on delivery.
- Sanctions & illicit-trade risk: The U.S. issued a multi-agency advisory on illicit African gold; counterparties are expected to screen and document their supply chains. (OFAC)
- OECD due diligence: Most hubs align to the OECD framework (risk assessment, mitigation, reporting). Expect to be asked for it formally or informally. (DMCC)
UAE: due diligence is now the norm
The UAE tightened responsible-sourcing rules and AML/CFT controls for the gold trade. If your metal touches Dubai or UAE refineries:
- Responsible Sourcing (MoE): The Ministry of Economy published Due Diligence Regulations for Responsible Sourcing of Gold and a policy for dealers in precious metals and stones (DPMS). These align with OECD guidance and sit alongside AML/CFT rules. (Ministry of Economy)
- DMCC rules: Dubai Multi Commodities Centre references the OECD 5-step due-diligence framework in its responsible-sourcing rulebook. If you’re using DMCC firms, expect structured KYC/KYT and documentation checks. (DMCC)
- Context: Independent reports have scrutinized UAE inflows from Africa; the practical takeaway is simple arrive with documentation in order (mine origin, transport, assays, invoices), because scrutiny is high. (Financial Times)
What importers should prepare
- Counterparty KYC, beneficial ownership, and risk assessment
- Mine-of-origin proof and chain-of-custody
- Export license from origin country, transport/insurance documents
- Assay certificates and (where applicable) responsible-sourcing audit references
United States: declare everything, watch classifications, screen for illicit trade
- Declarations: CBP requires you to declare gold coins, medals, and bullion on entry; duty is typically zero, but declaration is mandatory. (CBP Help Center)
- Illicit-trade advisory: The U.S. Africa Gold Advisory flags risks from illicit networks and expects firms to conduct due diligence across suppliers, transporters, and financiers. Build that analysis into your files. (OFAC)
- Tariff/HS code watch: In August 2025, CBP clarified tariff HS code 7108.13.5500 for kilo and 100-oz bars; press coverage highlighted potential tariff exposure depending on origin and code choice. Work with your broker to classify correctly and confirm current rates. (Reuters)
What importers should prepare
- Full commercial invoice, packing list, airway bill
- Origin evidence and chain-of-custody
- Forced-labor and sanctions screening records (19 USC §1307 context)
- HS classification memo from your broker; confirm current tariff status
European Union: Conflict Minerals Regulation (gold included)
- Law in force: Since 1 Jan 2021, Regulation (EU) 2017/821 requires EU importers of **tin, tantalum, tungsten and gold from conflict-affected and high-risk areas to conduct supply-chain due diligence. National authorities enforce it; importers need policies, risk assessment, third-party checks, and reporting. (EUR-Lex)
- Enforcement climate: NGOs continue to push for stricter application; expect spot checks and requests for enhanced documentation, especially on cargoes connected to Central Africa. (The Guardian)
What importers should prepare
- OECD-aligned due-diligence file (policy, risk mapping, mitigation, audit)
- Supplier declarations and third-party assurance (where feasible)
- Contract clauses on responsible sourcing and audit rights
China: quotas, licenses, and the SGE
- Import mechanism: China’s gold imports are tightly managed by the People’s Bank of China (PBOC). Banks with licenses receive import quotas; much of the wholesale trade clears through the Shanghai Gold Exchange (SGE), which is supervised by the PBOC. (Reuters)
- Quotas move with policy: Reports in 2024–2025 show the PBOC adjusting quotas to manage domestic supply and currency dynamics. Expect periodic pauses or expansions that affect timing and price. (Reuters)
- Operational detail: SGE sets physical-delivery and vaulting rules; qualified customs brokers handle entry to bonded zones for international board deliveries. (Shanghai Gold Exchange)
What importers should prepare
- Work via a licensed bank/SGE member for import approvals
- Contract early; quota windows can tighten
- Align documentation (origin, assays) to SGE and customs expectations
How Congo Rare Minerals de-risks your route
Congo Rare Minerals (CRM) is built around documentation and delivery:
- Source-direct from the DRC: We sell direct from licensed operations, not via a chain of brokers keeping provenance clean and margins tight.
- Responsible paperwork: Full chain-of-custody, export permits, invoices, and independent refinery assay on arrival.
- Compliant routing via Uganda: We move shipments through Uganda for export processing, then deliver to mutually approved refineries in Dubai, Switzerland, Europe, China, and the USA for assay-based settlement.
- Strategic backdrop: The DRC is widely cited with ~$24 trillion in untapped mineral wealth and ~90% unexploited a long runway for reliable source partnerships as rules tighten worldwide. (Trade and Economic Security)
Highlighted advantages
- Source direct from the DRC
- OECD-style due diligence and complete paperwork pack
- Assay-on-arrival settlement at approved refineries
- LBMA-linked pricing and contracts that pass audits
Quick checklist by destination
UAE
- OECD-aligned due diligence file ready (MoE DPMS + AML/CFT)
- DMCC responsible-sourcing references if applicable
- Mine origin, export permit, insurance, assay certificates (Ministry of Economy)
United States
- Declare all bullion; confirm HS code and any tariff exposure
- Keep the Africa Gold Advisory in your compliance file
- Sanctions/forced-labor screening memo and counterpart due diligence (CBP Help Center)
European Union
- Implement Reg. 2017/821 due diligence (policy, risk, reporting)
- Prepare to evidence supplier audits and risk mitigation steps (EUR-Lex)
China
- Coordinate with licensed banks/SGE; monitor PBOC quotas
- Ensure documents meet SGE delivery and bonded-zone rules (Reuters)
FAQ
Is the UAE really enforcing OECD-style due diligence now?
Yes. The UAE’s Ministry of Economy published responsible-sourcing regulations and policy guidance for gold/DPMS aligned with OECD measures; DMCC rules also follow the OECD framework. (Ministry of Economy)
Do I pay duty when importing gold bars into the US?
Gold bullion generally enters duty-free, but you must declare it and ensure correct HS classification; recent CBP rulings have raised tariff questions for certain bar categories and origins. (CBP Help Center)
What does the EU require from importers of gold?
Since 2021, EU importers of gold from conflict-affected/high-risk areas must run OECD-style due diligence under Regulation (EU) 2017/821 and prove responsible sourcing. (EUR-Lex)
How controlled are China’s gold imports?
The PBOC manages imports via licensed banks and quotas, with much of the trade clearing on the SGE; quotas can tighten or loosen with policy. (Reuters)
Conclusion & CTA
Regulation isn’t a hurdle; it’s your defense. When your documentation and delivery are airtight, you move faster, pay fewer penalties, and keep optionality across hubs.
Buy gold the clean way at the source, with paperwork that passes.
Contact Congo Rare Minerals to plan your allocation, route selection, and assay-on-arrival settlement to Dubai, Switzerland, Europe, China, or the USA.