Gold · UAE · Saudi Arabia · Egypt · Gulf buyers
Brazilian gold for Dubai and the Gulf: what UAE responsible-sourcing rules mean for buyers
For a buyer in Dubai, Riyadh or Cairo, Brazilian gold has an obvious appeal: a large producing country, a deep refining industry and São Paulo's financial infrastructure. It also carries a reputation problem, because the Amazon's illegal garimpo has made Brazilian origin a red flag in many compliance manuals. The buyers who succeed separate the two. This guide shows how, against the UAE's own rules.
Key takeaways
- The UAE imported about 8% of the value of Brazil's gold exports in 2020, according to importing-country data, and Dubai is a common settlement and refining hub for buyers across the region.
- Since the audit period starting 1 January 2023, UAE gold refiners and dealers must apply an OECD-based responsible-sourcing policy issued by the Ministry of Economy, with independent audits and annual reports.
- A UAE refiner will expect the same evidence Brazil now requires at home: invoice, mine of origin, formal holder and a clean chain of custody.
- Brazil's Supreme Court removed the buyer's presumption of good faith in March 2025, so origin evidence is no longer optional on either side.
- We offer lots of up to 1,000 kg of refinery bars in São Paulo, with invoice and documented origin, against spot payment at delivery through banks.
In this article
Trade data from importing countries show that, in 2020, the United Arab Emirates received about 8% of the value of Brazil's gold exports, behind Canada, Switzerland and the United Kingdom. Those figures understate the region's role, because gold often moves through intermediaries and re-exports, and Dubai is one of the main crossroads of that trade.
Gulf capital is also looking at Brazilian minerals more broadly. In 2023, Saudi Arabia's Manara agreed to buy 10% of the base-metals business of Vale, Brazil's largest miner. Interest in physical gold is the shorter-term expression of the same idea: Brazil as a supplier of metal to the Gulf.
This guide focuses on the Gulf. The Brazilian rules and the general procedure are covered in our compliance guide to buying physical gold from Brazil.
§ 01 · The hub
Why Brazilian gold and Dubai fit together
Dubai combines refining capacity, vaulting, trading houses and banks that know precious metals, all within a few hours' flight of most of the region. For a Brazilian seller, it is a single destination that reaches buyers in the Gulf, North Africa and South Asia. For a regional buyer, it is a place to receive, assay, refine and settle under a familiar framework.
UAE refiners and dealers
Receive Brazilian refinery bars or doré, re-refine if needed and sell to regional markets.
Saudi and Gulf investors
Buy for reserves, fabrication or trading, often through Dubai counterparties.
Egyptian and North African groups
Frequently act as mandated intermediaries or end buyers working with Gulf partners.
Brazilian holders
Authorised institutions and formal companies with invoiced, documented gold.
The weak link has always been the paperwork in between. Gold that left the Amazon informally and reached a Gulf refiner through several hands has been the subject of investigations and media reports in recent years. That history is why the UAE tightened its rules and why serious buyers now ask Brazilian sellers for the full chain from mine to vault.
Doré and refined bars in the Gulf trade
Much of the gold that reaches the Gulf from producing countries arrives as doré for refining. Our São Paulo lots are different: they are already refined bars with serial numbers and assay certificates. For a Gulf buyer, that shortens the chain, because the main remaining questions are origin, documentation and whether the bars meet the buyer's delivery standard or need re-refining.
§ 02 · The rules
The UAE's responsible-sourcing policy in brief
The UAE Ministry of Economy published regulations for the responsible sourcing of gold as part of its anti-money-laundering and counter-terrorist-financing framework, with controlled companies applying them from an audit period beginning 1 January 2023. The policy is based on the OECD Due Diligence Guidance.
| Element | What it requires |
|---|---|
| Scope | Dealers in precious metals and stones (gold), gold refiners and companies in their supply chains; accredited members under the UAE Good Delivery Standard |
| Governance | A compliance officer reporting to the chief executive with access to the board; staff training; due diligence before new supplier relationships |
| Risk assessment | Supply-chain due diligence, identification of high-risk indicators and continuous monitoring |
| Risk management | A strategy and monitoring plan to respond to identified risks |
| Audit | Independent third-party review under an annual audit plan |
| Reporting | Annual supply-chain due diligence reports to the Ministry of Economy |
For the buyer, this is good news. The documents a UAE refiner will ask for are the same ones that protect the buyer against fraud. A seller who can satisfy a refiner's compliance desk can usually satisfy yours.
The policy also explains why Gulf counterparties increasingly avoid long chains of brokers. Every additional, undocumented hand between the mine and the refinery is a gap in the audit trail. Expect a serious UAE buyer to want direct contact with the holder of the gold for compliance purposes, even when an intermediary introduced the deal and is protected by a commission agreement.
§ 03 · The checklist
What a Gulf refiner will ask about Brazilian gold
Typical supplier due diligence for Brazilian gold
- Seller identity: registration, tax number (CNPJ), directors and ultimate beneficial owners
- Licence to trade: Central Bank authorisation if the seller is a financial institution, or the company's corporate purpose and tax standing
- Origin: mine or mining titles of origin, with ANM process numbers, location and holder
- Exclusion of high-risk areas: evidence that the origin is not inside indigenous lands or protected areas
- Invoices: Brazilian electronic gold invoice and the chain of invoices from mine to current holder
- Product data: refiner, fineness, weight and serial numbers, with assay certificates
- Export documents: Brazilian export registration and customs clearance
Brazil's own rules now push in the same direction. Since 3 July 2023, gold treated as a financial asset must travel with an electronic invoice, and since the Supreme Court decision of 24 March 2025 Brazilian buyers can no longer rely on a presumption of good faith. In practice, the documentation a compliant Brazilian seller keeps for Brazilian regulators is the same documentation a Gulf refiner wants to see.
§ 04 · The offer
Our São Paulo lots, mapped to UAE expectations
BRAZIL MINE represents lots of up to 1,000 kg of gold in refinery bars, available for delivery in São Paulo. The table shows how each lot's documentation answers what a Gulf refiner or dealer is required to check.
| Due diligence item | What we provide |
|---|---|
| Supplier identity | Formal Brazilian holder: Central Bank-authorised institution or incorporated company with CNPJ |
| Origin | Mine of origin documented, with the mining title identified |
| Tax trail | Brazilian electronic invoice |
| Product | Refinery bars with serial numbers and assay certificates |
| Verification | Physical inspection and independent assay in São Paulo before payment |
| Payment | Spot, against delivery, through banking channels only |
Whether a given lot meets a specific delivery standard, such as UAE Good Delivery or LBMA Good Delivery, depends on the refiner that produced it. Tell us your requirement at the start and we will confirm it with the documents, or price re-refining.
§ 05 · The deal chain
Working with intermediaries from Egypt, Saudi Arabia and the region
Many gold transactions between Brazil and the Gulf start with an intermediary: a broker in Cairo with a buyer mandate, a trading contact in Riyadh, a consultant in Dubai. Intermediaries are legitimate and often essential. What separates a productive chain from a futile one is documentation.
- 01
Show the mandate
Every intermediary should hold a written mandate from the party it represents: the buyer on one side, the holder on the other.
- 02
Sign the commission agreement first
Before buyer and seller are introduced, all parties sign an agreement setting out each group's commission in writing. This protects whoever brought the deal.
- 03
Move to direct contact for compliance
KYC, inspection and payment happen between the principals and their banks, not through the chain.
- 04
Keep commission out of the gold price
Commissions are paid under the signed agreement, not by inflating or discounting the metal.
§ 06 · The route
From São Paulo to Dubai: logistics, insurance and timing
Gold moves from São Paulo to the Gulf by secure air freight, handled by specialist valuables carriers that manage collection from the vault, export clearance, the flight, insurance and delivery to the receiving vault or refiner.
| Leg | Typically handled by |
|---|---|
| Collection at the São Paulo vault | Valuables carrier, with seller and buyer representatives |
| Brazilian export clearance | Exporter and its customs broker |
| Air freight and insurance | Valuables carrier and its underwriters |
| UAE import and delivery | Buyer or its refiner, with the carrier |
| Receiving assay | Receiving refiner or vault |
Buyers can take delivery in São Paulo and appoint their own carrier, or agree delivered terms. Either way, decide it in the letter of intent and price it in from the start. The receiving refiner's assay should be compared against the São Paulo assay and the agreed tolerance written into the contract.
Each container should be sealed in São Paulo in the presence of both parties' representatives, with seal numbers recorded on the shipping documents and checked again on arrival in the Gulf. Any discrepancy in seals, weights or serial numbers should stop the delivery until it is explained.
§ 07 · The method
The procedure, start to finish
- 01
KYC on both sides
Corporate documents, beneficial owners and licences.
- 02
NDA and commission agreement
Signed by all parties before introductions.
- 03
Letter of intent
Volume, payment, delivery point, delivery standard and timetable.
- 04
Documentation review
Invoice, origin, holder and assay certificates, checked by the buyer's compliance team.
- 05
Inspection and assay in São Paulo
By a laboratory or refiner chosen by the buyer.
- 06
Contract
Price, fineness adjustments, delivery terms, liabilities and governing law.
- 07
Spot payment against delivery
Through banks, using escrow or delivery-versus-payment.
Most of the time in a Gulf transaction goes into compliance review. When the buyer's team receives the complete origin file at the start, review and commercial negotiation run in parallel. That is why we share the documents after KYC and the NDA, before any price commitment.
The Gulf does not lack gold. It lacks gold with a story it can audit. That is what we sell.
Itanay Sabino, BRAZIL MINE
Buying gold for Dubai, Saudi Arabia or Egypt?
Lots of up to 1,000 kg in São Paulo, refinery bars with invoice and documented origin, spot payment against delivery through banks. Tell us who is buying and how much.
Request terms§ FAQ
Frequently asked questions
Can Brazilian gold be imported into the UAE?
Yes. Brazil has been a regular source of gold for the UAE. The receiving refiner or dealer must apply the UAE responsible-sourcing policy, so documented origin, invoices and a formal seller are essential.
What does the UAE responsible-sourcing policy require?
An OECD-based due diligence system: a compliance officer, supplier due diligence, risk assessment and management, independent third-party audits and annual reports to the Ministry of Economy, applied from an audit period beginning 1 January 2023.
Is Brazilian gold considered high risk?
Gold from informal Amazon garimpos is. Gold from a licensed mine with an identified title, invoiced and held by a formal company or authorised institution can pass refiner due diligence, provided the documents are complete.
How much gold does BRAZIL MINE offer for the Gulf?
Lots of up to 1,000 kg per transaction, in refinery bars, for delivery in São Paulo, with invoice and documented origin. Availability is confirmed per transaction after KYC.
Are the bars UAE or LBMA Good Delivery?
That depends on the refiner of each lot and is confirmed with the documentation. If your refinery requires a specific standard, tell us at the start.
How is payment made?
Spot, against delivery, always through banking channels, using escrow or delivery-versus-payment. No physical cash and no advance fees.
I am an intermediary in Egypt. Can I work with you?
Yes, with a written mandate from your buyer. All parties sign a commission agreement before buyer and seller are introduced, so each group's commission is set out in writing.
Can the gold be delivered in Dubai?
Delivery is in São Paulo. The buyer can appoint its own valuables carrier to Dubai, or delivered terms can be negotiated in the letter of intent.
Why does Dubai matter for Brazilian gold?
Dubai combines refining, vaulting, trading and banking for precious metals and is a common settlement hub for buyers across the Gulf, North Africa and South Asia. The UAE took about 8% of the value of Brazil's gold exports in 2020, according to importing-country data.
Mathematician, Land Surveyor and Licensed Real Estate Broker · CRECI-TO 4631
BRAZIL MINE — Mining & Minerals
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