Buying gold from Africa: legal routes, sanctions and due diligence

Three things that decide whether a purchase is lawful

Whether a purchase of African gold is lawful is decided in three places: the country the gold comes from, the country it goes to, and the sanctions lists that apply to everyone involved. A gap in any one of them can make the transaction unlawful, whatever the seller's paperwork says.

1. The origin country's legal export channel. Each African country decides who may export gold and on what paperwork, and the rules differ. In Uganda, a person who buys or sells gold, as principal or agent, must be a licensed mineral dealer, and each export consignment needs its own export permit; a dealer's licence alone does not authorise export (see mineral dealer's licence in Uganda). In Ghana, a 2025 law made the Ghana Gold Board the sole exporter of gold from small-scale mining. According to a press report of a Gold Board statement of 14 April 2025, foreigners were told to leave the local gold trading market by 30 April 2025, and a foreigner could instead apply to buy or off-take gold directly from the Board. We have not confirmed whether this is still the position. Channels can change quickly, so confirm the current one with the regulator in the origin country, not with the seller.

2. The rules where the gold goes. Your own country's sanctions, customs and anti-money-laundering law applies to the purchase. Some destinations add supply-chain due-diligence duties; the main ones are summarised below.

3. Sanctions on anyone involved. The United States runs sanctions programmes covering, among others, the Democratic Republic of the Congo, the Central African Republic, Sudan, South Sudan, Mali and Libya. They are mainly directed at listed people and companies, so the seller, its owners, the refinery and any intermediary all need to be screened. Refineries in the Great Lakes region were placed on the US sanctions list in 2022 and in 2026.

What the main destination markets require

These are the rules we could confirm from official texts. They are summaries, not legal advice, and they apply on top of ordinary customs and tax rules.

United States. Imports of gold of Russian Federation origin have been prohibited since 28 June 2022 unless authorised; gold located outside Russia before that date is excluded. Dealers in precious metals that bought and sold more than USD 50,000 of gold in the previous year are typically covered by FinCEN anti-money-laundering programme rules. The 2023 US Africa Gold Advisory urges enhanced due diligence, but it is guidance: it states that it does not have the force of law.

United Kingdom. The import and acquisition of gold exported from Russia on or after 21 July 2022 is prohibited, including gold processed in a third country that incorporates such gold. The EU conflict-minerals regulation applies in the UK only in Northern Ireland. UK government guidance says the statutory duty to follow the OECD due-diligence guidance applies only in Northern Ireland, but that the government expects all companies importing gold into Great Britain to follow it too. Sanctions, anti-money-laundering and customs law apply throughout the UK.

European Union. Importers of 100 kg or more of gold a year must carry out supply-chain due diligence under Regulation (EU) 2017/821: a management system, risk management, a third-party audit and public reporting. Smaller importers fall outside that regulation, but not outside sanctions or anti-money-laundering law. EU sanctions also prohibit buying, importing or transferring gold that originates in Russia and was exported from Russia after 22 July 2022, including gold processed in a third country that incorporates it.

United Arab Emirates. Under Ministerial Decree No. 68 of 2024, gold supply-chain entities and precious-metals dealers must adopt a due-diligence policy and identify, assess and respond to supply-chain risks; refiners must also appoint an independent third-party auditor and report. Expect a UAE counterparty to ask you or your supplier for identity and origin documents.

India. According to a published reproduction of the government notification, gold doré is imported by refineries under an import licence with an actual-user condition. We have not confirmed from an official text whether anyone else may import it, and we do not give India's import duty rate, because the sources we found conflict.

Refiners accredited by the LBMA. The London Bullion Market Association's guidance applies to refiners on its Good Delivery List, not to buyers. But it shapes what those refiners will ask about your gold and its supplier if the gold is ever sold to one of them. Refiners must identify and verify the supplier's name, physical address, company registration and licence information, its owners of 10% or more and its authorised signatories, and confirm that the supplier and its owners are not named on government lists as wanted money launderers, known fraudsters or terrorists. Gold that comes from or through a conflict-affected or high-risk area, or that is claimed to come from a transit country or from a country with “limited known reserves, likely resources or expected production levels”, is treated as high risk and calls for enhanced checks.

What makes a purchase unlawful or unsafe

On the rules above, a purchase can become unlawful, or expose the buyer to enforcement, when, for example:

• the seller, its owners, the refinery or an intermediary is under sanctions;
• the gold is Russian-origin gold covered by the US, UK or EU prohibitions;
• the gold left or entered a country outside the legal channel, for example smuggled or undeclared;
• a business buyer breaches its own anti-money-laundering or due-diligence duties.

UK authorities list incomplete paperwork, cash transactions, gold from or through conflict-affected areas, and gold said to come from countries with limited known reserves or from transit countries as indicators of gold-based sanctions circumvention.

In Uganda, the problem most often recorded in mineral-related police cases is simpler: fraud. Of 135 mineral-related cases investigated by the Police Mineral Protection Unit in 2025, 102 were recorded as obtaining money by false pretence or fraud. The police report does not say how many involved gold or foreign buyers. Ugandan police have also warned that scam offers are priced far below the international market: see the price check in our scams guide. Our guide to Uganda gold scams sets out how those schemes work.

Why gold from Africa gets extra scrutiny

In June 2023 five US government departments and USAID issued an Africa Gold Advisory. It names conflict and terror financing, money laundering, sanctions evasion, human-rights and labour abuses and environmental harm among the risks linked to the gold trade in sub-Saharan Africa, and points to eastern Congo, Sudan, the Central African Republic and Mali. It urges US individuals and companies in the gold sector to apply enhanced due diligence, “as appropriate and necessary”. It is guidance, not law, and it also encourages responsible investment.

Uganda is a particular focus. In their final report of June 2026, United Nations experts on the Democratic Republic of the Congo reported that Uganda recorded gold exports of about 62 tonnes in 2025, valued at USD 6.4 billion, and assessed that the rise was largely attributable to gold originating in the Congo. They found that the declared origins of most of Uganda's 2025 gold exports were not corroborated by available trade data, and said this underscores the need for strengthened due diligence by companies sourcing through Uganda. Under US securities rules, countries that share a border with the Congo, Uganda among them, count as adjoining countries for conflict-minerals reporting; those rules bind companies that report to the US Securities and Exchange Commission, not buyers in general.

In practice, gold offered as Ugandan may have been mined elsewhere, and a refiner or bank may ask for far more evidence of origin than the seller expects to provide.