01 Gold Importation and Exportation
Clodia sources and imports gold into the UAE through a framework built to the standard of the UAE Ministry of Economy's Due Diligence Regulations (Ministerial Decree 68 of 2024) and the OECD five-step Due Diligence Guidance.
Gold is acquired from certified mines through suppliers verified against the group's KYC standard. Origin countries are tiered: Tier 1 for low-risk jurisdictions, Tier 2 for medium risk, Tier 3 for Conflict-Affected and High-Risk Areas. Tier 2 and Tier 3 cargoes require an independent OECD Step-5 assurance report issued within the preceding ninety days. Without it, the consignment does not move.
Pricing follows the London Bullion Market Association benchmark less a fixed discount, calculated on 99.99% fine gold content at the day of the refinery assay. Gold below 99.99% purity is compensated on its actual fine gold content, established by a DMCC Good Delivery accredited refinery in Dubai. Standard consignment size is one hundred kilograms per month over a twelve-month frame, with scope to increase by agreement.
Delivery is in dore bars of ten to 12.5 kilograms, minimum 92% Au, cast at the mine site, vacuum-sealed, and packed into UN-approved tamper-evident bullion boxes. Each bar carries mine code, bar number, gross weight, and cast date. A QR code on each box links to the digital chain-of-custody file.
Counterparties without prior transaction history with the group enter through a trial protocol: less than fifteen kilograms of fine gold, cash and carry, full export documentation, payment in Dubai on confirmed assay. The trial is a compliance and operational test at reduced scale. Passing it opens the standard framework.
The seller opens an account with IFB International Finance Bank, the group's banking channel. The buyer deposits the tranche purchase price into the seller's IFB account, where funds are blocked until the Dubai refinery issues the certified assay. Release is against the certified fine gold content, less the deductions set out in the Sales and Purchase Agreement. Settlement can be in cash in Dubai, in another currency by wire, or transferred to a third-party bank at the seller's written instruction.
Transport from origin airport to Dubai uses Emirates SkyCargo Secure Vault service or equivalent, insured at 110% of LME value through Lloyd's, claims payable in Dubai. Advance Cargo Information filing is made with Dubai Customs twenty-four hours before each flight, in compliance with Customs Notice 7/2023. Clearance is handled by Clodia at Dubai International, and the cargo moves directly to the assigned refinery under armoured escort.
Each shipment travels with the full documentary set: certificate of origin, certificate of ownership, commercial and customs invoices, conflict-free gold declaration, bill of lading, packing list, tax and customs paid receipts, certificate of assay, export permit, airway bill, insurance certificate, authorisation to sell to IFB Holdings LLC as the group's US buyer entity, UAE customs clearance, MoE DNFBP registration, MoEC Responsible-Sourcing Self-Assessment Questionnaire, refinery pro-forma approval, and the ACI filing number. Breach of the sanctions covenant constitutes an event of default.