Tanzania Gold Trading and Export: Licences, Domestic Allocation, BoT Purchases and Compliance
Tanzania gold trading and export is a highly regulated area of Tanzania’s mining sector. Investors, mineral dealers, mining companies and international businesses seeking to buy, trade, process or export gold from Tanzania must comply with a detailed licensing, taxation, domestic allocation and export framework.
Understanding the rules governing Tanzania gold trading and export is essential before entering into any transaction. The legal requirements cover the source of the gold, mineral trading licences, domestic allocation requirements, Bank of Tanzania purchases, royalties, taxation, assay and valuation, export authorisation and customs clearance.
Tanzania has increasingly focused on domestic value addition, gold refining and strengthening its official gold reserves. As a result, businesses entering the Tanzanian gold market must structure their operations around regulatory compliance from the outset rather than treating licensing and export requirements as an afterthought.
This guide explains the key requirements for Tanzania gold trading and export, including who can legally buy gold, which licences are required, how the 20% domestic allocation works, the role of the Bank of Tanzania, and the principal steps involved in exporting gold from Tanzania.
- Tanzania’s Gold Sector: Why the Regulatory Framework Matters
Gold is a strategically important component of Tanzania’s mining economy. The country has a substantial large-scale mining industry alongside a significant artisanal and small-scale mining sector.
The government’s policy direction is increasingly focused on three objectives:
- increasing government revenue from mineral production;
- expanding domestic processing, smelting and refining; and
- retaining a greater portion of the value generated by Tanzania’s mineral resources within the country.
The establishment and expansion of mineral markets, buying centres and domestic gold refineries has been an important part of this strategy. By 2025, the Ministry of Minerals reported that Tanzania had expanded mineral markets and buying centres and had established several gold refineries across different regions.
The Bank of Tanzania has also become an important participant in the domestic gold market. According to its 2024/25 Annual Report, the Bank had purchased approximately 6,190.4 kg of gold through its Gold Purchase Programme by June 2025.
For businesses entering this sector, therefore, the regulatory question is fundamental:
Who may legally buy gold, who may sell it, who may process it, and under what conditions can it leave Tanzania?
The answer depends on the type of licence held and the source and intended destination of the gold.
- The Legal Framework
Gold trading and export in Tanzania are governed by several pieces of legislation and regulatory instruments.
The principal framework includes:
| Legislation / Regulation | Principal relevance |
| Mining Act, Cap. 123 | Principal legislation governing mineral rights, mineral trading, processing, royalties, exports and enforcement. |
| Mining (Mineral Trading) Regulations, 2010 | Provides procedures relating to mineral dealer and broker activities and mineral trading documentation. |
| Mining (Minerals and Mineral Concentrates Trading) Regulations, 2018, as amended | Regulates mineral trading and domestic processing/trading requirements. |
| Finance Act, 2024 | Introduced important amendments concerning domestic allocation, the BoT’s role and royalty treatment for gold supplied to the Bank. |
| Finance Act, 2025 | Further amended the Mining Act, including the mandatory domestic allocation framework and the HIV Response Levy. |
| Mining (Local Content) Regulations | Establishes local content obligations applicable to mining operations and related activities. |
| Natural Wealth and Resources (Permanent Sovereignty) Act, 2017 | Establishes important requirements concerning agreements relating to Tanzania’s natural resources. |
| Anti-Money Laundering legislation | Requires appropriate customer identification, transaction records and controls against money laundering and illicit mineral trading. |
The Finance Act 2024 amended the Mining Act to introduce a requirement for mineral right holders and mineral dealers to set aside minerals for processing, smelting, refining and domestic trading. The initial statutory framework contemplated a percentage to be determined through regulations, with 20% of gold being the prescribed starting point.
The Finance Act 2025 subsequently expanded the statutory framework to address mining companies operating under agreements with the Government and introduced a 0.1% HIV Response Levy on the value of minerals.
The legislation should therefore be read together with the applicable regulations and current administrative requirements rather than relying on an older summary of the Mining Act.
- Mineral Trading Licences: Who Can Buy and Export Gold?
One of the biggest mistakes made by new entrants is assuming that possession of a company registration certificate or a mining-related business licence automatically permits gold trading.
It does not.
A company wishing to participate in mineral trading must hold the appropriate authorisation under the Mining Act.
Primary Mining Licence
A Primary Mining Licence (PML) authorises small-scale mining operations within the licensed area.
A PML holder is a miner—not automatically a general mineral dealer.
The gold produced under the mining licence may enter the formal trading system through the legally recognised mineral markets or other authorised channels.
Foreign participation in small-scale mining is particularly restricted. The Ministry of Minerals has repeatedly emphasised that PMLs are reserved for Tanzanian citizens, subject to the specific statutory framework and permitted technical-assistance arrangements.
A foreign investor should therefore not assume that establishing a Tanzanian company is sufficient to obtain or operate a PML.
Broker Licence
A Broker Licence permits the holder to purchase minerals from authorised sources in accordance with the conditions of the licence and subsequently sell them to licensed dealers.
The broker therefore performs an intermediary function.
A broker is not the same as a dealer.
The broker’s commercial role is generally to facilitate aggregation of minerals from authorised producers and transfer those minerals into the licensed dealer network. The Mining (Mineral Trading) Regulations require brokers to maintain transaction records and operate within the relevant licensed area.
Most importantly:
A broker licence should not be treated as an export licence.
A business intending to export gold must ensure that it holds the authorisation required for export in addition to complying with the applicable export procedures.
Dealer Licence
The Dealer Licence is the principal mineral-trading licence for a business whose model involves purchasing and dealing in minerals on a commercial basis.
A dealer may acquire minerals through legally recognised sources and, subject to the applicable requirements, may dispose of them and apply for the necessary export authorisation.
A dealer must maintain detailed records of mineral transactions. The Mining Act requires dealer licence holders to keep full and accurate records and accounts of their transactions and submit the prescribed information to the Mining Commission.
The exact eligibility, ownership, directorship and control requirements applicable to a particular dealer structure must be checked against the current Mining Act and regulations before incorporation or licensing.
This is particularly important for foreign investors because a foreign-owned company should not assume that ordinary company incorporation automatically makes it eligible for every category of mineral trading licence.
- The Gold Supply Chain: From Mining to Lawful Export
A compliant gold transaction should be capable of being traced from its origin to its final export.
A typical transaction may involve the following stages:
Stage 1 — Lawful mining
Gold must originate from a legally authorised mining operation.
For small-scale production, this may involve a Primary Mining Licence. Larger operations may operate under a Mining Licence or Special Mining Licence, depending on the nature and scale of the project.
The first compliance question for a buyer should therefore be:
Who produced the gold, and under what mining authority?
Stage 2 — Entry into the formal mineral market
Tanzania has established mineral markets and buying centres to formalise mineral trading, particularly for artisanal and small-scale production.
The Ministry of Minerals has reported substantial expansion of these markets and centres in recent years.
The use of authorised trading channels provides a mechanism for recording transactions, assessing applicable government charges and reducing the risk of illicit mineral trading.
Stage 3 — Broker involvement, where applicable
A licensed broker may aggregate gold from authorised producers and sell it onward to a licensed dealer.
The broker should be able to demonstrate:
- its valid licence;
- the source of the gold;
- the applicable buying location;
- transaction documentation;
- quantities and weights;
- payment records; and
- the identity of the parties involved.
Stage 4 — Dealer acquisition
The licensed dealer acquires the gold and becomes responsible for maintaining the necessary transaction records and satisfying the regulatory requirements applicable to subsequent disposal or export.
At this stage, a serious compliance system should include:
- seller verification;
- licence verification;
- KYC documentation;
- source-of-gold records;
- weight and purity records;
- purchase invoices;
- payment evidence;
- royalty documentation; and
- chain-of-custody records.
This is particularly important because gold is a high-value commodity and transactions can present significant money-laundering and illicit-trading risks.
- The 20% Domestic Gold Allocation Requirement
One of the most important recent developments is Tanzania’s domestic allocation requirement.
The Mining Act was amended to require qualifying mineral production intended for export to be partly allocated for domestic processing, refining, smelting and trading.
The policy was introduced to ensure that Tanzania does not simply export its mineral resources without developing domestic value addition and national gold reserves.
The Bank of Tanzania confirms that the 20% allocation applies to mineral rights holders and licensed dealers within the applicable framework.
The practical implication is significant:
An exporter cannot simply purchase 100% of its gold inventory and assume that the entire quantity can immediately be exported.
The required domestic allocation must first be dealt with in accordance with the applicable law and administrative procedure.
The domestic allocation may involve the Bank of Tanzania and authorised domestic processing or refining channels, depending on the applicable transaction and regulatory requirements.
The Bank of Tanzania’s Role
The BoT has a specific role in the domestic gold purchase system.
Its Gold Purchase Programme was established to enable the Bank to purchase gold domestically and increase Tanzania’s monetary gold reserves.
The Bank’s own publications confirm that the programme is connected to the 20% allocation requirement and that the Bank purchases gold at market-related prices.
This is not merely an administrative requirement. It has become an important part of Tanzania’s mineral policy.
- The Bank of Tanzania Gold Purchase Programme
The BoT Gold Purchase Programme was formally introduced in October 2024.
Under the programme, eligible sellers can supply gold to the Bank through the approved domestic arrangements.
The Bank has stated that gold prices are determined by reference to the world market price published by the Mining Commission and that payment is made after the fire-assay results have been confirmed.
The programme also provides significant fiscal incentives.
Key incentives include:
- 4% royalty on gold sold to the Bank;
- 0% inspection fee on gold sold to the Bank;
- zero-rated VAT treatment;
- payment within approximately 24 hours after confirmation of the fire assay, subject to the programme’s conditions; and
- the Bank covering applicable refining costs under the programme framework.
These measures make the BoT route commercially significant in addition to its regulatory importance.
The 20% Requirement Is Not the Same as “20% Must Always Be Sold to BoT”
This distinction is important.
The legal framework establishes the domestic allocation requirement, while the Bank’s programme provides the mechanism through which the Bank purchases gold under its statutory and policy mandate.
Therefore, an investor should not reduce the entire rule to the statement:
“20% of all gold must always be sold directly to BoT.”
The actual transaction should be structured according to the applicable Mining Act provisions, regulations, Mining Commission procedures and current BoT requirements.
For a transaction involving substantial quantities of gold, written confirmation of the applicable allocation and disposal mechanism should be obtained before the transaction is completed.
- Domestic Processing, Smelting and Refining
Tanzania’s mineral policy increasingly favours domestic value addition.
There is an important distinction between:
- mineral processing;
- smelting;
- refining; and
- mineral trading.
They are not interchangeable activities.
Processing
Processing may include activities such as crushing, washing, concentration and other beneficiation processes.
A business undertaking regulated processing activities may require a Processing Licence depending on the precise operation.
Smelting
Smelting involves recovering metal from mineral concentrates through thermal or chemical processes.
A business operating a smelting facility requires the appropriate mining-sector authorisation.
Refining
Refining takes the recovered precious metal to a higher level of purity.
A refinery is therefore a specialised downstream operation subject to its own licensing and technical requirements.
Why the distinction matters
A company holding a Dealer Licence cannot automatically assume that it can establish a refinery or smelting plant.
Likewise:
A refinery licence does not automatically turn the company into a mineral dealer or authorise it to export minerals without satisfying the separate trading and export requirements.
The licensing structure should therefore be designed around the actual business model from the beginning.
- Local Content and Operational Compliance
Mining-sector investors must also consider Tanzania’s local content framework.
For businesses operating in processing, smelting, refining and other mining-related activities, compliance may extend beyond the mineral licence itself.
Depending on the activity, the business may need to address:
- Tanzanian employment and skills development;
- procurement of locally available goods and services;
- local supplier participation;
- training and succession planning;
- local professional services;
- environmental obligations;
- occupational health and safety; and
- reporting obligations imposed by the relevant authorities.
Local content should therefore be treated as an operational requirement rather than something to address after the project has started.
- Exporting Gold from Tanzania: The Compliance Sequence
Once the domestic allocation requirements have been addressed, the exporter can proceed with the remaining export quantity, subject to the applicable regulatory requirements.
A typical export transaction involves several stages.
Step 1 — Confirm the licence position
The exporter should first confirm that it has the appropriate mineral dealer authorisation and that the licence is valid for the relevant mineral.
The company should also ensure that its corporate, tax and regulatory registrations are current.
Step 2 — Verify the source of the gold
Before accepting the gold, the dealer should establish:
- the identity of the seller;
- the seller’s mining or trading licence;
- the source of the gold;
- the quantity;
- the purchase price;
- the applicable government charges;
- payment records; and
- supporting transaction documents.
A dealer should never rely solely on the seller’s verbal representation that the gold is legitimate.
Step 3 — Assay and valuation
Gold intended for export must undergo the required inspection, weighing and valuation procedures.
The applicable government authorities determine the required assay and documentation for the transaction.
The purity and weight of the gold are fundamental because they affect:
- valuation;
- royalty calculations;
- taxes and fees;
- export documentation; and
- the final commercial settlement.
Step 4 — Pay applicable government charges
The exporter must settle the applicable royalties, fees, taxes and other statutory charges.
The precise fiscal treatment depends on:
- the type of gold;
- the source;
- whether the transaction is domestic or export;
- whether the BoT programme applies;
- whether the gold has undergone domestic processing; and
- the taxpayer’s specific circumstances.
This is an area where outdated online articles frequently create problems.
Do not calculate the total cost of a gold export transaction from a generic percentage without checking the current legislation and the specific transaction structure.
Step 5 — Apply for the export authorisation
The dealer must submit the required application and supporting documents to the competent mining authority.
The documentation may include, depending on the transaction:
- valid Dealer Licence;
- assay documentation;
- proof of ownership/source;
- purchase documentation;
- royalty and fee payment evidence;
- tax documentation;
- evidence of compliance with the domestic allocation requirement;
- commercial invoice;
- export documentation; and
- other documents required by the Mining Commission or customs authorities.
The exact documentation should be confirmed for the particular shipment before submission.
Step 6 — Customs clearance
After the mining-sector export requirements have been satisfied, the shipment must undergo customs procedures.
The exporter should coordinate:
- secure transportation;
- customs documentation;
- export declaration;
- security arrangements;
- airport or other approved export-point procedures; and
- destination-country import requirements.
Gold should never be moved through an informal logistics chain simply because it is a high-value commodity.
- Taxes, Royalties and Other Fiscal Obligations
The fiscal treatment of gold transactions is more complicated than a single “gold export tax.”
The applicable charges can depend on the transaction structure.
Principal fiscal considerations include:
| Fiscal item | General position |
| Mineral royalty | Generally applicable to mineral production/supply, with special treatment for certain domestic gold transactions. |
| Royalty on gold sold to BoT | Reduced to 4% under the applicable framework. |
| Inspection fee on gold sold to BoT | Removed under the BoT programme. |
| VAT on gold supplied to BoT | Zero-rated under the applicable framework. |
| HIV Response Levy | 0.1% on the value of minerals under the Finance Act 2025. |
| Corporate income tax | Applies according to the taxpayer’s income-tax position and applicable mining-sector rules. |
| Other fees and charges | May apply depending on the licence, transaction, processing activity and export arrangement. |
The Finance Act 2024 specifically reduced the royalty applicable to gold supplied to the Bank of Tanzania from 6% to 4% and removed the inspection fee on such supplies. It also provided VAT treatment designed to support the domestic gold purchase programme.
The Finance Act 2025 introduced the 0.1% HIV Response Levy on the value of minerals.
Accordingly, the simplistic statement that:
“Gold exports always cost exactly 9–10% of gross value”
should be avoided.
The effective burden depends on the nature of the transaction and the applicable statutory treatment.
- Anti-Money-Laundering and Source-of-Gold Controls
Gold trading presents significant financial-crime risks internationally.
A Tanzanian gold business should therefore implement a robust compliance system covering:
Customer due diligence
Identify the seller, buyer, beneficial owner and relevant counterparties.
Source verification
Establish where the gold was mined and through which licensed channel it entered the transaction.
Transaction records
Maintain accurate records of:
- weight;
- purity;
- purchase price;
- seller;
- buyer;
- licence numbers;
- payment method;
- government charges;
- assay results; and
- export documentation.
Payment transparency
High-value gold transactions should be processed through traceable financial channels and in accordance with applicable Tanzanian financial and foreign-exchange requirements.
Beneficial ownership
The dealer should understand who ultimately owns and controls the companies participating in the transaction.
These controls are not merely administrative. They are part of protecting the business from purchasing stolen, smuggled or illegally mined gold.
- What Happens If You Trade Gold Without the Correct Licence?
The consequences of non-compliance can be severe.
Potential consequences include:
- seizure or forfeiture of minerals;
- cancellation or suspension of licences;
- financial penalties;
- tax assessments and penalties;
- criminal prosecution;
- imprisonment where provided by law;
- loss of eligibility for future licences; and
- reputational damage with banks, refineries, buyers and international counterparties.
The government has demonstrated that illegal gold exports are actively investigated.
For example, in September 2024 authorities announced the seizure of 15.78 kg of gold valued at approximately TZS 3.4 billion at the Port of Dar es Salaam in connection with alleged smuggling.
This illustrates the practical—not merely theoretical—risk associated with attempting to move gold outside the regulated system.
- Common Mistakes Made by New Gold Investors
Mistake 1 — Registering a company and assuming it can trade gold
Company incorporation is not the same thing as obtaining a mineral trading licence.
The corporate structure and mineral licensing structure must be considered separately.
Mistake 2 — Buying directly from anyone claiming to be a miner
A seller’s possession of gold does not prove lawful ownership.
The buyer must verify the source and the relevant licence.
Mistake 3 — Treating a broker licence as an export licence
A broker operates within the mineral trading chain but should not be treated as a substitute for the authorisation required for commercial export.
Mistake 4 — Ignoring the 20% domestic allocation
A business that purchases gold with the intention of exporting all of it can encounter a serious regulatory problem.
The domestic allocation requirement must be incorporated into the commercial model from the beginning.
Mistake 5 — Calculating profitability using only the international gold price
The real calculation must include:
Purchase price + royalty + applicable fees + taxes + assay/refining costs + security + logistics + financing + compliance costs + foreign-exchange considerations.
The international spot price is only one part of the equation.
Mistake 6 — Using outdated tax information
Tanzania’s mining fiscal framework has changed materially since 2024.
Any investment model relying on an old article should be rechecked against the current Finance Acts, Mining Act, regulations and administrative notices.
- Practical Compliance Checklist for a Gold Trading Company
Before commencing commercial gold trading or export, an investor should be able to answer “yes” to the following:
Corporate
- Is the company properly incorporated?
- Are its beneficial owners identified?
- Is the company tax registered?
- Are the relevant corporate filings current?
Mineral licensing
- Does the company hold the appropriate Dealer Licence?
- Is the licence valid for gold?
- Are the licence conditions being observed?
Source of gold
- Is the seller properly licensed?
- Is the mining source verified?
- Is the transaction taking place through an authorised channel?
- Are the purchase documents complete?
Compliance
- Has KYC been completed?
- Has the gold been properly weighed and assayed?
- Have applicable royalties and fees been paid?
- Are all transaction records maintained?
Domestic allocation
- Has the applicable 20% domestic allocation requirement been addressed?
- Has the applicable BoT/refinery/domestic trading process been followed?
Export
- Has the required export authorisation been obtained?
- Are customs documents complete?
- Is secure transportation arranged?
- Does the destination country permit the import of the shipment?
- Are all certificates and supporting documents consistent?
If any of these questions cannot be answered confidently, the transaction should not proceed until the compliance gap has been resolved.
- Key Takeaways for Investors
- Gold trading is a licensed activity
A normal company registration does not give a company the right to buy and export gold.
The appropriate mineral trading licence is essential.
- The source of gold matters
The buyer must establish that the gold originates from a lawful source and has entered the trading chain through the legally recognised channels.
- The 20% domestic allocation is a central feature of the current system
The regulatory framework requires the applicable portion of gold destined for export to be allocated domestically for processing, refining, smelting and/or trading.
The BoT has confirmed that the 20% allocation framework applies to mineral rights holders and licensed dealers.
- BoT has become a major participant in Tanzania’s gold market
The Domestic Gold Purchase Programme is designed to increase Tanzania’s monetary gold reserves while providing eligible sellers with a regulated domestic sales channel.
- The BoT route has specific fiscal advantages
Gold supplied to the Bank receives preferential treatment, including a 4% royalty rate, removal of the inspection fee and zero-rated VAT under the applicable programme.
- Processing and refining require separate regulatory consideration
Trading, processing, smelting and refining are different activities. A business should obtain the licences applicable to the activities it actually intends to conduct.
- Tax calculations must be transaction-specific
Do not rely on a single “total percentage” when calculating the cost of exporting gold from Tanzania.
- Compliance should be designed before the first purchase
The strongest gold businesses build licensing, KYC, source verification, assay, taxation, domestic allocation and export procedures into their business model from the beginning.
Conclusion
Tanzania’s gold sector offers significant commercial opportunities, but it is not a market where an investor can safely operate by simply purchasing gold and arranging international shipment.
The legal structure is designed around a controlled chain:
licensed production → authorised mineral trading → verification and valuation → domestic allocation → applicable processing/refining or BoT purchase → payment of statutory charges → export authorisation → customs clearance → secure international shipment.
The policy direction is equally clear: Tanzania wants a larger share of the economic value generated by its gold to remain within the country, while simultaneously building domestic refining capacity and increasing the Bank of Tanzania’s monetary gold reserves.
For investors, the lesson is straightforward:
Do not build the business model first and ask about licensing later. Build the business model around the licensing and compliance requirements from the beginning.
A properly structured gold trading or export business can operate within Tanzania’s regulatory framework. A business that treats licensing, source verification, domestic allocation or taxation as afterthoughts can face substantial financial, regulatory and criminal exposure.
Important: Gold trading and export requirements can change through amendments to the Mining Act, Finance Acts, regulations, Mining Commission procedures and Bank of Tanzania directives. Before entering into a transaction or relying on this article for an investment decision, the current requirements should be confirmed with the relevant Tanzanian authorities and qualified local advisers.
GERPAT Solutions assists investors with Tanzania business formation, mineral-sector regulatory coordination, licensing, corporate compliance and related investment structuring.
-
Website:www.gerpatsolutions.co.tz
-
Email: info@gerpatsolutions.co.tz
Legal Disclaimer: This article is published for general educational and informational purposes only and does not constitute formal legal advice. Readers should consult a qualified legal practitioner in Tanzania before undertaking specific commercial or investment activities.