Inside the US, the physical gold market is mature and largely self-contained. Asahi Refining produces LBMA Good Delivery bars from its Salt Lake City facility, and A-Mark Precious Metals moves them through the wholesale book downstream. COMEX sits over both as the reference-price venue and the physical settlement layer, with its eligible-vault network anchored in named bank and security-logistics vaults in New York and Wilmington. Where the metal ultimately settles — Delaware Depository, the Texas Bullion Depository, or the New York Fed vault — depends on what the holder legally is. For most US allocations this stack is sufficient.
For a subset of qualified US buyers the question runs differently: allocated refinery-origin metal held in a Brink’s vault under a non-US legal regime, with onward dispatch from Hong Kong on exit. That subset runs the Hong Kong corridor alongside the onshore stack. A US qualified buyer typically holds positions in both.
1. The US physical gold market: refining, wholesale, market structure, custody
Compared to the Swiss or German footprint, the US bullion stack is structurally compact: one principal active LBMA-accredited gold refiner, a dominant publicly listed wholesaler, a single futures venue doubling as the physical settlement layer, and a depository landscape divided by what the holder legally is. Asahi’s bars clear through A-Mark’s wholesale book and settle on COMEX warrants; the warrants point to specific bars in a small set of named bank and security-logistics vaults whose accessibility depends on which legal regime the buyer operates under.
1.1 Asahi Refining: the US LBMA-accredited refining footprint
As the operational successor to Johnson Matthey’s US precious metals refining business — acquired by Asahi Holdings (Japan) in 2015 — Asahi Refining’s Salt Lake City facility holds the principal active US-domiciled position on the LBMA Good Delivery List for gold, and is the only US name on that list whose bars sit in regular COMEX delivery rotation. Metalor Technologies USA — the other historically significant US-domiciled name in the same bracket — has moved away from primary gold refining at its North Attleborough operation, leaving Asahi without an onshore peer at LBMA Good Delivery scale.
Two consequences follow. US-origin 400 oz Good Delivery supply runs thin relative to demand: institutional buyers reaching for large-format LGD typically source loco London or loco Zurich, since the bars themselves are largely produced abroad. COMEX physical delivery routes through a closed list of approved brands — Asahi Refining sits on that list alongside Argor-Heraeus, Heraeus, Valcambi, PAMP, the Royal Canadian Mint and a handful of others. Under its accreditation Asahi produces the 100 oz COMEX-deliverable format, which is why a US buyer taking physical from a COMEX warrant overwhelmingly receives one of those approved brands in 100 oz form, with Asahi the only one refined onshore.
1.2 A-Mark Precious Metals: the wholesale and dealer layer
Between refiner-direct and end-buyer, A-Mark Precious Metals (NASDAQ: AMRK) handles most US institutional and HNI physical-bullion flow. The wholesale book runs under A-Mark Trading; Collateral Finance Corporation extends secured lending against bullion, AM Capital Funding handles logistics, and the direct-to-consumer brands — JM Bullion, Silver Gold Bull, Provident Metals, BGASC, Goldline, Pinehurst Coin Exchange — sit on the same wholesale book under separate retail-facing identities, with Stack’s Bowers covering numismatics. As one of the small number of Authorized Purchasers of US Mint bullion coins, A-Mark also holds primary-distribution access for American Gold Eagles and Buffaloes that retail dealers do not have.
In practice, a domestic US purchase of kilobars or 100 oz bars from a non-bank counterparty is most likely facing A-Mark Trading directly, or a smaller dealer — Dillon Gage, MTB, Kitco USA — that itself clears wholesale through one of a handful of upstream names. The bullion banks (JPMorgan, HSBC, ICBC Standard, StoneX) sit on the other side of the same market; their physical-bullion books open to clearing-tier counterparties only, with direct corporate and family-office buyers handled downstream.
1.3 COMEX: price discovery and the physical settlement layer
COMEX is the CME Group division that runs the US gold futures market, with the GC contract set at 100 troy ounces. Its bridge to physical metal — and what separates the venue from a pure derivatives market — is the eligible-vault and warrant system that pins futures positions to specific bars in named depositories.
Two inventory categories run the system. Eligible metal sits in an approved vault and meets delivery specifications — approved brand, correct weight band, valid assay — without being warranted against a specific futures contract; the owner can warrant it at will. Warrant status defines the second category: registered metal carries a CME-issued electronic warrant pointing to that specific bar, and the warrant transfers on delivery against an expiring future. CME publishes the eligible-versus-registered split daily in its stock reports, where the market reads it as a signal of physical tightness relative to open interest.
For COMEX gold, the eligible-vault network runs through HSBC Bank USA (New York), JPMorgan Chase Bank (New York), Brink’s New York, Manfra Tordella & Brookes, Malca-Amit USA, and Loomis International’s Wilmington Delaware vault. Between COMEX and the LBMA spot market the arbitrage line clears through the Exchange for Physical (EFP) market, which prices loco New York against loco London and is where the basis between the two venues sits in continuous bullion-bank-desk pricing.
Standing for delivery on COMEX does not produce a truck of bars arriving at the buyer’s address. The buyer receives title to one or more warrants; the metal stays in the vault under the new owner’s name; physical withdrawal — vaulting out, transport, customs if international — is a separate workflow with its own carrier authorisation, insurance, and Incoterms layer. Most institutional COMEX deliveries stay vaulted under new title.
1.4 US depositories: COMEX-network vaults, Delaware Depository, Texas Bullion Depository, the NY Fed
Legal layer is the variable that sorts the US depository landscape. Holder status determines which depository is in play before geography or operator preference enters.
| Depository | Operator | Primary holder type |
|---|---|---|
| HSBC NY, JPMorgan Chase NY, Brink’s NY, MTB, Malca-Amit USA, Loomis Wilmington | Banks and security-logistics firms | COMEX eligible / registered metal |
| Delaware Depository (Wilmington, DE) | Private | IRA-eligible bullion; allocated and segregated commercial custody |
| Brink’s Salt Lake City; IDS of Delaware; CNT (Massachusetts) | Private | IRA custody and dealer-account custody |
| Texas Bullion Depository (Leander, TX) | State of Texas, operated by Lone Star Tangible Assets | State-jurisdiction custody under TX statutory framework |
| Federal Reserve Bank of New York vault | US Federal Reserve | Foreign central banks and the BIS — not commercial |
| Fort Knox, West Point, Denver Mint | US Treasury | US sovereign reserve — not commercial |
At 33 Liberty Street, the Federal Reserve Bank of New York vault holds gold for foreign central banks and the BIS under a custody-only arrangement; private holders have no access. The US sovereign stock sits at Fort Knox, West Point and the Denver Mint under Treasury custody. Both stand outside the commercial pathway, yet any honest map of where institutional-grade gold is physically held inside the US has to acknowledge them alongside the private depositories.
Opened in 2018 under Texas HB 483 (2015), the Texas Bullion Depository is administered by the Texas Comptroller and operated by Lone Star Tangible Assets. Volume has remained modest against established private depositories, and the depository stands as a deliberate jurisdictional choice — Texas statutory custody over private-contract custody — for buyers who specifically value that distinction.
Routing follows the holder. A buyer whose position is anchored to futures-physical plumbing finds the metal at one of the COMEX-network vaults; a buyer inside the IRA legal layer or a private allocated-storage contract finds it at Delaware Depository, Brink’s Salt Lake City, IDS or CNT. The depository is selected by what the buyer legally is at the moment of allocation; brand or geography enters only after.
2. Where the onshore route stops short for some US buyers
The US stack solves most allocations. A fraction of qualified buyers reaches offshore for structural reasons the onshore stack leaves unaddressed.
At the foundation sits legal-regime concentration. Whether COMEX-vaulted or sitting at Delaware Depository, a US-domiciled allocation exists under one body of bullion law, one tax regime, one sanctions authority, and one set of historical precedents. For a buyer whose other assets are already concentrated in that regime, additional gold inside it does not diversify what the gold is meant to diversify; US-only physical produces a US-only counterparty in a US-only legal forum on any exit or claim.
Layered on top is allocation depth. Most US bullion volume — including most “physical” IRA holdings — comes in segregated form or in pooled accounts at A-Mark and downstream dealers; the step up to full allocation requires a contract that names specific bars by refiner, weight, serial, and assay. That contract exists inside the US, yet the channel for it is narrower than the headline depth of the market suggests, and rarely the default offered to a buyer who has not asked for it explicitly.
Exit liquidity outside the US legal regime adds the further pressure. An offshore vault sits in a buyback market that prices off the local fix and the loco-Zurich or loco-Hong-Kong premium, independent of US dealer spreads and US settlement mechanics. For a buyer who anticipates an exit in a non-US currency, against a non-US obligation, or through a non-US counterparty — a relocation, a family-office consolidation, a treasury rebalance with a non-USD partner — the round-trip through the domestic market is a structural inefficiency the corridor removes.
For a buyer carrying concentrated US legal exposure, needing fully allocated metal at scale, or anticipating a non-US exit, the corridor functions as the operational extension that closes those specific gaps. It runs alongside the domestic stack the same buyer already uses.
3. The Hong Kong allocation corridor
Read end-to-end, the corridor moves through three operational layers a US buyer needs to keep separate: contracting (where the buyer signs and to whom), custody (where the metal physically sits), and dispatch (where it leaves from on exit or delivery). Contracting sits in Oman; custody can sit anywhere across the Brink’s network; Hong Kong anchors dispatch. Treating those three as a single jurisdiction is the most common source of misunderstanding about how the corridor works.
3.1 Why Hong Kong as the dispatch jurisdiction
Hong Kong’s pull as the corridor anchor combines several distinct features. The investment-gold regime carries no GST or VAT, and the free-port treatment of bullion removes the friction that would otherwise sit on every leg in and out. Layered onto that, vault infrastructure runs through the same carriers used elsewhere in the Brink’s network. The Chinese Gold and Silver Exchange Society, chartered in 1910, runs as a long-established market venue with active loco-Hong-Kong physical pricing. And the HKIA Precious Metals Depository provides gold-cargo direct airside handling that few other jurisdictions match. Market-structure detail — CGSE, Brink’s HK, Malca-Amit HK, HKIA Depository — sits under Hong Kong gold market structure.
For US-bound dispatch specifically, two adjacent features add weight. Cathay Pacific, FedEx and UPS air-freight networks give HKG direct cargo capacity to US gateways at densities that exceed the corresponding Asian peers. Investment gold sits outside HK export-control screening, so from vault release to aircraft departure the carrier’s own documentation is the only file the bars leave under. The shipment record reflects that: one carrier file from HK warehouse to US customs entry.
3.2 Storage flexibility across the Brink’s network
Allocated bars sit wherever the buyer holds them — Hong Kong is one option among several. Brink’s, under Golden Ark’s custody contract, operates allocated vault capacity across Switzerland (Zurich, Geneva), Singapore, Dubai, London, Liechtenstein, and Hong Kong itself, and the holding jurisdiction is chosen at contracting. That choice turns on the buyer’s own analysis of which legal regime they want the metal sitting under. Storage mechanics — segregated allocated, audit cadence, insured cover, reporting — are documented under allocated storage through Brink’s.
On exit, Hong Kong becomes the active jurisdiction. Physical dispatch routes the bars into Brink’s Hong Kong ahead of the air-freight leg and clears from there. On the buyback route the sale prices off loco-Hong-Kong; the bars release from holding to the Hong Kong settlement counterparty, and the cash settles against the documented chain of custody back to original allocation. Between holding jurisdiction and dispatch, the transfer runs as an internal Brink’s-network movement under a single custody contract — the release path completes inside the existing storage file.
3.3 Operational sequence: contracting, KYC, allocation, custody, delivery or buyback
The sequence is linear, and the artefacts at each step are the documentation the buyer should expect.
- Contracting. The buyer signs with Golden Ark General Trading (FZC) LLC, the Sohar Free Zone entity (CR 1603777). Format is specified in the counterparty contract (1 kg, 100 oz, 400 oz LGD), along with refiner constraint — Heraeus, Argor-Heraeus, or open to the LBMA Good Delivery List — and the chosen holding jurisdiction inside the Brink’s network.
- KYC and onboarding. Standard AML/KYC, OFAC and broader sanctions screening through Refinitiv World-Check, source-of-funds review. The intake adds FATCA self-certification and the W-9 / W-8 set for US persons.
- Quote and price lock. Pricing references either the LBMA AM/PM fix or a real-time spot the buyer specifies, with the refiner premium added on for the chosen format. The lock window and settlement currency are agreed in writing.
- Payment. SWIFT settlement to GA’s banking on the schedule in the contract. Confirmation of receipt triggers allocation.
- Allocation. Specific bars — by refiner, weight, serial number and assay — are assigned to the buyer’s holding and removed from the unallocated pool. The allocation record returns to the buyer with the bar list, refiner marks, weight to 0.001 oz, and the vault confirmation from Brink’s at the chosen jurisdiction.
- Custody. Bars sit segregated and allocated under the buyer’s name in the chosen Brink’s vault. Storage statements, audit reports and insurance certificates issue on the cadence written into the storage contract.
- Exit. Three routes are open at any point. The buyer can hold indefinitely; take physical delivery through the documented international delivery of allocated gold bars workflow; or sell back through the Hong-Kong-anchored buyback channel, which prices off loco-Hong-Kong and settles against the documented allocation chain.
At every step the file gains an artefact: the contract, the KYC record, the payment confirmation, the allocation record with bar serials, the vault placement confirmation, and on exit either the delivery documentation or the buyback settlement statement. That accumulating file is the buyer’s evidence set and the audit trail behind it.
3.4 The carrier layer: Brink’s, Malca-Amit, Ferrari Group, Loomis International
Movement of bullion on commercial freight requires an authorised secure-logistics carrier, and the institutional-grade list is short. Brink’s, Malca-Amit, Ferrari Group, and Loomis International cover that category across COMEX eligible vaults, LBMA loco-London settlement, and the major Asian and Middle Eastern vault networks. Inside the GA corridor, Brink’s holds the custody contract and runs as principal carrier end-to-end; the others appear on specific legs where routing or contingency requires.
Two artefacts make a delivery happen, and the buyer signs both.
Release instruction. A bank-grade signed instruction from the holder of allocated metal to the vault operator, naming specific bars by serial, the receiving carrier, and the consignment destination. Vault release runs against that instruction — a portal click or phone call alone will not move the bars from allocated status into in-transit status.
Carrier authorisation. Released bars require a matched signed schedule naming the natural persons authorised to take physical custody at the destination address. The carrier delivers against name and identity; no match, no release. For US-bound shipments to a corporate or family-office address, the authorisation typically names a primary and an alternate signatory.
US-bound bullion most commonly moves under DAP (Delivered At Place — carrier delivers to the named US address, buyer handles import clearance) or DDP (Delivered Duty Paid — carrier handles clearance and any applicable duties). Investment-grade gold enters the US duty-free under HTS chapter 7108 (non-monetary bullion gold), and the customs entry itself still has to be filed; DAP versus DDP decides which side files it. Release instruction, carrier authorisation, Incoterms responsibility and customs entry resolve together into the shipment record, with the bar list and serials tied back to the original allocation.
4. US-person operational layer
For a US person, corridor mechanics are identical to those any non-US buyer goes through. The variation sits in the documentary and reporting layer wrapped around them. Golden Ark’s intake adds a small set of US-specific items at onboarding — an administrative overlay. The reporting layer is something different: an ongoing obligation under US law that the buyer carries separately from anything Golden Ark provides or files. And the IRA route exists as a structurally different product solving a different problem; it is worth keeping in view as a comparison.
4.1 KYC, sanctions overlay, source of funds for US persons
Across every counterparty, Golden Ark’s baseline onboarding runs the same set — AML/KYC, OFAC and broader sanctions screening through Refinitiv World-Check, documented source of funds. For US persons, three administrative items attach to that intake.
FATCA self-certification. A signed declaration of US-person status (US citizen, US resident for tax purposes, or US-organised entity) and the accompanying W-9 — or, for non-US entities with US beneficial owners, the relevant W-8 series form. Golden Ark is not a US financial institution and does not file 1099s; the form sits in the counterparty file and is produced if and when a reporting obligation arises on the buyer’s side.
OFAC overlay. Because OFAC sanctions reach US persons extraterritorially, Golden Ark’s standing OFAC screen against the SDN list and sectoral programs applies to the US-person counterparty itself, and to every transfer agent, signatory and beneficial owner named in the file. The screen is the same one run on every counterparty, tightened for the additional surface that US-person status exposes.
Source of funds documentation. Standard across the book — bank statements, sale or distribution documents, audited financials for entity buyers. The expectation for US persons leans toward documentation that aligns with US tax filings (most commonly recent 1040 or entity 1120/1065 schedules where the funds traceably originate in declared income or proceeds). Depth of the request scales with the size and structure of the transaction.
Across all three items, the contracting counterparty remains Golden Ark General Trading (FZC) LLC in Sohar Free Zone, the custody contract remains with Brink’s, and the bars remain refinery-origin Heraeus or Argor-Heraeus. US-person status adds three artefacts to the counterparty file — the FATCA cert with W-9 or W-8, the OFAC screen result, and the source-of-funds documentation set — and those artefacts sit alongside the contract, the allocation record and the vault confirmation in the same transaction file.
4.2 Reporting regimes US persons should review with their tax counsel
The following is reference material — a neutral description of the US reporting regimes that touch offshore allocated gold. None of it is tax or legal advice. The applicability of each regime to a specific holding depends on facts that only the holder and their qualified US tax counsel can determine; the thresholds, forms and treatments cited are subject to change and should be verified at the point of filing.
| Regime | What it is | Where it sits in US law |
|---|---|---|
| FBAR — FinCEN Form 114 | Annual report of foreign financial accounts. Allocated physical gold held directly in a foreign vault, without a financial-institution intermediary, is generally regarded as falling outside the FBAR financial-account definition; a foreign brokerage or pooled-account holding may fall inside it. The distinction turns on the legal form of the holding. | Bank Secrecy Act, administered by FinCEN |
| FATCA — IRS Form 8938 | Statement of Specified Foreign Financial Assets. Reporting thresholds vary by filing status and US-vs-non-US residence. Treatment of directly held physical gold parallels the FBAR analysis; held through a foreign financial institution it generally reports, held as direct allocated bullion it generally does not. | Foreign Account Tax Compliance Act, IRC §6038D |
| IRS collectibles capital gains rate | Long-term capital gains on physical gold held as a personal investment are taxed at the collectibles rate — currently a maximum 28% federal rate — rather than the preferential LTCG rates applied to most other long-term assets. Entity holders and certain structures fall under different rules. | IRC §408(m), §1(h)(4) |
| 1099-B on sale | A broker that effects the sale of bullion meeting specific format and quantity thresholds files a 1099-B reporting the proceeds. Whether 1099-B issues on a given sale depends on the form of the transaction and the legal status of the counterparty effecting it; a foreign non-broker buyback does not generate a US-filed 1099-B, which does not affect the underlying gain’s US taxability. | IRC §6045, Treas. Reg. §1.6045-1 |
| Estate and gift tax | Physical gold held by a US person enters the gross estate at fair market value at date of death. Foreign situs does not remove it from US estate tax for a US-citizen or US-domiciled decedent. | IRC §2031, §2103 |
A qualified US tax counsel — and, for substantial holdings, a tax attorney with cross-border experience — is the appropriate party to determine which of these regimes apply to a specific holding, in what amount, and with what filing cadence.
4.3 IRA-eligible bullion as a separate vehicle
Inside a typical US buyer’s portfolio, IRA-held bullion and direct offshore allocation cover different needs; holding both at once is the common operational pattern.
Inside the IRA layer, the structure is a self-directed individual retirement account that holds bullion meeting IRC §408(m)(3) fineness rules — 0.995 fine for gold bars, plus an enumerated list of qualifying coins. Custody runs through an IRS-approved non-bank trustee under §408(n) or an approved bank; in practice that means an IRA custodian (Equity Trust, STRATA Trust, Kingdom Trust, Madison Trust and a small number of peers) directing storage to an IRS-recognised depository — most commonly Delaware Depository, Brink’s Salt Lake City, IDS of Delaware, or CNT in Massachusetts. Personal possession by the account holder triggers a distribution event with the associated tax and, where applicable, penalty consequences. The wrapper is purpose-built for tax-deferred retirement holdings inside the US legal regime.
Six structural dimensions separate the IRA wrapper from a direct offshore allocation.
| Dimension | IRA-held bullion | Direct offshore allocated |
|---|---|---|
| Legal layer | US IRC §408 retirement-account framework | Direct legal title in the buyer’s name (or named entity) |
| Custody | IRS-approved US depository, custodian-directed | Brink’s vault in chosen jurisdiction, buyer-contracted |
| Possession | Prohibited during the holding period | Available at any time via documented delivery workflow |
| Tax treatment in the wrapper | Tax-deferred (Traditional) or tax-free (Roth) within IRA rules | Subject to the regimes in 4.2 |
| Permitted formats | IRC §408(m)(3) — 0.995 gold bars, enumerated coins | Any LBMA Good Delivery bar, refiner of choice |
| Withdrawal mechanics | Distribution rules, RMDs, early-withdrawal penalties | None — sale or delivery on the buyer’s timing |
Use case decides which wrapper is in scope. The IRA wrapper carries US-framework retirement saving with its tax deferral, custodian-directed storage and possession restriction. Direct offshore allocation carries direct legal title in the buyer’s name (or named entity), a chosen vault jurisdiction inside the Brink’s network, and exit timing on either the delivery or the buyback workflow.