Start with your own registration position in Hong Kong
Hong Kong operates a registration regime for dealers in precious metals and stones (DPMS), administered by the Customs and Excise Department. It matters before a Kenyan transaction is contemplated, because it shapes what your business may lawfully do and what records it must keep.
| Category A | Category B | |
|---|---|---|
| Covers | Non-cash specified transactions only | Cash transactions, and the AML obligations that attach |
| Threshold | Transactions at or above HKD 120,000, single or linked | Cash transactions at or above HKD 120,000, single or linked |
| AML obligations | Registration; cash transactions not permitted | Customer due diligence and record-keeping under the AMLO, plus fit-and-proper testing |
Exemptions apply to authorised institutions, pawnbrokers and certain regulated financial institutions conducting ancillary business. The practical consequence for a Kenya sourcing programme is straightforward: structure the transaction so it settles through the banking system rather than in cash, and keep records to the standard the regime expects.
Verify: Confirm your registration category, current fees and obligations with the Customs and Excise Department or your Hong Kong counsel. This summary reflects the published regime and is not advice on your firm's position.
Why Hong Kong buyers look at Kenya
Hong Kong is one of the world's established precious metals trading centres, with concentrated refining, fabrication and jewellery manufacturing demand and deep connections into mainland Chinese consumption. That demand needs feedstock, and East African supply is one of the origins that appears in the market.
What Kenya specifically offers is not lower prices — a below-benchmark quotation from any origin should be treated as a warning rather than an opportunity — but an origin with an established licensing framework, a functioning commercial and banking centre in Nairobi, and direct long-haul air freight capacity. The proposition is a documented, verifiable transaction, not a discount.
The considerations specific to this corridor
Time zones and pace
Hong Kong is UTC+8; Nairobi is UTC+3. The five-hour difference leaves a workable overlap between a Hong Kong afternoon and a Nairobi morning, which is when pricing conversations against the London reference are most practical. Expect a counterparty to be explicit about which fixing and which pricing date apply.
Freight routing
There is no short air route between Nairobi and Hong Kong; consignments transit a hub, most commonly in the Gulf. Every transit point is a handover, and each handover is a place where insurance cover and chain of custody must be continuous. Confirm the routing, the carrier's valuables handling, the security arrangements at each transit point, and the consignee at destination before agreeing terms.
Refining and acceptance
Establish before shipment that your intended refiner will accept material of this origin under its own responsible sourcing policy, and whether it requires material to arrive already refined by an accredited refiner. Material that arrives and cannot be placed is a far worse outcome than a transaction that was never contracted.
Language and documentation
Kenyan commercial and legal documentation is in English, which removes a translation layer common to other origins. Contracts should nonetheless specify governing law and dispute forum explicitly, and be reviewed by counsel in both jurisdictions.
A practical sequence for a first Kenya transaction
- Confirm your own DPMS registration category covers the structure you intend to use.
- Qualify the Kenyan counterparty: registered entity, mineral dealer's licence category and number confirmed with the Directorate of Mines, directors, and a bank account in the entity's own name.
- Agree the commercial frame in writing: form, fineness, benchmark and differential, pricing date, Incoterms, exporter of record, and settlement basis.
- Instruct your own assay and your own inspector in Kenya. Do not rely on the seller's laboratory.
- Confirm acceptance with your Hong Kong refiner or vault operator, and identify the importer of record.
- Settle against a verifiable event — outturn or documents under a bank instrument. Never in advance, never in cash, never to a third party.
- Size the first lot to test the process end to end.