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Going for gold – an introduction to

the Shanghai International Gold
Exchange
January 2019
Going for gold – an introduction to the Shanghai
International Gold Exchange
Introduction
China is the world’s top consumer, producer and importer of gold. Yet, the price of gold and other precious metals continues
to be determined by the precious metals markets in London and elsewhere.

China’s first attempt at creating an international price for a commodity arose through its establishment of the Shanghai
International Gold Exchange (SGEI) in September 2014, long before its recent attempts to establish an international price for
crude oil and iron ore in Chinese yuan (RMB). It is worth noting that while China recognises the dual nature of gold as being
both a commodity and a financial product, gold is treated more as a ‘financial product’ than a ‘commodity’.

The SGEI is registered in the China (Shanghai) Pilot Free Trade Zone (Shanghai FTZ) and is a wholly owned subsidiary of
the Shanghai Gold Exchange (SGE). The SGE was itself established in October 2002 by China’s central bank, the People’s
Bank of China (PBOC). The SGEI enables foreign institutions and individuals to access China’s gold market, using free trade
accounts (FT Accounts) located in the Shanghai FTZ (i.e., the FT Account system) and the preferential policies applicable to
the Shanghai FTZ.

Today, the SGE is the world’s largest exchange for physical gold by trading volume, and is supported by the gold futures
market of the Shanghai Futures Exchange (SHFE) and the over-the-counter (OTC) gold market. Gold trading volumes on the
SGE in 2017 reached approximately 54,300 tonnes, amounting to RMB 14.98 trillion, and this grew more than 24% to
approximately 67,500 tonnes, amounting to RMB 18.30 trillion in 2018.

Development of SGE
The SGE has developed a diverse suite of products and services to meet market demand. Beyond physical spot trading of
gold, the SGE itself offers, or facilitates through others:

• price matching trading in precious metals (including spot and deferred products);

• OTC derivative gold products such as spot, forward, swap and option contracts, and exchange traded funds (ETFs);

• a gold leasing market, allowing for bank-to-enterprise leasing as well as inter-bank lending; and

• clearing, delivery, storage and shipment services for gold.

The SGE and SGEI (together, the Exchange) are at the heart of the Chinese precious metals markets, and are a key tool in
support of PBOC’s internationalisation of Chinese precious metals. The SGEI was launched, with its RMB-denominated gold
contracts, for trading by international participants using offshore RMB. Then in 2015, the SGE co-developed the ‘Shanghai-
Hong Kong Gold Connect’ to connect members of the Chinese Gold & Silver Exchange Society in Hong Kong (HK CGSE)
with the SGE. More recently, in 2016, the SGE launched the Shanghai Gold Benchmark Price, creating the first RMB-
denominated gold benchmark price catering to Asian trading hours.

Interaction with SGEI

The SGEI was set up to serve three main purposes:

i. as an information technology interface enabling international members to trade on the domestic Main Board (MB);

ii. to implement the clearing of offshore funds using FT Accounts; and

iii. to facilitate transhipment tradesi by countries in South-east Asia and East Asia, centred around Shanghai.ii

The SGEI offers international investors the opportunity to participate in China’s gold market by creating, onshore within the
Shanghai FTZ, an ‘offshore’ market. The SGEI oversees the International Board (IB), which lists three RMB-denominated
physical gold contracts, as distinct from but in parallel to the domestic MB. However, in many ways, the SGE and the SGEI

01 Reed Smith Going for gold – an introduction to the Shanghai International Gold Exchange
adopt similar rules and systems, with additional rules for SGEI participants to enable the SGEI to govern the ‘international
context’.

A good example of the distinction that exists between the SGE and the SGEI relates to the location of the underlying gold
traded on the IB. This gold is physically segregated from the domestic market, in a separate SGEI certified vault located in
the Shanghai FTZ. This allows international participants to freely deal in physical gold, including the load-in, load-out, storage
and delivery of physical gold within the SGEI certified vault, in accordance with the SGEI rules, guidelines and customs
procedures (on delivery and management of bullion, see further below).

The MB lists a wider variety of contracts, including silver and platinum products, not all of which are available to international
members and their customers. The table below summarises the list of MB and IB products currently available.

Certified vault for Domestic member/ International member/

Board venue Product type Product code
delivery customer customer
Au99.95
Spot gold Au99.99
products Au100g 1. Transaction and
Au99.5 delivery allowed.
Au(T+D) 2. Load-in and load-out
prohibited.
Deferred gold Au(T+N1)
products Au(T+N2) 1. Transaction and
SGE certified vault delivery allowed.
Main Board (SGE) mAu(T+D)
2. Load-in and load-out
1. Transaction allowed.
Deferred silver allowed.
Ag(T+D) 2. Delivery, load-in and
products load-out prohibited.
Ag99.9 Unable to transact since
Silver
Ag99.99 physically settled and no
dealing in physical
Platinum Pt99.95
delivery allowed.
iAu99.99 1. Transaction and
iAu99.95
1. Transaction and delivery allowed.
International Board Spot gold SGEI certified vault delivery allowed. 2. Load-in (only if
(SGEI) products 2. Load-in and load-out authorised) and load-out
iAu100g prohibited. allowed.

International members and their customers are able to transact and deliver in specified MB gold contracts, although load-in
and load-out of the SGE certified vaults are prohibited. Similarly, domestic members and their customers may transact and
deliver in IB contracts, but are prohibited from load-in and load-out of the SGEI certified vaults. A physical gold import licence
is needed to import any of the gold into the domestic market, for subsequent trading on the MB, and this licence is granted
sparingly. Any physical gold export from the domestic market is still generally prohibited at present. This restriction clearly
separates domestic market gold volumes from international market gold volumes.

International members and their customers are also required to open FT Accounts with designated settlement banks, using
offshore RMB (i.e., CNH) and the FT Account system in the Shanghai FTZ, in order to settle their trades. Funds can be
remitted freely between an FT Account and: (i) an overseas account; (ii) an onshore non-residential account; or (iii) other FT
Accounts.

International members and their role in the Exchange

Customers are classified by their brokerage member as ‘Domestic Customers’ or ‘International Customers’. Customers are
identified by trading codes, and brokerage members can only execute trades for each customer according to the customer’s
trading code. Each trading code comprises two elements: (i) the seat code of the brokerage member; and (ii) the customer
code. A customer using different brokers will always have the same customer code though each broker’s seat code will differ.

Brokerage services can only be offered to domestic customers through domestic ‘Financial Members’ or ‘General Members’,
and to international customers through international ‘Type A Members’. A brokerage agreement with the relevant member will
set out the rights and obligations of the SGE, the SGEI (where relevant), the brokerage member and the customer.

Going for gold – an introduction to the Shanghai International Gold Exchange Reed Smith 02
Brokerage members are able to set customer margin levels, and position and trading limits, as well as force liquidation of
customer positions if necessary. However, customer funds are kept separately from the brokerage member’s proprietary
trading funds by a settlement bank, and governed by a tripartite agreement between the customer, brokerage member and
settlement bank (on the role of the settlement bank, see further below).

Qualifying market participants may also wish to consider membership of the SGE or SGEI, as applicable.

At the end of May 2018, the Exchange had 254 members, comprising 185 domestic members and 69 international members.
This excludes the members of the HK CGSE linked via the Shanghai-Hong Kong Gold Connect.iii Domestic members are
legal entities registered in the People’s Republic of China (PRC), while international members are legal entities registered
outside the PRC (including in Hong Kong, Macau or Taiwan) or in a region otherwise recognised by the SGE (e.g., the
Shanghai FTZ). Domestic membership can be transferred (with the SGE’s approval), but international membership cannot
be.iv

Members are further categorised according to their business scope, with domestic members divided into ‘Financial Members’,
‘General Members’ and ‘Special Members’, while international members of the SGEI are classified as ‘Type A Members’,
‘Type B Members’ or ‘Special Members’.

The table below summarises the membership framework of the Exchange.

Domestic (SGE) International (SGEI)

Category of
Financial General Special Type A Type B Special
member
 Proprietary  Proprietary  Members,  Proprietary  Proprietary  E.g., HK
trading trading typically trading trading CGSE
 Brokerage for  Brokerage for corporations,  Brokerage
institutional institutional that SGE deems
Scope of important to
and individual customers
business customers address ‘market
 Other needs’
businesses
approved by
PBOC
In order to become a member, the applicant will need to satisfy the eligibility and application requirements. These differ
between domestic and international members. The eligibility and application requirements for international membership are
as follows:

To be eligible, you must… As part of your application, you must…

Be a legal or business entity registered outside the PRC Provide reasons for the membership application.
(including Hong Kong, Macau or Taiwan) or within a region
otherwise recognised by the Exchange.

Acknowledge and abide by the articles of association and Provide particulars of the principal responsible for relevant
rules of the Exchange. businesses, an operation plan and other information as
required.
Acknowledge that the SGEI governs respective business Participate in and complete the mock trading test.
activities and supervises activity in the Exchange.

Pay the membership fee of RMB 2.8 million for Type A

Possess competitive industry background or position.
Members and RMB 1.6 million for Type B Members.
Have net assets of not less than US$10 million (or equivalent Pay the annual fee of RMB 50,000.
in RMB or other currency).

Operate in compliance with the law and have no record of a Open an account at a certified settlement bank, to be
serious offence during the two years immediately preceding exclusively used for clearing purposes.
the application.

Have traders recognised by the Exchange and the trading Participate in training courses designed for traders and obtain

03 Reed Smith Going for gold – an introduction to the Shanghai International Gold Exchange
facilities and networks necessary to carry out business. relevant qualification certificates.

Meet the minimum trading volumev requirement for

Meet any other requirements prescribed by the Exchange. international members. Currently, the minimum trading volume
is ten metric tons per year for Type A Members and five metric
tons per year for Type B Members.
The decision for approval by the Exchange will take approximately 30 business days upon receiving completed and
satisfactory application documents. Following approval, the applicant will have 30 business days to complete the approval
procedures, and any applicant who fails to do so is deemed to have waived their membership request.

Unlike PRC futures brokers, who provide brokerage and clearing services on the PRC futures markets, members of the SGE
or SGEI are not precluded from entering into proprietary trades.

Role of settlement banks

As mentioned earlier, international members and their customers must open FT Accounts with a settlement bank for
purposes of clearing and settlement in offshore RMB. Brokerage members must open three FT Accounts:

i. a Proprietary Account;

ii. a General Settlement Account; and

iii. a Brokerage Account.

The Proprietary Account is used for proprietary trading by the brokerage member, while the General Settlement Account is
used to pay the Settlement Reservevi and other fees owed to the Exchange. The Brokerage Account is a transitional account,
to hold customers’ funds temporarily before these funds are transferred into the Exchange’s settlement account (SGEI
Settlement Account, also held with the settlement bank).

Settlement banks aid in the transfer of funds when settlement is carried out by the Exchange. International members and
their customers can currently choose from a list of eight certified settlement banks with which to open FT Accounts, including
one offshore bank, being the Bank of China (Hong Kong) Limited.

Trading and physical settlement on or via the SGE

The Exchange has developed a number of products for centralised trade and settlement (Centralised Exchange Traded
Products) on the Exchange. Centralised Exchange Traded Products should be distinguished from products that are not
centrally executed on the Exchange, but are either facilitated, settled or sponsored by the Exchange. Such means of bilateral
trade execution include the use of a National Association of Financial Market Institutional Investors Master Agreement
(NAFMII Master Agreement), an SGE operated quotation platform or the China Foreign Exchange Trade System (CFETS).

Appendix 1 sets out in more detail the types of products available. It should be noted that not all product types or products
listed on the Exchange are available for trading by all international members or their customers. For example, international
members and their customers are not allowed to participate in physical delivery of platinum and silver, which precludes them
from trading in platinum and silver contracts that are physically settled.

It should be noted that although China’s futures market regulator is the China Securities and Regulatory Commission (CSRC),
the SGE is not regulated by the CSRC but by the PBOC. Notionally, therefore, products traded on the SGE or SGEI are not
futures products.

As the SGEI is authorised by the SGE to provide trading access, clearing, risk management and other services to
international members, the following paragraphs and sections will refer to the SGEI in relation to conducting these activities
for international members.

The SGEI’s margin system comprises two pools of funds, which are used to cover its obligations: (i) the Trading Margin;vii and
(ii) Settlement Reserve. Subject to the approval of the SGEI, an international member may post marketable assets as
collateral, in accordance with applicable rules, in satisfaction of their margin requirements. Collateral includes inventories,
foreign currencies, bonds and other forms of collateral recognised by the SGEI. Detailed rules for administration of the margin
collateral service are published, and the SGE or SGEI will announce the base price and applicable haircut for the collateral.

Going for gold – an introduction to the Shanghai International Gold Exchange Reed Smith 04
Clearing and settlement of funds
The SGE performs clearing and provides performance guarantees to its members, and the SGEI provides centralised
settlement services to international members.

In the context of the SGEI, the term ‘clearing’ refers to the calculation, collection and remittance of currency payments, based
on trading results and pursuant to the relevant rules of the Exchange. Similar to the Shanghai International Energy Exchange
(INE) and other Chinese futures exchanges, the publication of the settlement price determines the gains or losses (in RMB)
with respect to the existing position of the participant. As such, the SGEI shall debit or credit the relevant earnings or losses
from or to the member’s Settlement Reserve. The amount of any penalties or expenses incurred will also be debited from the
member’s Settlement Reserve. Members must restore the minimum Settlement Reserve prior to commencement of trading
on the next day to avoid being declared in default.

At the end of a trading day, the SGEI will initiate a clearing process and each member will receive clearing data and
settlement statements/instructions, which the member then has to promptly act upon to perform the necessary debiting or
crediting from their respective settlement accounts. Any international member who wishes to dispute the clearing data or
settlement statements/instructions must notify SGEI in writing 30 minutes before market opens on the next trading day at the
latest, or is otherwise deemed to have accepted their accuracy.

Delivery and management of physical bullion

The Exchange has set up a network of SGE certified vaults and SGEI certified vaults, which provide storage, load-in and
load-out of all physical bullion. Load-in and load-out processes will be managed by the certified vault subject to certain
deposit and withdrawal conditions. The SGEI certified vault provides customs declaration services for international members
and customers, as well as any domestic members and customers who are qualified to import and export gold.

Bullion is classified into deliverable or depositable (otherwise known as ‘Safe Deposit Vaulting Service’) bullion. Depositable
bullion cannot be used for the delivery of trades executed on or through the Exchange, although inter-vault transfers
(between deliverable and depositable bullion vaults) can be carried out upon application.

The SGEI regulates the process for the delivery of precious metals traded on the IB, and oversees the operation of the SGEI
vault system for physical deliveries. ‘Physical delivery’ refers to the transfer of ownership of bullion in accordance with the
Exchange’s rules. The SGEI provides each member or customer with a unique Bullion Account (and code), which is used to
conduct physical delivery transactions via transfers between Bullion Accounts. This account can be subdivided into a Load-in
Inventory Accountviii and a Traded Inventory Accountix for gold.

Load-In Inventory can only be withdrawn from the same certified vault in which it was deposited. Conversely, depending on
the type of product, Traded Inventory can typically be withdrawn from any certified vault. However, as there is only one SGEI
certified vault at the time of writing (as compared to 56 SGE certified vaults for gold and two for silver), this is less of a
concern for international participants.

For deliverable bullion traded on the IB, authorised international members and customers may deposit bullion into the SGEI
certified vault only. An exception would be that authorised international members or customers may, subject to relevant
approved quota, deposit deliverables for the MB into the SGEI certified vault, but never into an SGE certified vault.

For physical contract trades executed on the Exchange, physical delivery takes place at the time of trade execution, and
members or customers may submit an application to take delivery immediately after trade execution. For trades in other types
of contracts, delivery timing might differ. The SGEI processes day-end physical delivery in the following order: spot contracts,
deferred contracts, benchmark price contracts and then OTC contracts. This order matters as gold received in a particular
Bullion Account from spot contracts can be used for physical delivery of, for example, OTC contracts.

Before the settlement process at the end of any trading day, all buyers and sellers should have the necessary physical gold
or funds agreed to in the trade, as failure to do so will result in the declaration of a default, and the imposition of a penalty.
The deduction of precious metal from a seller will take place in its Load-In Inventory Account followed by its Traded Inventory
Account, according to the order of the trade, with deductions made from accounts holding the lowest to the highest stock.

International members and customers must report any bullion withdrawn from the SGEI certified vault to the Exchange,
inform customs authorities of the destinations for such bullion, and comply with the various exit procedures in place for
withdrawn bullion.

05 Reed Smith Going for gold – an introduction to the Shanghai International Gold Exchange
Other services offered to members and customers by the Exchange are pledging and leasing services, inventory swaps, non-
trading transfers and the creation or redemption of gold ETF shares, subject to requisite qualifications.

Risk management system

The Exchange has implemented mechanisms to manage the risks associated with the trading activities of international
members and their customers. These mechanisms include:

• margin requirements; • large position reporting;

• price limits; • forced liquidation;

• fees (e.g., deferred fees and extended position fees); • risk warnings; and

• position and trading limits; • market surveillance.

Margin requirements and price limits are discussed briefly. The Settlement Reserve and Risk Management Fund, as well as a
waterfall model for distributing losses, also help in risk management.

Margin requirements are applied by the Exchange to provide protection against market risk exposures. There is a minimum
Trading Margin, which is a percentage of the notional value of each deferred product, amounting to no less than 6 per cent
for gold deferred products. However, the level may be adjusted in view of market risks, such as when open interest has hit a
certain threshold, or a price limit is hit. International members must collect from their customers no less Trading Margin than
that collected by the SGEI from the member.

The SGEI sets out price limits, which are typically based on a percentage of the settlement price of each product on the
previous trading day, but are subject to adjustments where necessary to account for potential market risk exposures. If
triggered, the price limit will apply again on the following trading day. In the event that trading continues to be one-sided at
price limits, the SGEI has broad powers to intervene, including by liquidating positions or suspending the market.

Conclusion
Alongside the ‘Belt and Road’ initiative, China will be looking to strengthen cooperation and interconnectivity in gold trading,
investment and financing with the markets of ‘Belt and Road’ countries in the years to come. The SGE, together with the
SGEI, is striving to become a world-class comprehensive gold exchange, and the platform of choice for end-to-end trade in
precious metals. Chinese commodity futures markets, such as the INE, have looked to the SGEI for inspiration when
establishing rules for international access. There are many similarities between the PRC futures exchanges and the SGE.
However, it would be wrong to assume the similarities between the two markets outweigh the very many differences.

i
Transhipment is the shipment of goods to an intermediate destination, prior to their final intended destination. Transhipment
may be used as a means to change the mode of transportation, or for consolidation or deconsolidation of cargo.
ii
Xu, Luode, “The Development and Opening of China's Gold Market”. Speech presented at the LBMA Bullion Market Forum
in Singapore on 25 June 2014. Retrieved from http://www.lbma.org.uk/assets/blog/alchemist_articles/Alch75Luode.pdf
iii
The HK CGSE as a whole is classified as a special international member. The list of members may be accessed at:
https://www.cgse.com.hk/en/member_01.php
iv
However, international membership can be withdrawn and the membership fee will be refunded.
v
The minimum aggregate trading volume of each member is based on the member’s total gold trading volume, including the
volume purchased and volume sold.
vi
Settlement Reserve refers to the cash funds and collateralisation quota maintained by an international member under the
SGEI Settlement Account for settling trades that may be executed in the future. It is the portion of the cash funds and
collateralisation quota not yet used as a margin for contracts. The minimum Settlement Reserve balance for an international
member is RMB 500,000 per seat, subject to adjustment by the SGEI based on market conditions as well as the scale of the
international member and the type of business it plans to engage in at the Exchange. The international member must use its
own cash funds to meet the minimum Settlement Reserve.
vii
Trading Margins refers to the funds and collateralisation quota maintained by an international member under the SGEI
Settlement Account to guarantee the performance of its trades, and is tied to the international members’ existing trade.
viii
The Load-in Inventory Account records the physical bullion deposited into a certified vault.
ix
The Traded Inventory Account records the precious metal purchased by a member or a customer.

Going for gold – an introduction to the Shanghai International Gold Exchange Reed Smith 06
Appendix 1
Centralised Exchange Traded Products
A. Price matching trading (bid/ask trading on a central order book)

Type Features
 Full funds and bullion must be available at order
submission
Physical contracts
 Immediate settlement upon transaction (i.e.,
seller can immediately use funds, and buyer can
immediately sell bullion or apply for withdrawal)
Spot Contracts (silver only)  Traded on margin at T
 Settlement and delivery of bullion on T+2
 Traded on margin at T
 When tendered for delivery, settlement and
Deferred contracts delivery of bullion on specified delivery date
 ‘Delivery equalizer’ mechanism used to balance
unequal long and short positions tendered for
delivery

B. Benchmark price trading (tendering volumes based on the Shanghai Gold Benchmark Price)

Type Features
 Used to fix the Shanghai Gold Benchmark Price
 AM session and PM session
 Fixing members and reference price members
provide initial price
Shanghai Gold Benchmark Price  Members and customers tender for intended
volume at stated initial price
 Based on size of volume imbalance between
buy and sell orders, session is either terminated
or repeated with an adjusted price
 Settlement and delivery of bullion on T+2

Exchange registered products

C. Price asking trading (trades registered on the SGE but negotiated bilaterally, such as through a NAFMII Master
Agreement, or executed through designated quotation platforms, such as CFETS)

Type Features
Spot contract  Settlement and delivery on T+2
 Physical or cash settlement available
 Settlement and delivery on specified delivery
Forward contract date
 Physical or cash settlement available
 Completed in two legs – positions in opposite
direction
Swap contract  Settlement and delivery on two different trading
days but in the same quantity
 Physical or cash settlement available
 Option buyer pays premium for option to buy or
sell agreed quantity at agreed time and price
Option contract from option seller
 European and American options available
 Physical or cash settlement available

07 Reed Smith Going for gold – an introduction to the Shanghai International Gold Exchange
 Generally only available for proprietary seats of
financial institutions
Lending contract  Institutions approved for CFETS transactions
can participate
 Bullion is borrowed, at a jointly determined
interest rate, and returned at a later date

Exchange settled products

D. Gold leasing

Type Features
 Lender must be a financial institution or other
such institution recognised by SGE
Financial institution to enterprise
 Borrower enterprise must be in the business of
precious metals, such as mining, refining or use
of gold in production process
 Lender must be an approved financial institution
Financial institution to financial institution or a gold ETF
 Parties are subject to the relevant regulatory
requirements
Intergroup leasing  Lending from headquarters to a branch

E. Gold ETFs (physical contract subscription, creation and redemption)

Going for gold – an introduction to the Shanghai International Gold Exchange Reed Smith 08
Authors
If you have questions or would like additional information on the material covered in this article, please contact one of the
authors.

Michael Fosh Katherine Yang Jeffrey Yang

Partner Counsel Senior Associate
Beijing Beijing Shanghai
+86 10 6535 9566 +86 10 6535 9532 +86 21 6032 3152
[email protected] [email protected] [email protected]

Peter Zaman Kate Whelan Matthew Yeo

Partner Associate Associate
Singapore London Singapore
+65 6320 5307 +44 (0)20 3116 3864 +65 6320 5391
[email protected] [email protected] [email protected]

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01 Reed Smith Going for gold – an introduction to the Shanghai International Gold Exchange