Responsible sourcing in Dubai: DMCC due diligence and UAE Good Delivery
Refiners are audited against the OECD five-step framework; wholesalers are asked to show where their metal came from. What the supply-chain rules mean downstream.
Dubai moves a large share of the world's physical gold, and the emirate's regulators have spent a decade aligning its supply-chain rules with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Two frameworks matter to a jewellery wholesaler.
DMCC Rules for Risk-Based Due Diligence
Refiners accredited under the DMCC's Dubai Good Delivery and Market Deliverable standards must implement the five OECD steps: a management system, risk identification, a risk-mitigation strategy, an independent third-party audit and public reporting. The audit report is published, so a buyer can check a refinery's status before sourcing from it.
UAE Good Delivery and the Ministry of Economy
At federal level the Ministry of Economy's due-diligence regulations for responsible sourcing of gold extend similar expectations across the sector, including traders who are not refiners. In practice a wholesaler is expected to know its suppliers, keep the refinery certificates and bar lists for the metal it buys, and be able to trace finished jewellery back to that metal.
What downstream buyers ask for
- The refinery and bar numbers behind a production run
- The supplier's own sourcing policy and latest audit summary
- Confirmation that no metal originated in a sanctioned or conflict-affected area without mitigation
Traceability without paperwork
Serialised pieces make this manageable. When a work order records the metal lot it consumed and each finished piece carries a serial linked to that work order, the question “where did this bangle's gold come from” is a lookup rather than an investigation, and the answer is printed on the invoice line the customs officer already has.
General information for gold traders in the UAE, not legal or tax advice. Rules change; confirm the current position with the Ministry of Economy, the Federal Tax Authority or your compliance adviser before acting.