UAE AML rules for gold dealers: goAML, cash reporting and the DPMSR
Dealers in precious metals and stones are a regulated sector in the UAE. What the Ministry of Economy expects from a Dubai gold wholesaler, and how to make it routine.
Since the Federal Decree-Law on anti-money laundering (No. 20 of 2018) and its implementing regulation, gold and jewellery businesses in the UAE are treated as Designated Non-Financial Businesses and Professions. For a wholesaler in Deira or the DMCC that means the same core obligations a bank has, scaled to the size of the trade.
Register on goAML
Every dealer in precious metals and stones must be registered on the Financial Intelligence Unit's goAML portal and supervised by the Ministry of Economy. Registration is not a one-off: the appointed compliance officer must keep the profile current and use the portal for all reporting.
Know your customer before the first gram moves
Customer due diligence covers identity, beneficial ownership for companies, the nature of the business and the source of funds where the risk warrants it. For export buyers this is where the trade licence, passport copy, importer code and address on file earn their keep. Enhanced due diligence applies to politically exposed persons and to counterparties in higher-risk jurisdictions.
Cash: the DPMSR threshold
Cash transactions of AED 55,000 or more, whether single or linked, must be reported through goAML as a Dealers in Precious Metals and Stones Report within the prescribed window. Most wholesalers simply refuse cash above the threshold and route settlements through bank transfer, which also keeps the audit trail clean for the invoice.
Suspicious transaction reports
Where something does not add up, a buyer who will not explain the source of funds, an unusual pattern of small invoices, pressure to change the consignee after the fact, the compliance officer files a Suspicious Transaction Report. Tipping off the customer is itself an offence.
Keep records for five years
Customer files, invoices, packing lists and the reasoning behind risk decisions must be retained for at least five years and be producible on request. A workstation that stores the signed invoice, its QR payload and the customer's KYC status side by side turns that from a filing exercise into a search.
Making it routine
- Name a compliance officer and write down the risk assessment.
- Block invoice issue when the customer's KYC is pending or expired.
- Run a sanctions screen on new counterparties and re-screen annually.
- Train counter staff on the cash threshold and red flags.
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.