The UAE is one of the world’s most important trading corridors for gold, diamonds, and precious stones. Shipments arrive from Africa, Central Asia, Europe, and beyond. Bullion is refined, traded, tokenised, stored, exported, and sometimes re-imported. Jewellery is retailed at scale. Diamonds move across borders with remarkable speed.
In this ecosystem, value is dense, portable, and liquid.
That reality makes Dealers in Precious Metals and Stones, DPMS, a strategically sensitive sector under the UAE AML framework. Compliance is not simply a regulatory obligation. It is a structural requirement for market access, banking continuity, and reputational durability.
This guide sets out the complete AML, CFT, and CPF legal framework applicable to DPMS in the UAE Mainland and commercial free zones, the regulatory authorities involved, the sector-specific challenges, and the best practice governance architecture expected today.
Who Are DPMS in UAE?
Under the UAE AML framework, Dealers in Precious Metals and Stones, commonly referred to as DPMS, are classified as Designated Non-Financial Businesses and Professions.
A business qualifies as a DPMS where it carries out, by way of trade or business, transactions involving precious metals or precious stones.
This includes, but is not limited to:
- Gold traders and bullion dealers
- Diamond and gemstone traders
- Jewellery retailers and wholesalers
- Precious metal refiners
- Importers and exporters of precious metals and stones
- Brokers and intermediaries in high-value commodity transactions
The Supervisory Authority for DPMS in UAE
Dealers in Precious Metals and Stones operating in the UAE Mainland and commercial free zones are supervised for AML purposes by the Ministry of Economy and Tourism.
The Ministry is the designated supervisory authority for the DPMS sector under the UAE AML Law. It conducts inspections, issues sector guidance, monitors goAML reporting, and imposes administrative penalties where non-compliance is identified.
DPMS are classified as Designated Non-Financial Businesses and Professions and must comply with federal AML legislation and Ministry directives.
Firms licensed in financial free zones such as ADGM or DIFC may fall under their respective financial regulators, depending on their activities.
Federal AML/CFT/CPF Laws and Executive Regulations
Dealers in Precious Metals and Stones are subject to the UAE’s broader AML, Counter-Terrorist Financing, and Counter-Proliferation Financing legal framework.
The core federal instruments include:
Federal Decree Law No. 10 of 2025
Concerning Anti-Money Laundering, Combating the Financing of Terrorism, and the Financing of Proliferation of Weapons.
Forms the legislative backbone of the UAE’s AML, CFT, and CPF framework, defining the statutory duties of all reporting entities, including DPMS. Establishes the risk-based approach, reporting obligations, governance standards, and enforcement architecture that structure the national financial crime regime.
Cabinet Resolution No. 134 of 2025
Concerning the Executive Regulations of Federal Decree Law No. 10 of 2025.
Provides the detailed implementing provisions supporting the AML Law, setting out requirements for customer due diligence, enhanced due diligence, ongoing monitoring, and supervisory inspections. Converts legislative intent into operational compliance standards subject to regulatory review.
Federal Law No. 7 of 2014
On Combating Terrorism Crimes.
Criminalises terrorism financing and associated conduct within the UAE. Underpins the national counter-terrorist financing framework and reinforces the obligation on reporting entities to detect and report activity linked to terrorist networks.
Cabinet Decision No. 74 of 2020
Regarding Terrorism Lists Regulation and Implementation of UN Security Council Resolutions on Targeted Financial Sanctions.
Establishes the UAE mechanism for implementing UN Security Council sanctions, including screening, immediate asset freezing, and reporting duties. Imposes strict compliance requirements where designated persons or entities are identified.
Cabinet Resolution No. 71 of 2024
Regulating administrative penalties for violations under the supervision of the Ministry of Economy and the Ministry of Justice.
Sets out the administrative penalty framework applicable to supervised entities, including DPMS. Defines financial sanctions and corrective measures for failures relating to due diligence, reporting, governance, and sanctions compliance.
Cabinet Decision No. 109 of 2023
On Regulation of Beneficial Owner Procedures.
Introduces mandatory identification, verification, and maintenance of accurate beneficial ownership information for UAE legal entities. Strengthens corporate transparency and supports effective risk assessment and regulatory oversight.
Cabinet Resolution No. 132 of 2023
Concerning administrative penalties for violations of Beneficial Owner regulations.
Imposes specific penalties for breaches of beneficial ownership disclosure and record-keeping requirements. Reinforces supervisory scrutiny over ownership transparency and documentation standards.
These instruments collectively define:
- AML obligations
- Counter-terrorist financing requirements
- Counter-proliferation financing controls
- Targeted Financial Sanctions Implementation
- Beneficial ownership transparency obligations
- Administrative penalty structures
For DPMS, this means AML compliance extends beyond suspicious transaction reporting. It includes screening against terrorism lists, compliance with UN sanctions regimes, beneficial ownership record maintenance, and adherence to penalty frameworks.
AML/CFT/CPF Guidance Applicable to All Reporting Entities
In addition to primary legislation, DPMS must align their compliance frameworks with federal guidance issued to all reporting entities, including financial institutions, DNFBPs, and VASPs.
Key instruments include:
Issued by the Executive Office for Control and Non-Proliferation, this guidance sets out the UAE’s framework for implementing UN Security Council sanctions, including screening, freezing obligations, reporting requirements, and internal controls for Targeted Financial Sanctions compliance.
This guidance provides a structured methodology for financial institutions, DNFBPs, and VASPs to identify, assess, and mitigate proliferation financing risks in alignment with UAE CPF obligations.
This document outlines typologies and red flag indicators associated with terrorist financing and proliferation financing, enabling firms to strengthen transaction monitoring and escalation procedures.
This guidance clarifies regulatory expectations for implementing counter-proliferation financing controls, including sanctions screening, internal governance measures, and reporting mechanisms.
This guidance addresses the regulatory risks associated with dealing with virtual asset service providers that are not licensed or supervised within the UAE. It sets expectations for due diligence, risk assessment, and control measures where counterparties may be operating outside the approved regulatory perimeter.
This document provides supervisory insight into compliance standards observed during inspections, highlighting examples of effective AML frameworks alongside common deficiencies. It serves as a practical benchmark for firms to assess whether their governance, documentation, and control environment meet regulatory expectations.
These reports present typologies, trends, and case studies relating to money laundering, terrorist financing, and proliferation financing risks identified in the UAE. Firms are expected to incorporate these insights into their Business Risk Assessment, monitoring scenarios, and staff training programmes to ensure their controls reflect current threat patterns.
UAE Money Laundering and Terrorist Financing National Risk Assessment (ML/FT NRA)
The UAE ML/FT National Risk Assessment outlines the country’s assessment of money laundering and terrorist financing threats, vulnerabilities, and inherent risks across financial institutions, DNFBPs, and other regulated sectors.
The NRA evaluates:
- Key predicate offences generating illicit proceeds
- Sector-specific exposure to ML and TF risks
- Cross-border risk factors
- Effectiveness of supervisory and institutional controls
DPMS are specifically assessed within the DNFBP category, with emphasis on trade-based money laundering, high-value commodity transactions, and cash-intensive activity.
Firms are expected to align their Business Risk Assessment with the findings of the ML/FT NRA. Failure to demonstrate this linkage is often identified during inspections.
UAE Proliferation Financing National Risk Assessment (PF NRA)
In addition to the ML/FT National Risk Assessment, the UAE has conducted a dedicated Proliferation Financing National Risk Assessment (PF NRA) to evaluate the country’s exposure to risks associated with the financing of weapons of mass destruction and related sanctions evasion.
The PF NRA assesses:
- National vulnerabilities to proliferation financing threats
- Sectoral exposure across financial institutions, DNFBPs, and VASPs
- Effectiveness of Targeted Financial Sanctions implementation
- Cross-border trade and dual-use goods risk factors
For Dealers in Precious Metals and Stones, the PF NRA is particularly relevant due to the international nature of bullion and gemstone trade, cross-border counterparties, and exposure to sanctioned jurisdictions.
Regulators expect DPMS to incorporate PF NRA findings into their Business Risk Assessment and sanctions compliance framework. Proliferation financing risk should not be treated as theoretical. It must be assessed, documented, and controlled through appropriate screening, escalation, and reporting mechanisms.
Together, the ML/FT NRA and PF NRA form the national risk foundation underpinning UAE AML/CFT/CPF supervision.
DNFBP Regulatory Framework Governing AML/CFT/CPF Compliance
Dealers in Precious Metals and Stones fall within the UAE’s regulated category of Designated Non-Financial Businesses and Professions (DNFBPs). As a result, their obligations extend beyond sector-specific rules and include compliance with the wider federal DNFBP AML/CFT/CPF framework.
This broader framework consists of:
- Federal AML/CFT/CPF legislation and its Executive Regulations
- Federal AML/CFT/CPF guidance issued to all reporting entities
- The UAE National Risk Assessment and related federal risk publications
- AML/CFT Guidelines for DNFBPs, issued September 2025
- Implementation Guide for Customer Risk Assessment, November 2024
- Implementation Guide for Customer Due Diligence, November 2024
These instruments collectively establish the core compliance foundation that all DPMS must implement as part of their AML, CFT, and CPF programme in the UAE.
AML Legal Framework for DPMS in UAE
The AML obligations applicable to DPMS are derived from the UAE’s primary AML legislation and implementing regulations. These include:
Federal Decree Law No. 10 of 2025
Strengthening enforcement mechanisms and expanding administrative sanctioning authority.
Cabinet Resolution No. 134 of 2025
Enhancing supervisory coordination and inspection authority.
Together, these instruments establish the mandatory compliance framework for DPMS.
Under these laws, firms are required to implement:
- A documented and regularly updated Business Risk Assessment
- Structured Customer Due Diligence and Enhanced Due Diligence procedures
- Ongoing transaction monitoring mechanisms
- Suspicious Transaction Reporting through goAML
- Targeted Financial Sanctions screening
- Record retention policies
- Clear governance and AML officer accountability
These are operational obligations. They apply directly to retail jewellery transactions, wholesale bullion trading, refining activities, diamond consignments, international wire transfers, and structured corporate purchases.
Federal and Sector-Specific Guidance for DPMS in UAE
Primary legislation establishes obligations. Regulatory guidance defines supervisory expectations.
DPMS must comply with federal DNFBP guidance in UAE, including:
- AML/CFT Guidelines for DNFBPs, September 2025
- Implementation Guide for Customer Risk Assessment, November 2024
- Implementation Guide for Customer Due Diligence, November 2024
These documents require firms to adopt a genuine risk-based approach. Risk scoring models must reflect transaction behaviour, geographic exposure, customer type, delivery channels, and ownership complexity. Template-based risk matrices rarely withstand inspection scrutiny.
In addition, DPMS are subject to sector-specific instruments that address vulnerabilities unique to precious metals and stones.
Supplemental Guidance for Dealers in Precious Metals and Stones, May 2019
This guidance identifies sector risks such as trade-based money laundering, structured cash transactions, misuse of intermediaries, and opacity in beneficial ownership structures.
Ministry Circular 08/AML/2021
This circular introduced mandatory threshold reporting requirements for cash and international wire transactions exceeding prescribed amounts. Reporting must be completed through goAML. Threshold reporting operates independently of Suspicious Transaction Reporting. Firms must maintain controls for both.
FIU Strategic Analysis Report, September 2025
This report outlines typologies involving bullion integration schemes, cross-border layering, and trade mispricing. Regulators increasingly expect Business Risk Assessments to incorporate typology intelligence. Static documents are treated as governance weaknesses.
Core AML Obligations for the DPMS Sector in UAE
A robust UAE AML Compliance framework for DPMS should include:
Business Risk Assessment
A documented, board-approved assessment aligned with UAE AML Law, National Risk Assessment findings, and sector typologies. It must address geographic exposure, customer segmentation, delivery channels, and product risk.
Customer Due Diligence
Firms must identify and verify customers, understand beneficial ownership, and establish the purpose and intended nature of the business relationship. For corporate clients, ownership tracing must be documented clearly and independently validated where necessary.
Enhanced Due Diligence
Required for high-risk jurisdictions, politically exposed persons, complex trade chains, and unusual transaction structures. Enhanced scrutiny should include source of funds and source of wealth analysis, where appropriate.
Ongoing Monitoring
Transaction monitoring should reflect the commercial realities of bullion and stone trading. Rapid resale patterns, structured payments, or inconsistent pricing behaviour must trigger internal review.
Targeted Financial Sanctions Screening
Screening must align with UAE requirements and Cabinet Resolution mandates. Screening should occur at onboarding and prior to transaction execution.
Suspicious Transaction Reporting
DPMS must file STRs promptly through goAML where suspicion arises. Internal escalation procedures should be documented and staff trained accordingly.
Governance and Oversight
Senior management must demonstrate active oversight. Minutes, reporting lines, AML officer appointment documentation, and periodic reviews are expected during inspections.
Key AML Challenges in the DPMS Sector
The DPMS sector presents distinctive compliance pressures.
- High cash exposure remains a risk factor in certain segments of the market. Structured cash purchases can mask layering attempts.
- Trade-based money laundering is a persistent vulnerability. Mispricing, complex invoicing chains, and cross-border documentation discrepancies require careful review.
- Portability of gold and stones allows rapid cross-border movement. Physical transport can bypass conventional banking controls.
- Corporate buyers may utilise layered offshore structures. Identifying ultimate beneficial ownership can be complex and resource-intensive.
- International counterparties introduce sanctions and high-risk jurisdiction exposure.
Operationally, there is often tension between sales velocity and compliance scrutiny. A culture that prioritises speed over verification invites regulatory findings.
Best Practices for Strong AML and GRC Architecture for DPMS in UAE
Leading firms approach AML as part of an integrated GRC framework.
A mature GRC Consultancy approach for DPMS typically includes:
- Risk assessment methodologies tailored to bullion, refining, wholesale, or retail models
• Technology-enabled monitoring integrated with accounting systems
• Real-time sanctions screening solutions
• Structured beneficial ownership verification processes
• Sector-specific training based on FIU typologies
• Periodic internal audit or independent AML reviews
• Inspection readiness exercises aligned with Ministry methodology
AML Consulting in the UAE today demands alignment with Federal Decree Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025. Enforcement posture has strengthened. Administrative penalties are more visible. Documentation quality is closely examined.
Where digital commodity models are involved, advisory work may also consider VARA licensing implications, CMA virtual asset framework standards, and ADGM FSRA Virtual Asset Framework expectations.
Effective GRC Advisory does not isolate AML. It integrates governance, risk management, regulatory awareness, and operational reality.
Reputation Is the Most Precious Commodity
The UAE’s ambition as a global trading hub stretches confidently across physical commodities and digital assets, supported by a regulatory framework shaped by FATF standards and coordinated global supervision. Within this environment, UAE AML Compliance for Dealers in Precious Metals and Stones is far more than a defensive obligation designed to satisfy inspectors. It functions as commercial infrastructure, protecting banking relationships, enabling cross-border trade, and reinforcing market credibility. Gold can be weighed, and diamonds can be graded with technical precision, yet governance is assessed differently. It is reflected in the strength of internal systems, the discipline of controls, the clarity of documentation, and the quiet confidence of being inspection-ready at any moment.
