AML Compliance Framework for DPMS in the UAE
- Dealers in Precious Metals and Stones (DPMS) are classified as DNFBPs under the UAE AML framework, requiring full compliance with AML, CFT, and CPF obligations due to the sector’s exposure to high-value and portable commodities.
- The regulatory structure is primarily based on Federal Decree Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025, supported by sanctions regulations, beneficial ownership rules, and sector guidance.
- DPMS must implement strong risk-based controls, including Business Risk Assessments, Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), sanctions screening, and suspicious transaction reporting through the goAML platform.
- Effective governance, monitoring, and documentation are essential to manage risks such as trade-based money laundering, cross-border transactions, and complex ownership structures in the precious metals and stones sector.
The United Arab Emirates is one of the world’s leading trading hubs for gold, diamonds, and precious stones. Large volumes of bullion and gemstones are imported, refined, traded, stored, exported, and in some cases re-imported. Jewellery is manufactured and sold at scale. Diamonds and other high-value commodities move quickly across borders.
In this environment, value is concentrated, portable, and highly liquid. These characteristics make the sector inherently exposed to money laundering and proliferation financing risks.
For this reason, Dealers in Precious Metals and Stones, DPMS, are treated as a strategically sensitive sector under the UAE AML framework. Compliance is not merely a legal requirement. It is essential for maintaining banking relationships, market access, and long-term reputational stability.
This guide explains the AML, CFT, and CPF legal framework applicable to DPMS in the UAE Mainland and commercial free zones, the supervisory authorities involved, the relevant national risk assessments, and the governance standards expected by regulators.
Who Qualifies as DPMS in the UAE
Under the UAE AML law, Dealers in Precious Metals and Stones are classified as Designated Non-Financial Businesses and Professions.
A business is considered a DPMS if it conducts, as part of its trade or business, transactions involving precious metals or precious stones.
This category includes:
- 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 involved in high-value commodity transactions
The defining feature of the sector is the ability to transfer significant value through relatively small and easily transportable assets. This risk profile shapes the regulatory expectations placed on DPMS.
The Supervisory Authority for DPMS in UAE
Ministry of Economy and Tourism serves as the AML supervisory authority for Dealers in Precious Metals and Stones (DPMS) operating across the UAE Mainland and its commercial free zones.
Under the UAE AML Law, the Ministry holds formal oversight of the DPMS sector. Its role includes conducting inspections, issuing sector-specific guidance, overseeing goAML reporting obligations, and applying administrative penalties in cases where breaches or compliance gaps are identified.
DPMS fall within the category of Designated Non-Financial Businesses and Professions and are therefore required to comply fully with federal AML legislation, along with the directions and supervisory expectations issued by the Ministry.
Where DPMS are established within financial free zones such as ADGM or DIFC, supervision may instead fall under the relevant financial free zone regulator, depending on the nature of the firm’s licensed activities.
Core Federal AML, CFT, and CPF Laws
Federal Decree Law No. 10 of 2025
Concerning Anti-Money Laundering, Combating the Financing of Terrorism, and the Financing of Proliferation of Weapons.
This is the primary AML legislation in the UAE. It establishes the obligations of reporting entities, including DPMS, covering customer due diligence, suspicious transaction reporting, record keeping, sanctions compliance, and governance responsibilities. It also strengthens enforcement powers and administrative sanctioning authority.
Cabinet Resolution No. 134 of 2025
Concerning the Executive Regulations of Federal Decree Law No. 10 of 2025.
This resolution provides the detailed implementing framework for the AML Law. It defines risk-based approach requirements, customer risk assessment standards, enhanced due diligence triggers, and supervisory inspection powers. It translates legislative principles into operational compliance obligations.
On Combating Terrorism Crimes.
This law criminalises terrorism financing and related offences. It underpins the UAE’s counter-terrorist financing regime and reinforces the obligation on reporting entities, including DPMS, to prevent and detect transactions linked to terrorist activity.
Cabinet Decision No. 74 of 2020
Regarding Terrorism Lists Regulation and Implementation of UN Security Council Resolutions on Targeted Financial Sanctions.
This decision establishes the framework for implementing UN Security Council sanctions in the UAE. It requires immediate screening, freezing of assets, and reporting obligations where designated individuals or entities are identified. DPMS must incorporate targeted financial sanctions screening into onboarding and transaction controls.
Cabinet Resolution No. 71 of 2024
Regulating Administrative Penalties for Violations under the Supervision of the Ministry of Economy and the Ministry of Justice.
This resolution sets out the schedule of administrative penalties applicable to supervised entities, including DPMS. It defines the consequences of failures in customer due diligence, reporting, governance, and sanctions compliance.
Cabinet Decision No. 109 of 2023
On Regulation of Beneficial Owner Procedures.
This decision requires companies to maintain accurate and up-to-date beneficial ownership information. DPMS must ensure proper identification and documentation of ultimate beneficial owners, particularly where corporate customers or layered structures are involved.
Cabinet Resolution No. 132 of 2023
Concerning Administrative Penalties for Violations of Beneficial Owner Regulations.
This resolution establishes penalties for failure to comply with beneficial ownership transparency requirements. It reinforces the importance of accurate record-keeping and timely updates to ownership registers.
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AML/CFT/CPF Guidance Applicable to All Reporting Entities
Primary legislation defines the legal obligations. Federal guidance defines how regulators expect those obligations to operate in practice.
Dealers in Precious Metals and Stones must ensure that their AML framework aligns with the guidance issued to all reporting entities in the UAE, including financial institutions, DNFBPs, and VASPs. During inspections, supervisors frequently assess whether internal policies reflect these guidance papers in substance rather than by reference alone.
Key instruments include:
Guidance on Targeted Financial Sanctions for Financial Institutions, DNFBPs, and VASPs, July 2025
Issued by the Executive Office for Control and Non-Proliferation, this guidance establishes the UAE’s framework for implementing UN Security Council sanctions. It sets out expectations for real-time screening, immediate freezing obligations, prohibition on making funds or assets available to designated persons, reporting timelines, and internal control standards. DPMS must ensure their sanctions screening systems and escalation processes are calibrated to these requirements.
Proliferation Finance Institutional Risk Assessment Guidance, December 2023
This document provides a structured methodology for identifying, assessing, and mitigating proliferation financing risks. It requires firms to adopt a documented, risk-based approach to CPF exposure, including customer risk factors, geographic exposure, product vulnerabilities, and trade-based indicators. DPMS are expected to reflect this methodology within their Business Risk Assessment.
Terrorist and Proliferation Financing Red Flags Guidance, December 2023
This guidance outlines typologies and red flag indicators associated with terrorist financing and proliferation financing. It supports firms in strengthening transaction monitoring, identifying unusual trade patterns, and enhancing internal escalation procedures. For DPMS, this includes attention to trade mispricing, unusual shipping routes, and counterparties linked to sanctioned jurisdictions.
Guidance on Counter Proliferation Financing, November 2022
This document clarifies regulatory expectations for implementing CPF controls. It covers governance structures, sanctions screening mechanisms, reporting obligations, and internal awareness programmes. It reinforces that proliferation financing risk must be actively managed rather than treated as an extension of standard AML processes.
Joint Guidance on Combating the Use of Unlicensed Virtual Asset Providers in the UAE
This guidance addresses risks associated with transactions involving unlicensed or unregulated virtual asset service providers. Where DPMS engage in digital asset settlement, tokenisation models, or crypto-linked transactions, this guidance becomes particularly relevant.
Joint Guidance on Satisfactory and Unsatisfactory Practices
This document provides supervisory insight into compliance practices observed during inspections. It highlights examples of effective governance as well as common deficiencies. Firms can use it as a benchmark to evaluate the maturity of their own AML frameworks.
FIU Strategic Analysis Reports
These reports present typologies, trends, and case studies relating to money laundering, terrorist financing, and proliferation financing. Regulators increasingly expect firms to incorporate these findings into their risk assessments, training programmes, and monitoring scenarios.
Alignment with federal guidance should be demonstrable. Policies, procedures, risk scoring models, and monitoring controls must reflect the themes and methodologies outlined in these instruments.
UAE Money Laundering and Terrorist Financing National Risk Assessment (ML/FT NRA)
The UAE Money Laundering and Terrorist Financing National Risk Assessment serves as the country’s official examination of how, where, and why financial crime risks arise. It maps the exposure of financial institutions, Designated Non-Financial Businesses and Professions (DNFBPs), and other regulated sectors, providing a structured view of national threats, vulnerabilities, and inherent risk levels.
The assessment focuses on several core areas:
- The primary predicate offences responsible for generating illicit funds
- The level of exposure faced by different sectors to money laundering and terrorist financing risks
- Risks arising from cross-border activity and geographic connections
- The strength and effectiveness of supervisory systems and institutional safeguards
Dealers in Precious Metals and Stones are assessed as part of the DNFBP segment. Within this sector, particular focus is placed on trade-based money laundering risks, large-value commodity transactions, complex international supply chains, and the continued presence of cash-driven business activity.
Regulators expect DPMS to reflect the conclusions of the ML/FT NRA within their own Business Risk Assessment. During supervisory inspections, authorities routinely review whether a firm’s internal risk analysis, mitigation controls, and governance arrangements demonstrate clear awareness of, and consistency with, the national risk picture. Where this alignment cannot be demonstrated, it is often treated as a weakness in the firm’s risk governance framework.
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UAE Proliferation Financing National Risk Assessment (PF NRA)
Alongside its ML/FT risk review, the UAE has also completed a dedicated Proliferation Financing National Risk Assessment. This assessment examines the country’s exposure to risks linked to the financing of weapons of mass destruction and attempts to bypass international sanctions.
The PF NRA evaluates:
- National-level vulnerabilities to proliferation financing activity
- Sector-specific exposure across financial institutions, DNFBPs, and Virtual Asset Service Providers
- The implementation and effectiveness of Targeted Financial Sanctions
- Risks associated with cross-border trade and goods that may have both civilian and military applications
For Dealers in Precious Metals and Stones, these risks carry particular relevance. The sector’s global trading networks, cross-border counterparties, and involvement in high-value physical commodities can create potential exposure to sanctioned parties or high-risk jurisdictions if not carefully controlled.
Taken together, the ML/FT NRA and PF NRA form the national risk baseline that underpins AML, CFT, and CPF supervision in the UAE. Firms that align their internal frameworks with these assessments are better positioned to demonstrate regulatory maturity and inspection readiness.
AML Legal Framework for DPMS in the UAE
The AML responsibilities that apply to Dealers in Precious Metals and Stones in the UAE originate from the country’s primary AML legislation and its supporting executive framework. These laws establish the legal and operational standards that govern how DPMS firms must manage financial crime risk within their day-to-day business.
The principal legislative instruments include:
Federal Decree Law No. 10 of 2025
This law serves as the foundation of the UAE’s Anti-Money Laundering, Counter-Terrorist Financing, and Counter-Proliferation Financing regime. It strengthens the overall enforcement structure, expands the authority of supervisory bodies, and reinforces the system of administrative penalties. The law defines the fundamental compliance obligations that apply to all reporting entities, including Dealers in Precious Metals and Stones.
Cabinet Resolution No. 134 of 2025
This resolution contains the Executive Regulations of the AML Law and translates the legal framework into detailed, operational requirements. It outlines expectations relating to the risk-based approach, customer due diligence, enhanced due diligence, reporting duties, and supervisory oversight. It also supports greater coordination between competent authorities and provides clarity on how regulated entities are expected to implement compliance controls in practice.
Taken together, these instruments form the mandatory compliance structure that governs the DPMS sector in the UAE.
Under this framework, Dealers in Precious Metals and Stones are required to establish and maintain:
- A formal Business Risk Assessment that is documented and periodically reviewed
- Customer Due Diligence and Enhanced Due Diligence processes aligned with risk exposure
- Ongoing monitoring of transactions to detect unusual or inconsistent activity
- Procedures for submitting Suspicious Transaction Reports through the goAML platform
- Screening measures to comply with Targeted Financial Sanctions requirements
- Record retention systems that meet statutory retention periods
- Defined governance arrangements, including the appointment and accountability of an AML Compliance Officer
These obligations apply directly to the operational reality of the sector. Whether the activity involves retail jewellery sales, wholesale bullion transactions, refining operations, diamond trading, cross-border payments, or corporate-level purchases, firms are expected to apply these controls consistently as part of their business processes.
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Federal and Sector-Specific Guidance for DPMS in the UAE
Primary legislation defines the legal duty. Regulatory guidance explains what that duty looks like when translated into real systems, controls, and daily decision-making.
Dealers in Precious Metals and Stones are required to follow the federal DNFBP guidance issued within the 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 publications emphasise the need for a true risk-based approach. Firms are expected to build risk assessment models that reflect the realities of their business, including transaction patterns, geographic connections, customer profiles, delivery methods, ownership structures, and the specific risks associated with their products. Risk frameworks that rely on generic templates, without meaningful customisation, are often questioned during supervisory reviews.
Alongside the broader DNFBP framework, Dealers in Precious Metals and Stones are also subject to guidance tailored to the risks inherent in their sector.
Supplemental Guidance for Dealers in Precious Metals and Stones, May 2019
This document highlights vulnerabilities specific to the precious metals and stones trade. It addresses risks such as trade-based money laundering, attempts to avoid reporting thresholds through structured transactions, the use of intermediaries to conceal identities, and challenges in identifying true beneficial ownership. It also provides practical indicators and examples that firms are expected to reflect in their internal controls.
Ministry Circular 08/AML/2021
This circular introduced mandatory reporting requirements for certain cash and international wire transactions that exceed defined thresholds. These reports must be submitted through the goAML platform. This requirement exists separately from Suspicious Transaction Reporting, meaning firms must be able to manage both reporting streams simultaneously.
FIU Strategic Analysis Report, September 2025
This report provides insight into recent typologies observed within the sector, including the use of bullion in layering schemes, cross-border movement of value, manipulation of trade pricing, and the use of complex supply chains to obscure financial flows. Supervisory authorities increasingly expect firms to incorporate these typologies into their Business Risk Assessment and monitoring controls. Where risk assessments remain unchanged despite evolving typology information, this is often viewed as a weakness in the firm’s risk management approach.
Core AML Obligations for the DPMS Sector in the UAE
A robust UAE AML compliance framework for DPMS should include the following components.
Business Risk Assessment
Firms must maintain a documented and management-approved Business Risk Assessment aligned with the UAE AML Law, National Risk Assessment findings, and sector risks. It should evaluate customers, geographies, transaction types, delivery channels, and product exposure.
Customer Due Diligence
DPMS must identify and verify customers, establish beneficial ownership, and understand the purpose of the relationship. Corporate ownership structures must be traced and supported with reliable documentation.
Enhanced Due Diligence
Higher-risk relationships, including those involving high-risk jurisdictions, politically exposed persons, or complex structures, require deeper scrutiny. This may include source of funds and source of wealth verification.
Ongoing Monitoring
Firms must review transactions to ensure they align with the customer’s profile. Unusual pricing, structured payments, or unexpected trade routes must be examined and recorded.
Sanctions Screening and Reporting
Customers and counterparties must be screened against UAE sanctions lists. Where suspicion arises, firms must submit Suspicious Transaction Reports through goAML and follow escalation procedures.
Governance and Oversight
Senior management must oversee AML compliance, appoint a Compliance Officer, and maintain clear reporting and documentation demonstrating active supervision.
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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 obscure layering attempts.
- Trade-based money laundering is a persistent vulnerability. Mispricing, complex invoicing chains, discrepancies in shipping documentation, and unusual routing patterns require detailed scrutiny.
- The portability of gold and precious stones enables rapid cross-border movement. Physical transport may bypass traditional banking oversight, increasing reliance on internal controls.
- Corporate buyers may operate through layered offshore structures. Identifying and verifying ultimate beneficial ownership can be complex and resource intensive.
- International counterparties introduce sanctions risk and exposure to high-risk jurisdictions. Firms must maintain effective sanctions screening and geographic risk assessment controls.
Operationally, tension may arise between sales velocity and compliance depth. A culture that prioritises transaction speed over verification increases the likelihood of regulatory findings.
Best Practices for a Strong AML and GRC Architecture
Leading firms integrate AML within a broader Governance, Risk and Compliance framework rather than treating it as a standalone function.
Common best practices include:
- Risk assessment methodologies tailored to bullion trading, refining, wholesale distribution, or retail operations
- Technology-enabled monitoring systems integrated with accounting and ERP platforms
- Real-time sanctions screening solutions
- Structured and independently verified beneficial ownership processes
- Sector-specific training informed by FIU typologies
- Periodic internal audit or independent AML reviews
- Inspection readiness exercises aligned with Ministry methodology
Reputation Is the Most Valuable Asset
The UAE’s ambition as a global trading hub encompasses both physical commodities and digital assets. Its regulatory framework reflects FATF standards and coordinated global supervision.
Within this environment, AML compliance for Dealers in Precious Metals and Stones functions as commercial infrastructure. It protects banking relationships, supports cross-border trade, and reinforces credibility in international markets.
Gold and diamonds can be assessed with technical precision. Governance is evaluated through the strength of internal systems, the consistency of controls, the quality of documentation, and the ability to demonstrate inspection readiness at any time.
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