Are free zone DPMS entities subject to UAE federal AML law?
Yes. Dealers in precious metals and stones (DPMS) operating in the UAE mainland and in commercial free zones are subject to the federal AML framework and are supervised for AML purposes by the Ministry of Economy and Tourism. Being licensed in a commercial free zone does not place a DPMS outside the reach of the AML law.
This means a free-zone DPMS must register on the goAML portal, apply customer due diligence and beneficial owner identification, screen against sanctions lists, retain records for at least five years, and submit Dealers in Precious Metals and Stones Reports and Suspicious Transaction Reports as required. It must also implement internal AML policies approved at management level and support the compliance and reporting function. The supervisory authority can inspect free-zone entities and impose the full range of administrative penalties for breaches.
Financial free zones with their own independent regulators, such as the DIFC and ADGM, operate under separate but equivalent AML regimes overseen by their respective authorities. A DPMS should confirm which supervisor applies to its specific licence, but in all cases robust AML controls are mandatory.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 16 — supervisory authorities oversee DNFBPs within their areas of competence.
· Federal Decree-Law No. 10 of 2025, Article 20 — registration or enrolment required to carry on a DNFBP activity.
For more details, consult the Ministry of Economy financial crimes legislations page or seek guidance from your AML compliance officer.