Do gold refiners need an independent third-party audit in the UAE?
Yes. Gold refiners operating in the UAE are required to arrange an independent third-party audit of their supply-chain due diligence as part of the responsible sourcing framework. The audit tests whether the refiner’s management systems, risk assessment and risk-response measures are actually working, and its findings feed into the public report the refiner must publish each year.
This independent review is a specific requirement of the responsible sourcing regulations and is separate from, but complementary to, the independent audit function that all regulated firms must maintain for their internal AML controls. Together they give supervisors and counterparties assurance that gold entering the UAE market has been checked against conflict, human rights and money laundering risks. Refiners should select auditors with genuine independence from day-to-day compliance operations.
Legal Reference (UAE):
· Ministry of Economy - Due Diligence Regulations for Responsible Sourcing of Gold requires an independent third-party audit within the OECD five-step process.
· Cabinet Resolution No. 134 of 2025, Article 21(6) requires an independent audit function to test internal AML controls.
For more details, consult the Ministry of Economy responsible sourcing regulations or seek guidance from your AML compliance officer.
MoET Supplemental Guidance for Dealers in Precious Metals and Stones