Do instalment payments trigger DPMSR reporting for a UAE precious metals dealer?
Yes. Instalment payments are aggregated for the purpose of the Dealers in Precious Metals and Stones Report (DPMSR) threshold in the UAE. A dealer cannot avoid reporting simply by splitting a single sale into smaller payments below AED 55,000.
Where a customer settles a purchase through cash instalments (for both individuals and corporate customers) or by wire transfer (for corporate customers), the dealer must add the linked payments together. Once the accumulated value reaches or exceeds AED 55,000, the transaction becomes a designated transaction and a DPMSR must be filed on goAML within two weeks of the payment that crosses the threshold. Deliberate structuring of payments to stay under the threshold is itself a red flag that may warrant a separate Suspicious Transaction Report.
Dealers should therefore track running balances against each customer and sale, not just individual receipts. Robust record-keeping is essential both to identify when the threshold is crossed and to evidence the report to the supervisory authority.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025, Article 25 — retain transaction and due diligence records for at least five years.
· Federal Decree-Law No. 10 of 2025, Article 18(1) — suspicion-based reporting applies regardless of transaction value.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.