Does Ministerial Decree No. 68 of 2024 on responsible gold sourcing apply to my business?

Does Ministerial Decree No. 68 of 2024 on responsible gold sourcing apply to my business?

Ministerial Decree No. 68 of 2024 concerns the responsible sourcing of gold and applies primarily to gold refineries and other stakeholders in the UAE gold supply chain, including entities operating in commercial free zones under the Ministry of Economy’s supervision. If your business refines gold, recycles gold products, or trades gold along the supply chain, you are very likely within scope.

The decree requires covered entities to adhere to the due diligence policy for responsible sourcing of gold, which follows the OECD five-step framework, and to submit a report on their supply-chain due diligence. It also requires an independent third-party review of those due diligence procedures. This sits alongside, and does not replace, a dealer’s general AML/CFT obligations such as customer due diligence, sanctions screening and suspicious transaction reporting.

Even a dealer that is not a refiner should assess whether it forms part of a covered supply chain, because responsible-sourcing failings can expose the business to both supervisory penalties and reputational harm. Where in doubt, map your gold sourcing and seek supervisory guidance.

Legal Reference (UAE):

· Ministerial Decree No. 68 of 2024, Article One — refiners and covered entities must adhere to the responsible gold sourcing due diligence policy and submit a due diligence report.

· Ministerial Decree No. 68 of 2024, Article Two — an independent review of the due diligence procedures is required.

For more details, consult the Ministry of Economy financial crimes legislations page or seek guidance from your AML compliance officer.

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