Must a dealer in precious metals and stones appoint an AML compliance officer?

UAE
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Yes. Every DNFBP, including a dealer in precious metals and stones, must appoint a compliance officer at management level who has independence in decision-making and the standing, authority and resources to run the AML programme. The role is central to the firm’s obligations and cannot be left vacant or treated as a purely nominal title.

The compliance officer’s duties typically include implementing the firm’s AML policies and controls, overseeing customer due diligence and sanctions screening, reviewing internal alerts, and deciding on and filing suspicious transaction reports and DPMSRs on goAML. In a small dealership the owner or a senior manager may take on the function, but the person appointed must be competent, adequately trained and able to act without conflict. Supervisors expect the appointment to be documented and the officer to be reachable during inspections.

Legal Reference (UAE):

For more details, consult the full text of Cabinet Resolution 134 of 2025 or seek guidance from your AML compliance officer.

AML Policy Drafting for Dealers in Precious Metals and Stones

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Yes, once in scope as a DNFBP. Every financial institution, DNFBP and virtual asset service provider must appoint a compliance officer at management level, under its responsibility, with independence in decision-making and appropriate competence and experience.

The appointment is also a named minimum content of the internal policies, controls and procedures the business must maintain. The role carries five duties: monitoring transactions related to the crime; receiving, examining and assessing suspicious transaction data and deciding in full confidentiality whether to notify the Financial Intelligence Unit or retain the matter with reasons; reviewing the internal systems against the law and reporting periodically to senior management; developing, implementing and documenting training; and cooperating with the supervisory authority and the Unit.

Legal Reference (UAE):

· Cabinet Resolution No. 134 of 2025, Article 22: appointment of a compliance officer at management level with independence in decision-making, and the five duties.

· Cabinet Resolution No. 134 of 2025, Article 21(3): compliance management arrangements as a minimum content of internal policies; Article 3(3): DNFBP status for dealers at or above AED 55,000 in cash.

For your own circumstances, check your internal AML policy or speak to your compliance officer.

In-house AML compliance department setup