Must a sole proprietor jeweller in the UAE comply with AML obligations?
Yes. AML obligations in the UAE apply to the activity, not the size or legal form of the business. A sole proprietor jeweller who deals in precious metals and stones is a Designated Non-Financial Business or Profession (DNFBP) and must meet the same core AML/CFT requirements as a larger company.
In practice this means the sole proprietor must register on the Financial Intelligence Unit’s goAML portal, apply customer due diligence and identify beneficial owners, screen customers against sanctions lists, keep records for at least five years, file Dealers in Precious Metals and Stones Reports for designated transactions of AED 55,000 or more, and file Suspicious Transaction Reports whenever suspicion arises. The proprietor must also put in place written internal AML policies and procedures approved at management level, and effectively perform, or appoint someone to perform, the compliance and reporting function. Operating without the required registration is itself a breach of the AML law.
Being small does not reduce the legal duty, though the risk-based approach allows controls to be proportionate to the actual risk the business faces. Supervisory penalties apply equally to sole proprietors.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 20 — no person may carry on a DNFBP activity without registration or enrolment.
· Cabinet Resolution No. 134 of 2025, Article 21 — internal policies and appointment of a compliance officer at management level.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.