What AML obligations apply to dealers in precious metals and stones in the UAE?
DPMS businesses in the UAE must adhere to AML and CFT regulations and requirements, including reporting suspicious transactions, meeting cash threshold reporting obligations, and implementing the Responsible Sourcing policy. These sit on top of the general reporting entity obligations that apply to all DNFBPs.
The cash threshold reporting obligation is the one most specific to the sector. Where a DPMS carries out a transaction in cash at or above the prescribed threshold, or a series of linked transactions reaching it, a report is required regardless of whether anything about the transaction is suspicious. That is a separate duty from suspicious transaction reporting, which has no threshold at all.
The Responsible Sourcing policy addresses the supply side rather than the customer side. It obliges dealers and refiners to establish where their material originated, which is the control that addresses smuggled gold entering the legitimate market.
Legal Reference (source document and governing law):
· UAE Money Laundering and Terrorist Financing National Risk Assessment, 2nd NRA (2024)
· Federal Decree-Law No. 10 of 2025 on AML/CFT and Financing of Illegal Organisations
· Cabinet Resolution No. 134 of 2025, Executive Regulations
Scope note: cash threshold amounts and the DPMSR filing mechanism are set by the Ministry of Economy and the UAEFIU. Confirm the current threshold before filing.
Further reading: How to file the DPMS report in the UAE
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