What are common AML red flags for dealers in precious metals and stones in the UAE?
Dealers in precious metals and stones face distinctive money-laundering risks because their products are high-value, portable and easily converted to cash. Recognising red flags is central to meeting customer due diligence and reporting obligations in the UAE.
Common warning signs include a customer who insists on settling large purchases in cash, or who breaks a single purchase into several payments that each fall just below the AED 55,000 reporting threshold. Others include reluctance to provide identity or beneficial-owner information, purchases that do not match the customer’s apparent profile or business, third parties paying for or collecting goods without a clear reason, and customers who appear indifferent to price, quality or delivery. Requests to route payment through unrelated jurisdictions, use of shell companies, or a match against a sanctions list are also serious indicators. In the gold supply chain, unclear provenance or sourcing from conflict-affected and high-risk areas raises additional concern.
When a red flag cannot be satisfactorily explained, the dealer must consider filing a Suspicious Transaction Report, which has no value threshold, and must not tip off the customer. Red flags should be documented and staff trained to spot them.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 18(1) — duty to report suspicious transactions to the FIU regardless of value.
· Cabinet Resolution No. 134 of 2025, Article 6 — customer due diligence and ongoing monitoring to detect unusual activity.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.