What are the OECD five-step due diligence requirements for responsible gold sourcing in the UAE?
The UAE’s Due Diligence Regulations for the responsible sourcing of gold are built on the OECD’s five-step framework for responsible supply chains of minerals from conflict-affected and high-risk areas. Refiners and covered gold-sector entities must implement all five steps.
The five steps are: first, establish an effective company governance and management system, including a supply-chain policy; second, identify and assess risks in the supply chain, paying particular attention to gold sourced from conflict-affected and high-risk areas; third, design and implement a strategy to respond to and mitigate identified risks; fourth, arrange an independent third-party audit of the entity’s due diligence at identified points in the supply chain; and fifth, report publicly and periodically on supply-chain due diligence.
These steps are risk-based and continuous rather than a one-off exercise: governance systems must be maintained and reviewed, and risk assessments repeated as sourcing changes. They complement the dealer’s core AML/CFT controls, including know-your-counterparty checks and beneficial owner identification, and support the wider integrity of the UAE gold market.
Legal Reference (UAE):
· Ministerial Decree No. 68 of 2024, Article One — adherence to the responsible gold sourcing due diligence policy following the OECD guidance.
· Federal Decree-Law No. 10 of 2025, Article 19(1)(a) — risk-based identification, assessment and documentation of ML/TF/PF risks.
For more details, consult the Ministry of Economy financial crimes legislations page or seek guidance from your AML compliance officer.