AML Compliance for Jewellery &
Precious Metals Businesses in UAE
Let's Talk
Free Consultation
AML Compliance for UAE Jewellery & Precious Metals Businesses
The UAE is a major global centre for gold, jewellery, precious metals, and precious stones. However, the characteristics that make these products commercially attractive, including their high value, portability, and international trade, can also create exposure to financial crime risks.
For businesses that fall within the UAE framework for Dealers in Precious Metals and Stones, or DPMS, understanding AML Compliance for Jewellers in UAE is therefore an important part of managing regulatory and financial crime risk.
The requirements are not limited to completing customer checks. They can involve risk assessment, customer due diligence, beneficial ownership, sanctions screening, record keeping, internal controls, and regulatory reporting.
Key AML Compliance Requirements for Gold & Diamond Businesses
Jewellers and other relevant DPMS businesses should apply AML/CFT/CPF measures that reflect their activities, customers, transactions, and identified risks.
Customer Due Diligence, KYC & Beneficial Ownership
Customer Due Diligence, or CDD, involves identifying and verifying customers and, where applicable, the individuals who ultimately own or control legal entities.
Businesses should also understand the purpose and nature of relevant transactions or business relationships and assess the risks involved.
The AED 55,000 threshold is important for covered transactions. However, transactions below that level should not automatically be treated as risk-free. Appropriate risk-based measures may still be necessary where the circumstances indicate elevated risk.
Suspicious Transaction & Activity Reporting
Relevant businesses should have procedures for identifying and escalating transactions or activities that raise reasonable grounds for suspicion.
Where reporting criteria are met, Suspicious Transaction Reports, Suspicious Activity Reports, or other applicable reports are submitted to the UAE Financial Intelligence Unit through the goAML system.
Importantly, a transaction does not become suspicious simply because it has a high value. Businesses should consider the customer, transaction pattern, source and movement of funds, commercial rationale, and other relevant risk indicators.
AML Requirements Across Different UAE Jurisdictions
A DPMS business should identify the AML/CFT/CPF requirements and supervisory framework that apply to its specific jurisdiction and activities.
Businesses operating in mainland UAE, commercial free zones, or financial free zones may be subject to different supervisory arrangements. Therefore, firms should rely on the current requirements of the competent authority relevant to their business rather than assuming that one framework applies identically across every UAE jurisdiction.
Staff Training & Internal Controls
Relevant employees should understand the business's AML procedures and know how to recognise potential red flags.
A suitable compliance framework can include internal policies, escalation procedures, risk controls, designated responsibilities, staff training, and periodic review of the effectiveness of those measures.
Record Keeping & Documentation
DPMS businesses must maintain required customer, transaction, due diligence, and reporting records in accordance with applicable UAE requirements.
For applicable DPMS reporting, records relating to relevant transactions and customer information should generally be retained for the required period, which can include a minimum of five years.
Who Is Required to Comply with AML Laws?
UAE AML/CFT/CPF legislation includes Dealers in Precious Metals and Stones within the Designated Non-Financial Businesses and Professions, or DNFBP, framework.
The DPMS sector can include businesses involved at different stages of the precious metals and stones supply chain, such as:
Precious Metals Businesses
- Gold and precious metal traders
- Precious metal refiners
- Wholesalers
- Retail jewellers
- Manufacturers using precious metals
- Participants in secondary or scrap markets
Precious Stones Businesses
- Diamond dealers
- Precious stone traders
- Jewellery businesses dealing in precious stones
- Cutters and polishers
- Wholesalers and retailers
Other Relevant DPMS Activities
Depending on the nature of the business and products involved, the framework can also extend across other participants in the production, processing, brokerage, manufacture, wholesale, retail, and secondary markets for precious metals and stones.
The exact obligations that apply should be assessed according to the business activity, transaction type, value, risk profile, and relevant supervisory framework.
Understanding the AED 55,000 Threshold
The AED 55,000 threshold is particularly important for the DPMS sector. Under current UAE guidance, it acts as a legal trigger for mandatory AML/CFT/CPF measures on covered transactions.
In addition, specific Dealers in Precious Metals and Stones Reports, or DPMSRs, are required for relevant transactions. These include cash transactions with resident or non-resident individuals of AED 55,000 or more. For transactions with companies or entities, the reporting requirement also covers qualifying transactions of AED 55,000 or more made by cash or wire transfer.
However, the threshold should not be treated as a safe harbour. If a transaction below AED 55,000 presents unusual circumstances or elevated ML/TF/PF risks, proportionate risk-based controls may still be appropriate.
What Happens If You Don't Comply?
Failure to meet applicable AML/CFT/CPF obligations can expose a business to regulatory and legal consequences.
Depending on the nature and seriousness of the breach, consequences may include:
*The consequences depend on the specific breach and the applicable legislation. Therefore, businesses should avoid treating AML compliance as a simple box-ticking exercise.
How Elevate Supports Jewellery Businesses with AML Compliance
Elevate Accounting & Auditing provides professional AML compliance advisory and support services for jewellery and DPMS businesses.
Support can include:
- ✓AML Risk Assessment SupportAssistance in reviewing business and customer risk factors.
- ✓CDD, KYC & Beneficial Ownership ProceduresSupport with developing and reviewing appropriate due diligence processes.
- ✓goAML & Reporting SupportAdministrative and compliance support relating to applicable goAML registration and reporting processes.
- ✓AML Policies & Internal ControlsAssistance with developing or reviewing internal compliance frameworks.
- ✓Staff AML TrainingPractical training and awareness support for relevant employees.
- ✓Compliance ReviewReviewing existing documentation, procedures, and controls to identify potential areas for improvement.
*The precise obligations remain dependent on the business's activities, jurisdiction, transactions, and regulatory circumstances.
Protect Your Jewellery Business with Practical AML Guidance
AML Compliance for Jewellers in UAE involves much more than checking customer identification.
For relevant DPMS businesses, effective compliance means understanding customers, assessing transaction risk, maintaining appropriate records, applying internal controls, identifying suspicious activity, and meeting applicable reporting requirements.
It also requires judgement. A transaction below a reporting threshold can still carry risk, while a high-value transaction is not automatically suspicious simply because of its value.
Elevate Accounting & Auditing can support jewellery and precious metals businesses in reviewing and strengthening their AML/CFT/CPF procedures based on the nature of their operations.
Speak with Elevate Accounting & Auditing to discuss your existing AML framework and the compliance areas that may require further attention.
Frequently Asked Questions
Precious metals and stones can carry significant value, move easily across borders, and sometimes involve cash-intensive trading. These characteristics can create exposure to money laundering and other financial crime risks. Relevant DPMS businesses are therefore subject to UAE AML/CFT/CPF requirements.
The framework can cover participants across the precious metals and stones supply chain, including relevant producers, brokers, refiners, manufacturers, wholesalers, retailers, and participants in secondary or scrap markets. The exact obligations depend on the business activity and circumstances.
No. AED 55,000 triggers mandatory measures for covered transactions, but current UAE guidance makes clear that DPMS businesses should still take proportionate risk-based measures below that threshold when elevated risk is identified.
Depending on the business and transaction, requirements can include risk assessments, CDD, beneficial ownership checks, sanctions screening, record keeping, internal controls, staff training, ongoing monitoring, and applicable reporting through goAML.
Yes. Businesses that fall within the relevant DNFBP and reporting framework should understand their goAML registration and reporting obligations. The platform is used for submitting applicable reports to the UAE Financial Intelligence Unit.
A Dealers in Precious Metals and Stones Report is a specific goAML report used for qualifying DPMS transactions. Reporting requirements vary depending on whether the customer is an individual or an entity and on the payment method involved.
For resident and non-resident individuals, DPMSRs apply to qualifying cash transactions of AED 55,000 or more. For companies and entities, qualifying transactions of AED 55,000 or more can require reporting whether payment is made in cash or through wire transfer.
Potential indicators can include unusual cash activity, unexplained third-party payments, inconsistent customer information, attempts to avoid identification, unusual transaction structures, or activity that does not make commercial sense. A red flag should trigger appropriate review rather than an automatic conclusion of wrongdoing.
CDD involves identifying and verifying customers and, where relevant, beneficial owners. It can also involve understanding the purpose of the transaction or relationship and assessing the customer's financial crime risk.
Enhanced Due Diligence involves additional measures where higher risks are identified. The measures taken should reflect the nature and level of risk rather than applying one identical process to every customer.
Applicable customer, transaction, due diligence, and reporting records generally need to be retained for the period required under UAE AML rules. Relevant DPMS reporting guidance specifies a minimum five-year retention period for records connected with covered transactions.
No. High value alone does not establish suspicion. Businesses should assess the transaction in context, including the customer profile, payment method, commercial rationale, transaction pattern, and other relevant risk factors.
*Service Scope Disclaimer
Elevate Accounting & Auditing supports jewellery and DPMS businesses with AML policies, risk assessments, due diligence processes, training, and reporting procedures. We do not issue regulatory approvals, determine enforcement outcomes, or guarantee that a business will be deemed compliant by a regulator.