The UAE is a global powerhouse in the gold and jewellery trade, with major hubs like Dubai playing a pivotal role in international bullion trading and precious stone commerce. From refineries and bullion traders to luxury retailers and jewellery manufacturers, the sector is both economically significant and vulnerable to misuse for money laundering and terrorist financing.

Recognizing these risks, the UAE Ministry of Economy, in alignment with FATF recommendations, has placed the Gold & Jewellery Industry under heightened regulatory supervision. Entities operating in this space must now implement effective AML risk management frameworks to ensure compliance and preserve the sector’s integrity.

Why the Gold & Jewellery Industry Faces High AML Risks

The precious metals and stones sector is designated high-risk due to:

  • The high value and portability of products
  • Cash-intensive transactions that may lack transparency
  • Cross-border trade with limited traceability
  • Complex supply chains that can obscure the source of origin
  • Historical misuse in sanctions evasion and trade-based money laundering

In the UAE, all Dealers in Precious Metals and Stones (DPMS) are classified as Designated Non-Financial Businesses and Professions (DNFBPs), making them subject to stringent AML/CFT regulations.

Key AML Risk Management Measures for Jewellery and Gold Businesses in the UAE

1. Customer Due Diligence (CDD) and Risk Assessment

Jewellers, gold traders, and refineries must perform risk-based due diligence on all customers and counterparties, including:

  • Verifying identity and Ultimate Beneficial Ownership (UBO)
  • Understanding the nature and purpose of the transaction
  • Identifying politically exposed persons (PEPs)
  • Assessing geographic risks (e.g., high-risk jurisdictions)

High-risk clients must be subjected to Enhanced Due Diligence (EDD), with additional scrutiny on the source of funds.

2. Transaction Monitoring and Documentation

All transactions—especially those involving cash payments or high-value trades—must be closely monitored. Businesses must record:

  • Product details (type, weight, purity, etc.)
  • Invoice values and payment method
  • Customer identification documents
  • Supporting transaction records

These documents must be retained for a minimum of 5 years.

3. goAML Reporting and DPMSR Upload

All DPMS entities must register with the UAE FIU’s goAML platform and submit:

  • Designated Non-Financial Businesses and Professions Suspicious Reports (DPMSR)
  • Suspicious Transaction Reports (STRs) or Suspicious Activity Reports (SARs) where applicable

WinGuardAML simplifies compliance by enabling the automated upload of DPMSR reports, reducing reporting delays and human error.

4. Internal Controls and Staff Training

Gold and jewellery businesses must establish internal AML policies, appoint a Compliance Officer, and train employees to detect suspicious activity, such as:

  • Structuring transactions to avoid detection
  • Reluctance to provide KYC information
  • Payments from unrelated third parties
  • Transactions with unclear or unverifiable funding sources

5. Supply Chain Due Diligence

Especially for refiners and wholesalers, conducting due diligence on suppliers and origin of goods is critical. This includes:

  • Verifying documents of origin and ethical sourcing
  • Screening counterparties against sanctions lists
  • Avoiding supply from conflict zones or embargoed countries

Adopting international standards like the OECD Due Diligence Guidance and aligning with UAE Good Delivery principles helps protect the business from reputational and regulatory risks.

Conclusion

The gold and jewellery sector is a cornerstone of the UAE economy—but it’s also a focal point for financial crime risk. As such, businesses must take a proactive, structured approach to AML risk management by combining regulatory awareness with intelligent compliance technology.

WinGuardAML provides specialized tools for the UAE’s DPMS community, including automated screening, risk profiling, and goAML DPMSR uploads—empowering businesses to remain compliant, reduce risk exposure, and contribute to the integrity of the UAE’s financial system.