AML Regulations DPMS UAE

Dealers in Precious Metals and Stones (DPMS) in the UAE are classified as Designated Non-Financial Businesses and Professions (DNFBPs) and must comply with the applicable AML/CFT/CPF framework, including Federal Decree-Law No. 10 of 2025, Cabinet Resolution No. 134 of 2025, and relevant supervisory guidance. Businesses involved in buying or selling precious metals and stones must assess their applicable obligations, complete AML registration where required, conduct customer due diligence, report suspicious transactions, and maintain records in accordance with the applicable legal requirements. ADS Auditors supports DPMS businesses with AML registration, risk assessment, policy development, and compliance training.

What the DPMS Compliance Baseline Actually Covers

UAE AML rules for DPMS businesses rest on several obligations that apply regardless of company size. A sole proprietorship in the Gold Souk carries the same core duties as a larger diamond trading firm.

The AED 55,000 trigger applies to single cash transactions or a series of connected transactions that appear deliberately split. When a customer reaches this threshold, the business must verify identity, understand the purpose of the transaction, and file a Designated Precious Metals and Stones Report (DPMSR) through goAML. Below that amount, CDD may still be needed if there is any suspicion, a sanctions match, or unusual payment behaviour.

Suspicious Transaction Reports work differently. An STR must be filed whenever there are reasonable grounds to suspect money laundering, terrorist financing, or proliferation financing, regardless of transaction value. A customer paying AED 20,000 in small mixed notes, refusing proof of identity, or showing no concern about price can justify an STR even though the threshold was never crossed.

Where Most DPMS Businesses Fall Short

The compliance gap is rarely about bad intent. It is usually about treating the AED 55,000 figure as a simple checkout rule rather than a risk trigger. Structuring, where a customer splits a purchase into several smaller payments to stay under the threshold, is one of the most common detection patterns. A customer who buys AED 54,000 worth of gold on Tuesday and returns Thursday for another AED 40,000 purchase is not necessarily laundering, but the pattern requires documented assessment.

Another weak point is the AML Policy Framework. Many businesses copy a generic template that mentions banks and wire transfers but says nothing about walk-in cash buyers, bullion buybacks, or trade-ins. Regulators expect policies that reflect the actual business model. An Enterprise-Wide Risk Assessment (EWRA) should map how the business is exposed through its customer base, product mix, delivery channels, and geographic reach. A jeweller selling high-value investment bars to international buyers has a different risk profile from one selling bridal jewellery to local residents, and the EWRA must show that difference.

AML Training is also frequently treated as a one-time onboarding formality. Staff who handle sales need practical instruction on spotting structuring, recognising reluctant identification, and understanding when to escalate internally. Training works best when it uses real scenarios from the jewellery trade, not generic banking examples.

How ADS Auditors Approaches DPMS Compliance

ADS Auditors works with DPMS businesses across Dubai and Abu Dhabi to build compliance that fits the operation rather than forcing a bank-style program onto a retail jewellery environment.

1. Initial consultation to understand the business model, customer base, and current compliance posture

2. Gap assessment against Federal Decree-Law No. 10 of 2025, Cabinet Resolution No. 134 of 2025, and applicable supervisory guidance.

3. Enterprise-Wide Risk Assessment covering money laundering, terrorist financing, and proliferation financing risks

4. Development or revision of the AML Policy Framework, tailored to the actual trade flows

5. AML Registration support, including goAML portal setup and user guidance

6. Staff AML Training with jewellery-specific scenarios and structuring red flags

7. Assistance with DPMSR and STR preparation and filing

8. Ongoing support for regulatory updates and inspection readiness

The service includes document review, CDD procedure design, record-keeping setup, and advisory support when a suspicious transaction needs assessment. ADS Auditors does not guarantee regulatory outcomes, but the structured approach reduces the likelihood of avoidable findings during supervisory reviews.

Practical Steps DPMS Businesses Can Take Now

Review the most recent three months of cash transactions and look for customers who repeatedly transacted just below AED 55,000. If patterns emerge, document the assessment and strengthen the CDD file for those customers.

Check that the goAML registration is active and that at least two authorised users can access the portal. A common operational failure is having only one registered user who leaves the company, cutting off reporting capability.

Update the AML Policy Framework to reflect current operations, not a template written years ago. If the business has added bullion buyback, online sales, or international shipping since the last policy update, the framework is outdated.

Schedule AML Training for all customer-facing staff before the next peak season. Gold Souk retailers and high-street jewellers both see seasonal spikes that attract opportunistic structuring attempts.

For businesses unsure whether their activities fall within DPMS scope, or those preparing for a supervisory inspection, professional assessment through ADS Auditors provides a practical starting point without disrupting trade.

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