DPMS AML & CFT Requirements for Gold Businesses in the UAE

“Businesses operating as Dealers in Precious Metals and Stones (DPMS) may fall within the UAE’s Designated Non-Financial Businesses and Professions (DNFBP) framework and become subject to applicable anti-money laundering (AML) and counter-financing of terrorism (CFT) obligations.

 Gold and precious metals businesses must obtain the appropriate commercial licence from the relevant licensing authority, while businesses falling within the DPMS DNFBP framework must comply with applicable federal AML/CFT requirements. 

The UAE Ministry of Economy oversees AML/CFT supervision for relevant DNFBP sectors, while licensing authorities such as DMCC provide commercial licensing for businesses established within their respective jurisdictions. ADS Auditors helps gold traders, refiners, jewellery manufacturers and precious metals businesses in Dubai and Abu Dhabi develop practical AML/CFT frameworks aligned with applicable UAE requirements.  

Core obligations every DPMS gold licence holder must meet

The UAE Ministry of Economy regulates gold trade federally; DPMS provides the physical and commercial ecosystem. Compliance sits with the licence holder. Main duties:

• goAML registration with the UAE Financial Intelligence Unit

• Appointment of a Compliance Officer responsible for AML/CFT compliance

• Customer due diligence (CDD) and enhanced due diligence (EDD) for high-risk counterparties

• Suspicious Transaction Report (STR) filing through goAML

• Record keeping for a minimum of five years

• A documented AML Policy Framework supported by an Entity-Wide Risk Assessment (EWRA), regular AML training, ongoing transaction monitoring, periodic AML audits, and regular policy reviews and updates.

Gold dealers fall under Dealer in Precious Metals and Stones (DPMS) rules, triggering additional scrutiny for cash transactions and cross-border counterparties. The UAE Good Delivery (UAEGD) standard sets responsible sourcing expectations intersecting with AML controls, particularly supply chain verification.

How AML Registration and goAML fit together

AML Registration is the gateway obligation. Without it, a DPMS gold licence holder cannot demonstrate compliance to banks, auditors or regulators. The goAML portal operated by the UAE FIU handles registration, STR filing, and transaction reporting. Common mistakes include failing to appoint a Compliance Officer or assuming that compliance responsibilities end after registration. goAML access must be maintained, user permissions reviewed, and contact details kept up to date.

The Compliance Officer must be sufficiently independent to escalate concerns, familiar with gold trade typologies, and able to document decisions. Appointing a Compliance Officer who does not actively review transactions or address compliance risks can expose the business to regulatory scrutiny and potential compliance failures.

The EWRA requirement and why it matters for gold traders

An Enterprise-Wide Risk Assessment (EWRA) is the foundation document for any credible AML/CFT programme. For a DPMS gold licence holder, it must reflect precious metals trading risks: high-value portable assets, cash-intensive transactions, cross-border counterparties, politically exposed persons and jurisdictions with weaker controls.

A generic EWRA copied from another sector will not satisfy a regulator or a bank conducting enhanced due diligence. The assessment should map customer types, delivery channels, geographic exposure and product lines, then assign risk ratings and corresponding controls. Gold refiners face different risks than jewellery retailers, and the EWRA should show that distinction.

Building an AML Policy Framework that actually works

The AML Policy Framework translates the EWRA into day-to-day procedures, typically covering:

• Customer identification and verification standards

• Beneficial ownership checks

• Transaction monitoring thresholds and escalation rules

• Cash handling limits and reporting triggers

• Sanctions screening procedures

• Record retention protocols

• Internal reporting channels for staff

The framework should be plain language staff can follow, not unread legal boilerplate. Regulators and banks test whether policies match actual practice, so a polished document with no operational backing is a liability.

AML Training for staff at every level

AML Training is mandatory for all employees whose roles touch customers, payments, shipments or compliance, including front-office sales staff, logistics coordinators and senior management. Training should cover gold-specific red flags: unusually large cash payments, third-party funders, requests to split transactions, vague beneficial ownership structures and reluctance to provide source-of-funds evidence.

Refresher training should occur at least annually and whenever regulations change or new products launch. Documented attendance records form part of the compliance file and are routinely requested during audits and bank reviews.

Common compliance gaps that trigger enforcement

Recurring issues surface in DPMS gold licence reviews. Incomplete CDD files are the most frequent finding, often because staff collect identification documents but never verify beneficial ownership or screen against sanctions lists. Another gap is treating STR filing as optional when a transaction seems too small; the obligation attaches to suspicion, not transaction size. Cash threshold reporting under DPMS rules is also frequently missed, particularly where businesses split receipts across multiple invoices.

Banks are the de facto first line of enforcement. A gold trader with weak AML documentation will struggle to open or maintain corporate accounts, regardless of how clean the underlying business is. Compliance is a commercial necessity, not just a regulatory box to tick.

How ADS Auditors supports DPMS gold licence holders

ADS Auditors works with gold traders and precious metals businesses across Dubai and Abu Dhabi to design, document and maintain AML/CFT programmes. The approach starts with a gap review against current UAE obligations, then moves into EWRA preparation, AML Policy Framework drafting, goAML registration support and staff AML Training. Ongoing support includes transaction monitoring guidance, STR filing assistance and regulatory update briefings so compliance stays current as rules evolve.

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