Responsible Sourcing Due Diligence Services for Gold Refineries in the UAE

Gold refineries in the UAE face one of the most demanding compliance environments in global precious metals trade. Ministerial Decree No. (68) of 2024 makes OECD-based due diligence mandatory for refiners, recyclers, and supply-chain participants, with penalties up to AED 5 million. A D S Management Tax Consultancy LLChelps refineries build and maintain the documentation, risk assessment, and reporting systems these regulations require without disrupting daily operations.

What the UAE Due Diligence Framework Actually Requires

The Ministry of Economy’s Due Diligence Regulations for Responsible Sourcing of Gold apply to every entity in the UAE gold supply chain, including commercial free zones supervised by the Ministry. The framework follows the OECD Five-Step model, with local enforcement teeth.

Refiners and recyclers carry the heaviest burden. They must implement all five steps: a documented management system, supply-chain risk identification, a risk response strategy, independent third-party audit, and public reporting. Other dealers and supply-chain participants must complete the first three steps.

The regime sits alongside, not instead of, AML/CFT obligations under Federal Decree-Law No. (10) of 2025. This includes filing a Dealers in Precious Metals and Stones Report (DPMSR) for qualifying transactions of AED 55,000 or more.

What Is Responsible Sourcing Due Diligence for Gold Refineries?

Responsible sourcing due diligence is the process of tracing gold back through the supply chain to confirm it does not finance conflict, fund criminal activity, or originate from human rights abuses. For UAE refineries, this means knowing your counterparties, understanding the origin of every consignment, and being able to demonstrate that knowledge to regulators and auditors.

The Ministry describes the sector’s risk rating as inherently high, with refineries identified as the highest-risk sub-segment. Bullion trading, refining, and wholesale are all named as higher-risk activities in the 2026 DPMS guidance.

Building a Compliant Management System

A compliant management system starts with a written responsible sourcing policy incorporating OECD Annex II standards. Senior management must be formally accountable, and an in-house compliance officer should be appointed with clear authority.

The system needs documented chain-of-custody tracking, staff training records, and a confidential grievance mechanism. Records must be retained for at least five years. This is where many refineries struggle: the policy exists on paper, but the day-to-day documentation trail breaks down under pressure.

Your AML policy frame work should integrate with responsible sourcing controls rather than existing as a separate document. The two regimes overlap significantly, particularly around customer due diligence and transaction monitoring.

Identifying and Assessing Supply-Chain Risk

Know Your Counterparty (KYC) is the foundation. Refineries must conduct due diligence before establishing relationships and continuously throughout the trading relationship. This includes identifying beneficial owners, understanding the counterparty’s own sourcing practices, and checking against sanctions lists and adverse media.

Red flags include gold from conflict-affected or high-risk areas, unusual payment arrangements, and counterparties who cannot explain their own supply chain. The assessment must be documented, not assumed.

An EWRA (Enterprise-Wide Risk Assessment) helps refineries map where their specific vulnerabilities lie. A refinery sourcing primarily from large-scale mines faces different risks than one handling recycled material or artisanal output.

How A D S Management Tax Consultancy LLCSupports Gold Refineries

A D S Management Tax Consultancy LLCworks with refineries to translate regulatory requirements into practical, auditable processes.

1. Initial consultation to map your current sourcing practices against Decree 68 requirements

2. Gap assessment covering documentation, KYC procedures, and record-keeping

3. Development or review of your responsible sourcing policy and AML policy frame work

4. Support with AML registration and DPMSR filing obligations, alongside Corporate Tax Registration where applicable

5. Preparation for independent third-party audit

6. Ongoing compliance support as regulations evolve

What the Service Includes

• Review of existing supply-chain documentation and counterparty files

• Assistance drafting responsible sourcing policies aligned with OECD guidance

• KYC procedure design and implementation support

• Staff Aml training tailored to precious metals operations

• Pre-audit readiness reviews for refiners facing annual independent audit

• Guidance on DPMSR reporting thresholds and filing requirements, plus E-Invoicing Consultation for compliant transaction documentation

Benefits of Professional Due Diligence Support

Working with specialists reduces the risk of regulatory penalties and protects your access to international markets. LBMA Good Delivery refiners must meet Responsible Sourcing Programme requirements, and UAE regulators increasingly expect alignment with these global standards.

A well-documented programme also strengthens relationships with banks and international counterparties, who apply their own due diligence to UAE refineries. Weak documentation can restrict access to trade finance even before regulators take action.

Why Choose A D S Management Tax Consultancy LLC

A D S Management Tax Consultancy LLC brings regulatory and compliance expertise specific to UAE precious metals businesses. The team understands how Ministry of Economy requirements intersect with AML obligations, and how to build systems that satisfy both without duplication.

The approach is practical rather than theoretical. Refineries receive step-by-step assistance, clear documentation, and ongoing support as regulations change.

How We Work

1. Free consultation to understand your current sourcing operations

2. Tailored proposal covering the specific gap areas identified

3. Expert execution of documentation, training, and process improvements

4. Ongoing support for audits, regulatory changes, and annual reporting

For practical support with your refinery’s responsible sourcing obligations, Contact A D S Management Tax Consultancy LLC to discuss your current compliance position and next steps.