goAML Reporting for Precious Metals Dealers: Common Mistakes

Yet, despite awareness, many bullion businesses make serious and avoidable mistakes when it comes to goAML reporting—mistakes that can result in regulatory penalties, audits, or license complications.

Below are the most common errors seen in the precious metals sector, and how to avoid them.

 

1. Believing goAML Is Only for Banks

One of the most frequent misconceptions is that goAML reporting applies only to banks or financial institutions.

In reality, dealers in precious metals and stones (DPMS) are classified as Designated Non-Financial Businesses and Professions (DNFBPs) and are fully subject to:

• Suspicious Transaction Reports (STRs)

• Suspicious Activity Reports (SARs)

• Mandatory registration on the goAML portal

Failing to register or report because “we are not a bank” is a serious compliance breach.

 

2. Reporting Only Confirmed Criminal Activity

Many bullion dealers delay reporting because they believe they must first prove wrongdoing.

This is incorrect.

UAE AML law requires reporting based on reasonable suspicion, not confirmed evidence. Examples include:

• Unusual transaction sizes

• Repeated cash transactions with no clear business rationale

• Reluctance to provide source-of-funds information

Waiting for certainty often results in late or missed reports, which regulators treat as non-compliance.

 

3. Confusing Threshold Reporting with Suspicion

Another common mistake is assuming that only transactions above a certain value must be reported.

In fact:

• Thresholds apply to internal controls

• Suspicion overrides transaction value

A small transaction that appears unusual, structured, or inconsistent with customer behavior must still be reported via goAML—even if it falls below internal or cash thresholds.

 

4. Poor Quality or Incomplete Reports

Submitting a report is not enough. Regulators frequently identify:

• Vague descriptions

• Missing customer details

• No explanation of why the activity is suspicious

A weak report undermines its purpose and exposes the business to follow-up scrutiny.

A proper goAML report should clearly explain:

• Who is involved

• What happened

• Why it is suspicious

• How the transaction deviates from normal behavior

 

5. Delaying Reports for Internal Approval

Some companies hold suspicious cases internally for extended discussions, management approvals, or legal reviews.

While internal escalation is important, unjustified delays are risky. goAML reports must be filed promptly once suspicion arises.

Delays can be interpreted as:

• Intentional suppression

• Poor AML governance

• Lack of compliance independence

 

6. Failure to Maintain Confidentiality

A critical rule under UAE AML law is tipping-off prohibition.

Common violations include:

• Informing customers that a report will be filed

• Asking follow-up questions after suspicion is triggered

• Changing customer treatment in an obvious way

Any indication that a report has been or will be filed can lead to serious legal consequences.

 

7. Treating goAML as a “One-Time” Task

Some bullion dealers register on goAML but fail to:

• Keep user access updated

• Train staff on reporting triggers

• Test internal reporting workflows

goAML is not a checkbox exercise—it must be embedded into daily operations, especially in high-risk sectors like bullion trading.

 

What Regulators Expect from Bullion Dealers

UAE authorities expect precious metals dealers to demonstrate:

• A clear internal escalation process

• Trained staff who can identify red flags

• Timely, well-documented goAML submissions

• Independent oversight by a Compliance Officer

Failure in reporting is often viewed more seriously than the suspicious transaction itself.

 

Final Thought

For bullion dealers, goAML reporting is a front-line defense, not an administrative burden. Most enforcement actions arise not from criminal intent, but from poor reporting culture and weak internal controls.

Getting goAML right protects your license, your reputation, and your long-term ability to operate in the UAE’s regulated precious metals market.