AML Obligations for Gold & Bullion Traders in the UAE

This article explains those obligations in simple, practical terms.

 

Why Are Gold & Bullion Traders High Risk?

Gold can be used to:

• Move value across borders discreetly

• Convert illicit cash into legitimate assets

• Bypass traditional banking controls

Because of these risks, bullion dealers fall under the category of Designated Non-Financial Businesses and Professions (DNFBPs) and are closely supervised by UAE regulators.

 

Who Regulates Bullion Traders in the UAE?

Depending on your license and location, bullion traders may be supervised by:

• Ministry of Economy (MOE) – for mainland DNFBPs

• Free Zone Authorities (e.g. DMCC, SRTIP)

• Financial Intelligence Unit (FIU) – for reporting obligations

Regardless of the authority, AML compliance requirements are broadly the same.

 

Core AML Obligations (What You Must Do)

1. Customer Due Diligence (CDD)

You must identify and verify your customers before doing business:

• Passport / Emirates ID for individuals

• Trade license, shareholders, and UBOs for companies

• Understand the purpose and nature of the transaction

For high-risk customers or large cash transactions, Enhanced Due Diligence (EDD) is required.

 

2. Sanctions & PEP Screening

All customers must be screened against:

• Sanctions lists

• Politically Exposed Persons (PEPs)

• Adverse media

This applies to both buyers and sellers of bullion.

 

3. Risk Assessment

You are required to maintain a Business-Wide Risk Assessment (BWRA) that evaluates:

• Customer risk

• Country risk

• Product risk (e.g. cash gold trades)

• Delivery and payment methods

This document must be updated regularly and shown to regulators on request.

 

4. Suspicious Transaction Reporting (goAML)

If you suspect:

• Unusual payment structures

• Cash transactions without economic rationale

• Attempts to avoid KYC

You must file a Suspicious Transaction Report (STR) through the UAE goAML system — without informing the customer.

 

5. Record Keeping

All KYC and transaction records must be kept for at least 5 years, including:

• Identification documents

• Invoices and contracts

• Payment records

• Due diligence notes

 

6. Appointment of an MLRO

Every bullion trading business must appoint a Money Laundering Reporting Officer (MLRO) responsible for:

• AML oversight

• STR reporting

• Regulatory communication

• Staff training

 

7. AML Training & Independent Audit

• Staff must receive annual AML training

• An independent AML audit is required periodically to assess compliance effectiveness

These are frequently reviewed during inspections.

 

Penalties for Non-Compliance

Failure to comply can result in:

• Heavy financial penalties

• License suspension or cancellation

• Criminal liability in serious cases

• Reputational damage with banks and suppliers

 

Final Thoughts

AML compliance for gold and bullion traders is not optional in the UAE. However, when implemented correctly, it:

• Protects your business

• Strengthens banking relationships

• Builds long-term credibility

A well-structured AML framework is not a burden — it is a business safeguard.