Anti-Money Laundering for Gold Traders: What Are Your Obligations in the UAE?

If you own a gold shop, a jewellery trading company or a refinery in the UAE and you are asking about anti-money laundering for gold dealers, the direct answer is this: you are one of the Designated Non-Financial Businesses and Professions supervised by the Ministry of Economy and Tourism, and you carry five core obligations: registering on the goAML system and the Executive Office notification system; verifying the identity of the customer and the beneficial owner for every cash transaction equal to or above AED 55,000, whether a single transaction or several that appear linked; filing the Dealers in Precious Metals and Stones Report (DPMSR) for those transactions; reporting any suspicious transaction immediately regardless of its value; and keeping records for five years while appointing a compliance officer and documenting a written risk assessment. A breach of any of these exposes you to an administrative fine of up to AED 5,000,000 per violation, and can reach licence cancellation and criminal prosecution.

In this article, AWADH ALMHEIRI LAW FIRM AND LEGAL CONSULTATIONS explains the anti-money laundering obligations of gold and jewellery dealers under the new 2025 Decree-Law and its Executive Regulation, and what a dealer should do when an inspection notice or a fine decision arrives.

Is a gold shop covered by the UAE anti-money laundering law?

Yes. Under Federal Decree-Law No. 10 of 2025 on Combating Money Laundering Crimes, the Financing of Terrorism and the Financing of Proliferation, and its Executive Regulation issued by Cabinet Decision No. 134 of 2025, dealers in precious metals and stones are Designated Non-Financial Businesses and Professions whenever they carry out any single cash transaction, or several transactions that appear linked, equal to or above AED 55,000. This covers the retail shop, the wholesaler, the jewellery manufacturer, the refinery and the bullion trader, whether licensed on the mainland or in a non-financial free zone.

The supervisory authority for this sector is the Ministry of Economy and Tourism, which inspects and imposes sanctions, while the Financial Intelligence Unit receives reports through goAML. If you are setting up a new gold business, registration in the AML framework starts with the licence, not after it.

Obligation one: registering on goAML and the Executive Office system

You cannot report a suspicious transaction or file a DPMSR unless your establishment is registered on the goAML system of the Financial Intelligence Unit, and also on the notification system of the Executive Office for Anti-Money Laundering to receive sanctions-list updates. Under Ministerial Decision No. 253 of 2025, licensing authorities themselves are now obliged to classify gold and jewellery activities within this category and to screen the names of partners, managers and beneficial owners against sanctions lists when a licence is issued or amended.

More seriously, the Decree-Law prohibits practising any designated non-financial business without registration with the supervisory authority, and punishes it with imprisonment and a fine of AED 200,000 to AED 10,000,000 or either of them. Selling gold for large amounts of cash without registration is a crime, not merely an administrative irregularity.

Customer due diligence: when must you ask for ID, and who is the beneficial owner?

The Executive Regulation requires customer due diligence in four situations: when a continuing business relationship begins; when an occasional transaction equal to or above AED 55,000 is carried out, singly or through several transactions that appear linked; when there is any suspicion of crime regardless of the amount; and when there is doubt about the accuracy of data obtained earlier. The measures include the full name, address, nationality and date of birth, with a copy of a valid identity card or passport.

If the buyer or seller is a company, a photocopy of the trade licence is not enough; you must identify the beneficial owner, the natural person who ultimately owns or controls the company, in line with Cabinet Decision No. 109 of 2023 on beneficial owner procedures. Any dealing under an anonymous, fictitious or assumed name is strictly prohibited. Ministry of Economy and Tourism Circular No. 6 of 2025 confirms that due diligence is risk-based: enhanced due diligence for high-risk customers such as politically exposed persons or customers from high-risk countries, standard due diligence for medium-risk customers, and simplified due diligence for low-risk customers where there is no suspicion. To see how a gold dispute turns into a crime, read Fraud in Gold Trading in the UAE.

The DPMSR report and suspicious transaction reporting through goAML

Under Ministry of Economy Circular 08/AML/2021, dealers in precious metals and stones must file a Dealers in Precious Metals and Stones Report (DPMSR) through goAML in three cases: cash transactions with resident individuals equal to or above AED 55,000; cash transactions with non-resident individuals at the same threshold; and transactions with companies equal to or above AED 55,000 whether in cash or by wire transfer. This is a routine record of a large transaction, not a suspicion report, and failing to file it is a violation in its own right.

The suspicious transaction report is a separate obligation: whenever there are reasonable grounds to suspect that funds are proceeds of a crime, you must inform the Financial Intelligence Unit without delay through the electronic system, whatever the value of the transaction and without invoking customer confidentiality. You and your staff are prohibited from tipping off the customer that a report has been filed or that an investigation is under way; the penalty is imprisonment and a fine of no less than AED 50,000. You must also freeze the funds of any person or entity appearing on sanctions lists without delay, which Ministerial Decision No. 253 of 2025 defines as twenty-four hours from listing.

Compliance officer, risk assessment and five-year record keeping

The Decree-Law obliges every covered establishment to identify, assess, document and continuously update the crime risks in its business, and to keep the risk assessment and present it to the supervisory authority on request. That means a written document classifying customers by nationality, product and payment channel and setting the level of due diligence for each class. You must also adopt internal policies approved by senior management applied across all branches, appoint a compliance officer and train staff.

All records and documents relating to transactions and due diligence must be kept for at least five years from the date the transaction was completed or the business relationship ended, and be available to the authorities urgently on request. These same records are what you will need later in any tax audit or VAT dispute over gold; one system serves both obligations.

Penalties: what happens to a gold dealer who breaches AML obligations?

Penalties run on two levels. The administrative level is imposed by the Ministry of Economy and Tourism without a court and starts with a warning, then an administrative fine of AED 10,000 to AED 5,000,000 per violation, doubled for repetition within a year, and extends to barring the offender from the sector, restricting managers' powers, suspending the activity, cancelling the licence and publishing the sanction. Cabinet Decision No. 71 of 2024 unified the list of violations and fines the Ministry of Economy applies to this sector.

The criminal level is harsher: whoever wilfully or through gross negligence breaches the duty to report a suspicious transaction is punished with imprisonment and a fine of AED 100,000 to AED 1,000,000 or either; whoever deliberately provides false beneficial-owner information or breaches targeted financial sanctions instructions faces imprisonment and a fine of no less than AED 20,000. If the dealer is found to have committed money laundering itself, the penalty is one to ten years' imprisonment and a fine of AED 100,000 to AED 5,000,000 or the value of the funds involved, whichever is higher; the company's fine reaches AED 100,000,000 with possible dissolution and closure, and a foreigner is deported by law. To see what happens in practice when proceedings begin, read What to do if a complaint is filed against you at Dubai Police and Referral to the Public Prosecution and detention, and remember that a company manager may be personally liable, as explained in the responsibility of an LLC manager.

Common mistakes of gold shops in Dubai

Inspections keep surfacing the same mistakes: splitting one sale into several invoices under AED 55,000 to avoid asking for ID, which the law treats as linked transactions and penalises; accepting cash from someone other than the buyer named on the invoice without verifying the connection; relying on a photocopy of a company's trade licence without reaching the beneficial owner; not screening customers against sanctions lists, or screening once without following updates; registering on goAML without ever filing a DPMSR despite selling bullion for cash; and keeping invoices without copies of the IDs. Each is a separate violation with its own fine.

I received an inspection notice or a fine decision from the Ministry of Economy: what should I do?

Practical tips for gold and jewellery dealers

Legal references

• Federal Decree-Law No. 10 of 2025 on Combating Money Laundering Crimes, the Financing of Terrorism and the Financing of Proliferation

• Cabinet Decision No. 134 of 2025 on the Executive Regulation of Federal Decree-Law No. 10 of 2025

• Cabinet Decision No. 109 of 2023 on Regulating Beneficial Owner Procedures

• Cabinet Decision No. 74 of 2020 on the Terrorism Lists System and Implementation of the relevant Security Council Resolutions

• Cabinet Decision No. 71 of 2024 on the Unified List of Violations and Administrative Fines for AML breaches by entities supervised by the Ministry of Justice and the Ministry of Economy

• Ministerial Decision No. 253 of 2025 on the Controls and Conditions for Registering Designated Non-Financial Businesses and Professions by Licensing Authorities

• Ministry of Economy Circular No. 08/AML/2021 on goAML Reporting Requirements for Dealers in Precious Metals and Stones

• Ministry of Economy and Tourism Circular No. 6 of 2025 on Risk-Based Customer Due Diligence Measures

• Federal Law No. 11 of 2015 on the Control of Trading in Precious Stones and Metals and their Hallmarking, and its Executive Regulation issued by Cabinet Decision No. 45 of 2018

• Federal Decree-Law No. 31 of 2021 Issuing the Crimes and Penalties Law, as amended

Frequently asked questions on anti-money laundering for gold dealers

If you do not know whether a report or case exists in your name, read How do I know if I have a case or report in the UAE, and to understand the effect of a case on your movement read Lifting a travel ban in the UAE.