The threshold sets the minimum. Risk sets the standard.
The March 2026 Supplemental Guidance for Dealers in Precious Metals and Stones (DPMS) from the UAE Ministry of Economy and Tourism (MoE) reinforces the importance of a risk-based approach to Anti-Money Laundering, Counter-Terrorist Financing and Counter-Proliferation Financing (AML/CFT/CPF) compliance.
Three recent developments are relevant for dealers:
- MoE Supplemental Guidance (March 2026): the AED 55,000 threshold is a minimum trigger, not an exemption.
- MoE Circular No. (2) of 2026 (14 September 2026): updated high-risk and increased-monitoring country lists, with measures for DNFBPs.
- Updated UAE Proliferation Financing (PF) National Risk Assessment (NRA) (2026): highlights sanctions-evasion risks, including gold as a revenue source for proliferation networks.
What the AED 55,000 Threshold Does and Does Not Do
Under Cabinet Resolution No. 134 of 2025, dealers in precious metals and stones fall within the scope of Designated Non-Financial Businesses and Professions (DNFBPs) when conducting a single cash transaction, or several linked cash transactions, of AED 55,000 or more.
The threshold is the minimum legal trigger for applying the full AML/CFT/CPF measures. Key points for dealers:
- Linked payments and cash equivalents count. Invoices, deposits and instalments for one purchase are treated together, and cashier’s cheques, money orders and trade-ins are treated like cash.
- Reporting follows the transaction, not the risk rating. A Dealers in Precious Metals and Stones Report (DPMSR) is filed through goAML for qualifying cash transactions with individuals and cash or wire transactions with companies, generally within two weeks, even where customer due diligence (CDD) is satisfactory.
However, the Ministry’s supplemental guidance clarifies that transactions below this threshold should not automatically be regarded as presenting negligible financial crime risks.
Where the nature, pattern or circumstances of a transaction indicate elevated money laundering, terrorist financing or proliferation financing risks, businesses are expected to apply appropriate and proportionate risk-based measures, irrespective of the transaction value. Sanctions screening applies regardless of transaction value.
Why the Sector Receives Extra Attention
The Ministry’s guidance, drawing on the UAE’s national and sector risk assessments, regards bullion trading and refining as higher-risk sub-sectors, with wholesalers exposed to trade-based money laundering (TBML) and retailers to placement and structuring.
The sector’s exposure reflects the high intrinsic value and portability of precious metals and stones, cash-intensive transactions, cross-border trading and intermediaries.
A third UAE NRA, covering money laundering, terrorist financing and proliferation financing, was launched in September 2026. Its findings may inform sector risk ratings, so dealers should watch for its publication.
Six Areas Where Dealers Should Focus
1. Risk-Based CDD
CDD measures should be proportionate to the risks identified. Where a transaction or business relationship presents elevated risk indicators, dealers should consider whether additional verification, enhanced due diligence or further enquiries are warranted.
Typical triggers for enhanced due diligence (EDD) include:
- cash or cash equivalents as the main payment method;
- non-resident customers and politically exposed persons;
- intermediaries or third-party payers without a clear role;
- complex or opaque ownership structures; and
- links to high-risk or increased-monitoring jurisdictions.
Beneficial ownership should be verified beyond the customer’s own statements where risk warrants. The Ministry expects dealers to decline or exit relationships where ownership or source of funds cannot reasonably be verified.
2. Linked, Structured and Third-Party Payments
Businesses should maintain controls to identify transaction patterns that may indicate attempts to circumvent thresholds or conceal suspicious activity. Repeated transactions involving the same customer, unexplained third-party payments or purchasing patterns inconsistent with the customer’s known circumstances may warrant further examination.
Particular attention should be given to transactions that appear connected, even where individual transaction values fall below AED 55,000.
3. Sanctions and High-Risk Countries
Dealers should ensure that applicable targeted financial sanctions obligations are addressed through appropriate screening and escalation procedures. Screening applies regardless of transaction value, and potential matches should be escalated immediately.
MoE Circular No. (2) of 2026 (14 September 2026) updates expectations for high-risk and increased-monitoring jurisdictions. Dealers are expected to:
- check the current FATF and national lists regularly, reflect them in country-risk ratings and due diligence, and revisit countries that have been removed;
- apply EDD to all relationships and transactions involving high-risk (call for action) jurisdictions;
- report internally and, where necessary, file suspicious transaction reports (STRs) with the UAE Financial Intelligence Unit (FIU) through goAML’s high-risk jurisdiction reports; and
- not rely on third parties in high-risk jurisdictions to perform CDD.
Administrative penalties can follow, including for senior management, if these measures are not implemented.
4. Supply Chain and Origin Checks
For gold and stones, origin matters as much as customer identity. Dealers are expected to:
- verify origin with recognised documents, such as Kimberley Process certificates for rough diamonds, customs and shipping records;
- check that declared origin, weight and purity are plausible; and
- treat unverifiable “scrap” claims, unsupported refinery letters and unusual routing as red flags, rejecting shipments that cannot be verified.
5. Reporting: DPMSR, STR and FIU Requests
The DPMSR and suspicion-based reporting are separate obligations: a DPMSR does not replace an STR, and an STR does not replace a DPMSR. Where reasonable grounds for suspicion arise, businesses should assess their obligations to submit a STR or Suspicious Activity Report (SAR) through the UAE Financial Intelligence Unit’s goAML platform, as applicable.
The fact that a transaction falls below AED 55,000 does not, in itself, eliminate the need to assess potentially suspicious activity. STR timeliness and quality are supervisory focus areas.
Dealers registered on goAML may also receive FIU information requests and freeze instructions through the FIU’s Integrated Enquiry Management System (IEMS), using the same login. The MLRO should monitor it and respond by each due date.
6. Governance, Documentation and Internal Controls
An effective AML/CFT/CPF framework requires businesses to demonstrate that identified risks are appropriately assessed, managed and documented. For dealers, this typically means:
- a qualified compliance officer or MLRO, with senior management oversight;
- a documented Business Risk Assessment (BRA), including PF, reviewed regularly and when risks change;
- records kept for at least five years, including certificate numbers, weight, purity and custody of goods;
- regular training on TBML, structuring, third-party payments and sanctions evasion; and
- periodic independent review.
A Note for ADGM-Registered Dealers
ADGM-registered dealers should also note FSRA Notices Nos. 62 and 82 of 2026: the BRA should be documented, approved by senior management and reviewed at least annually and when national risk assessments are updated, with PF risks and sanctions-evasion typologies built into controls and training.
Your Action Checklist
Businesses should consider reviewing their existing controls against the latest updates. A practical starting point:
- Refresh the BRA for the updated PF NRA, and again when the third NRA is published.
- Update country-risk lists and screening.
- Test monitoring for linked, split and cash-equivalent payments below AED 55,000.
- Check DPMSR and STR processes, goAML access and who responds to FIU requests.
- Review origin documentation and refresh staff training on structuring and PF typologies.
How Banks Corporate Services Can Assist
Banks Corporate Services provides AML/CFT/CPF compliance advisory support to businesses operating within the UAE’s regulated non-financial sectors.
Our services include the development and review of AML policies and procedures, business and customer risk assessments, proliferation financing assessments, CDD frameworks, sanctions screening controls, compliance training and independent compliance reviews.
Through a practical and risk-based approach, we assist businesses in identifying compliance gaps, strengthening internal controls and maintaining frameworks aligned with applicable regulatory expectations.
For further information on our compliance advisory services, please contact Banks Corporate Services.
Contact Details
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