Why this matters now
The Ministry of Economy and Tourism (the Ministry, formerly the Ministry of Economy) supervises dealers in precious metals and stones (DPMS) for anti-money laundering purposes. It describes the sector's risk rating as inherently "high" and identifies refineries as the highest-risk sub-segment. Its 2026 guidance for DPMS also names bullion trading, refining and wholesale as higher-risk sub-sectors. It points to the opacity of where goods come from and to supply chains that cross several jurisdictions.
Responsible sourcing is the Ministry's response to that risk across the supply chain. The question it asks is simple: do you know where your gold comes from, and can you show it?
This guide covers the UAE federal regime, including commercial free zones supervised by the Ministry. It does not cover firms in the DIFC or ADGM.
The legal framework in brief
Ministerial Decree No. (68) of 2024. This is the core instrument. Its full title is Ministerial Decree No. (68) of 2024 Regarding Gold Refineries' adherence to the Policy of Due Diligence Regulations for Responsible Sourcing of Gold ("Decree 68"). It was signed on 29 March 2024 and took effect on the date of issue. It requires those in scope to follow the procedures in the Ministry's due diligence policy, which is attached to the decree (the "Regulations"). Its legal bases include Federal Law No. (11) of 2015 Concerning Monitoring Trade in Precious Metals and its Stamping.
The Regulations. These are a set of policies and procedures to identify and reduce risks when importing gold from conflict-affected and high-risk areas (CAHRAs). They follow the five-step framework issued by the Organisation for Economic Co-operation and Development (OECD).
Circular No. (2) of 2024. This circular was issued to licensed gold refineries on the same date as the decree. It confirms that every entity with gold refining as an activity on its licence must carry out the five-step framework.
The AML/CFT framework. The Ministry was designated as supervisor of designated non-financial businesses and professions (DNFBPs) by Cabinet decisions in 2019. Under Federal Decree-Law No. (10) of 2025 and its Executive Regulations (Cabinet Resolution No. (134) of 2025), DPMS fall within the DNFBP category.
Who is in scope
Decree 68 applies to:
- all entities that refine gold or recycle gold products; and
- stakeholders in the gold supply chain operating in the UAE, including commercial free zones subject to the Ministry's supervision.
The decree is framed by activity. It does not set a volume threshold below which a business falls outside its scope. It sets two tiers of obligation:
The five steps, in practice
Below are the five steps as the Ministry lists them. Under each step we set out what the rules require, followed by practical pointers that reflect RegLex's experience rather than the text of the Regulations.
Step 1: Build a strong management system
Establish strong company management systems and adopt a company-specific policy on due diligence for gold supply chains. In practice, that usually means senior management ownership, a named person responsible, written procedures, training and records.
Step 2: Identify and assess supply-chain risk
Identify and assess the risks in your gold supply chain. Start with origin. The Ministry's 2026 DPMS guidance points to export certificates, customs declarations and shipment documents as ways to verify where gold has come from. Gaps or inconsistencies in that paperwork call for follow-up questions. Don't treat them as a formality.
Step 3: Respond to the risks you find
Design and implement a strategy to manage the risks you have identified. A sound response is proportionate and documented. Depending on the risk, it might mean enhanced checks, conditions on continued trading, suspension, or ending the relationship.
Step 4: Independent third-party audit (refiners and recyclers)
Refiners and recyclers must commit to appointing an independent third-party auditor to review their gold supply-chain due diligence. Accredited reviewers must carry out that review following the procedures in the Regulations.
On timing, the Ministry states that the first audit period began on 1 January 2023, and that the third-party review takes place once 12 months of the cycle are complete. For the first cycle, Circular No. (2) of 2024 expected the audit itself to be completed within 90 days of 31 December 2023. In practice, the review should be booked well before the cycle ends.
Step 5: Report (refiners and recyclers)
Refiners and recyclers must submit a report on due diligence in the gold supply chain. The Ministry states that reports must reach it within 90 days of the end of the review cycle.
How this links to your AML/CFT obligations
Responsible sourcing does not replace your anti-money laundering (AML) and counter-terrorist financing (CFT) programme. The two overlap, and in our view it makes sense to keep the supplier information, risk ratings and records behind them consistent.
DPMSR filing. The Ministry's 2026 DPMS guidance requires a DPMSR for transactions of AED 55,000 or more, or the foreign currency equivalent. This covers cash transactions with individuals, whether resident or not, and cash or wire transfer transactions with companies or other entities. The duty does not depend on risk: it applies even where customer due diligence has been completed satisfactorily.
Record keeping. The same guidance requires records to be kept for at least five years from the latest of the events it lists, such as the end of the transaction.
A similar perimeter. The guidance applies to DPMS established or operating in the UAE and in commercial free zones, a scope similar to that of Decree 68.
Penalties and the new AML law
Decree 68 says breaches attract administrative penalties under Federal Decree-Law No. (20) of 2018, the previous AML law. That law was repealed by Federal Decree-Law No. (10) of 2025, issued on 30 September 2025, which entered into force two weeks after publication in the Official Gazette. The new law keeps resolutions and circulars issued under the old law in force until replacements are issued, as long as they do not conflict with it.
RegLex view: Decree 68 therefore continues to apply, and penalties for breaching it now fall under the new law. Under that law, the supervisor may impose administrative penalties including a fine of between AED 10,000 and AED 5,000,000 for each violation. Circular No. (2) of 2024 also states that refineries that fail to meet their obligations will be subject to administrative action by the Ministry.
UAE Good Delivery: a separate standard
UAE Good Delivery (UAEGD) is an accreditation standard. Its rules are issued by the Executive Office of the Emirates Bullion Market Committee (EBC), which the UAEGD website describes as chaired by the Ministry. Accredited members must comply with the EBC Rules for Risk Based Due Diligence in the Gold Supply Chain. These rules require members to report publicly every year on their supply-chain due diligence. They also say members "shall avoid, where practicable, cash purchases", and must support any unavoidable cash purchase with verifiable documentation. If you hold or are seeking UAEGD accreditation, read those rules alongside Decree 68.
What this means for your business
If you are a refiner or recycler:
- Confirm that your due diligence policy is approved, current and specific to your gold supply chain.
- Refresh your supply-chain risk assessment, focusing on origin and documentation.
- Diary your 12-month review cycle and engage an accredited independent reviewer well before it ends.
- File your due diligence report with the Ministry within 90 days of the end of each review cycle.
- Update policies and procedures that still refer to Federal Decree-Law No. (20) of 2018.
If you trade, import or deal in gold:
- Put a written due diligence policy and management system in place (step 1).
- Assess and document supply-chain risks for each supplier and source (step 2).
- Record how you respond to each risk you identify (step 3).
- Check that DPMSRs are filed for every qualifying transaction (cash with individuals; cash or wire with entities) and that records are kept for at least five years.