AML Requirements for Dealers in precious metals and stones in ADGM
Businesses trading in gold, precious metals or gemstones at any stage of the supply chain, from extraction and refining through wholesale to retail jewellers.
Are dealers in precious metals and stones designated in ADGM?
Yes. The designation follows the business itself, so a firm carrying on this activity in ADGM is within the regime without any further test.
- Designating provision
- ADGM AML Rulebook, DNFBP definition (b)
- Supervisor
- ADGM Registration Authority
A dealer in precious metals or stones. ADGM separately designates a dealer in any saleable item at or above USD 15,000, which is broader than the federal category.
Reports filed with no suspicion required
- Cash at or above USD 15,000 with an individual
- Any transaction at or above USD 15,000 with an entity, whether in cash or by wire transfer
ADGM AML Rulebook, rule 8.1.1(7)(a)
These are not risk-based. They are due whenever the trigger is met, even where due diligence is complete and nothing looks wrong, which is why an unfiled one is a strict-liability gap rather than a judgement call.
What the regime requires here
ADGM Anti-Money Laundering and Sanctions Rules and Guidance (AML), made by the FSRA under the Financial Services and Markets Regulations 2015 governs AML in ADGM. Every designated firm owes the same spine of obligations: a documented risk assessment covering money laundering, terrorist financing and proliferation financing; customer due diligence with enhanced measures for higher risk and for high-risk countries; policies approved by senior management; a compliance officer at management level; an independent audit of the controls; immediate implementation of targeted financial sanctions; staff training; and records available to the authorities on request.
- ADGM Anti-Money Laundering and Sanctions Rules and Guidance (AML)
- ADGM Financial Services and Markets Regulations 2015
What Federal Decree-Law No. 10 of 2025 changed sets out the obligations and the penalties in full, with each article cited.
See where this firm actually stands
AML Compass assesses a dealers in precious metals and stone against the duties that apply in ADGM, scores its risk and inspection readiness, and produces a report of the gaps citing the provision behind each one.
The same sector elsewhere in the UAE
The designation, the threshold and the supervisor are not the same across jurisdictions, so a firm operating in more than one needs both answers.
This page summarises published legislation and rulebooks for general information. It is not legal advice, and it does not replace the texts themselves or guidance from your supervisor.