Sanctions screening for gold, jewellery and precious stones dealers in the UAE

Cabinet Resolution No. 134 of 2025 makes dealers in precious metals and stones DNFBPs for single or linked cash transactions of AED 55,000 or more. The Ministry of Economy and Tourism's 2026 guidance is clear that this threshold is not an exemption: dealers still apply risk based measures below it when the nature, pattern or context of a transaction raises risk.

Sanctions duties are not threshold based at all. The guidance requires dealers to comply with UAE directives on terrorism lists and targeted financial sanctions, and notes some obligations apply whether or not a covered transaction takes place.

The EOCN guidance applies screening to all parties to a transaction. For a dealer that includes:

• walk-in and repeat customers, individuals and companies;
• suppliers you buy from, including their beneficial owners;
• anyone paying or collecting on someone else's behalf; and
• existing and former customers from the last five years whenever the lists are updated.

For a confirmed match, stop immediately: do not complete the sale or purchase, provide no services, and file a Confirmed Name Match Report (CNMR) in goAML within five business days, describing the attempted transaction and the items involved. For a partial match you cannot resolve, suspend or reject and file a Partial Name Match Report (PNMR). See how to file a CNMR or PNMR.

The 2026 guidance requires a Dealers in Precious Metals and Stones Report (DPMSR) for:

• transactions with resident individuals in cash of AED 55,000 or more, or the foreign currency equivalent;
• transactions with non-resident individuals in cash of AED 55,000 or more; and
• transactions with companies or entities of AED 55,000 or more, whether in cash or by wire transfer.

Like the REAR in real estate, the DPMSR is not risk dependent. If a reportable transaction is also suspicious, the suspicious transaction report must be filed as well.