Governance &
Compliance

The legal entity behind a transaction must be clearly identified. Relevant information includes its registered name, jurisdiction, registration number, licensing authority and permitted business activities. Documents should be current and checked against the issuing authority where available.

A trading licence, refinery authorisation and industry accreditation serve different purposes. The existence of one does not establish the others. The relevant scope must match the proposed activity.

AML due diligence examines who is involved, who ultimately owns or controls the business, why the transaction is taking place and how it will be funded. The level of review should reflect the counterparty, product, geography and transaction risks.

Unexplained intermediaries, unusual payment routes, inconsistent documents or a mismatch between the transaction and the business profile require further assessment. Source-of-funds information and supporting records may be necessary. Politically exposed person status calls for appropriate risk assessment and does not, by itself, establish wrongdoing.

Sanctions checks must consider the actual parties and the rules applicable to the transaction. The UAE framework includes the UN Consolidated List and the UAE Local Terrorist List. Other restrictions may be relevant because of the jurisdictions, banks, currencies or routes involved.

Names alone are insufficient. Ownership and control, intermediaries, payment beneficiaries and the destination also matter. Potential matches require verification and appropriate action. A declaration from a counterparty cannot replace independent screening, and a previous result does not guarantee a later transaction is permitted.

Responsible sourcing starts with identifying where the gold came from and how it reached the seller. The review should be proportionate to the supply chain and consider conflict, human-rights abuses, bribery, money laundering and misrepresentation of origin.

For mined gold, relevant evidence may include the mine or producer, extraction and export permissions, custody records and the handling of taxes or royalties. Recycled gold requires its own source assessment. Risk depends on the specific circumstances; an entire continent is not a single risk category.

For a refinery in Dubai or elsewhere in the UAE, verify the entity, facility and authorised activities. Where an accreditation or responsible-sourcing assurance is relied on, confirm that it is current, relevant to the material and supported by the issuing body.

Commercial discussions should identify the proposed refinery, the assay and sampling procedure, the form and purity of the output, and the agreed settlement basis. No refinery partnership or accreditation is implied by this website.

Both buyers and suppliers must complete the applicable onboarding review before a commercial relationship proceeds. The review should establish the entity, authorised representative, beneficial ownership, relevant licences and the proposed transaction.

Completing a form is the beginning of due diligence, not approval. Supporting documents, independent checks and follow-up questions may be needed. Any acceptance remains subject to a separate review of the counterparty and transaction.

The following official resources provide background to these topics. Requirements depend on the entity, activity and transaction concerned.

• DMCC • Gold Ecosystem
• UAE Ministry of Economy & Tourism • Responsible Sourcing Of Gold
• Executive Office For Control & Non-Proliferation • Sanctions
• OECD • Responsible Mineral Supply Chains