When it comes to protecting the integrity of the global financial system, few nations pack a punch quite like the UAE.
The country’s influence stems from a rare combination of factors – it is a major hub for global trade and finance that remains deeply committed to multilateralism, international co-operation and the rules-based order.
One sector where this leadership is especially visible is gold. In 2023, the UAE became the world’s second-largest gold trading hub.
This was achieved through leadership that balanced the importance of building a trusted regulatory framework for gold trading with the creation of a business-friendly environment. The Ministry of Economy and Tourism has developed robust regulations and compliance procedures that are in line with – and in some areas exceed – the highest international standards.
Meanwhile, efforts by the Dubai Multi Commodities Centre have contributed significantly to the sector’s trade growth. More than 1,500 gold and precious metals companies now operate from the emirate and collectively benefit from specialised industry infrastructure, products and services.
Yet with scale comes responsibility. Gold is a high-value, low-volume, fungible commodity that is an attractive target for illicit use, including money laundering. The Financial Action Task Force has identified many of the risks associated with the gold sector – risks that have been echoed in the UAE’s latest National Risk Assessment. This assessment calls on all public and private stakeholders to identify, understand and mitigate the risks involved in conducting their activities, in close collaboration with the authorities.
Many gold-exporting countries have limited oversight of artisanal mining, where gold often functions as an informal currency. Globally, there is no consistent reporting standard, and regulatory regimes vary widely, creating gaps that criminals can exploit.
UAE sets global gold trade benchmark
The UAE has chosen not to step back but to set a new global benchmark for responsible trade in gold, aligning its framework with international best practices, including the OECD’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
Since 2023, the UAE Ministry of Economy has required all gold refiners to conduct full supply chain due diligence in line with the OECD’s guidelines and submit independently audited reports. In addition, many refineries have signed up to the UAE Good Delivery standard for accreditation, which includes further disclosure on a refinery’s technical state, capacity and financial health. Traders must also report suspicious transactions to the UAE’s Financial Intelligence Unit through the UN-developed goAML platform.
Unlike other bullion centres, the UAE’s framework is mandatory, not voluntary, setting a new global precedent. Crucially, it applies not only to UAE Good Delivery refiners but to all refiners operating in the UAE, regardless of Good Delivery accreditation. Compliant entities are rewarded with market access, while those that fall short face tougher conditions as buyers prioritise trusted partners. Those with serious failings face tough sanctions and enforcement, including closure orders.
Gold traders in the UAE fall under the category of Designated Non-Financial Businesses and Professions, bringing them under Federal Decree Law No. 20 of 2018 on anti-money laundering and combating terrorism financing, in line with FATF standards.
The Ministry of Economy and Tourism enforces strict supervision. Inspections were carried out on dealers in precious metals and stones, resulting in significant fines where companies were found non-compliant. In addition, between 2022 and 2024, the total number of seizures of gold and precious metals and stones from all points of entry increased by more than 70 per cent, illustrating how enforcement fights illicit flows.
The UAE requires disclosure of portable gold, including its source and purpose of entry. This measure supports efforts to thwart illegal trading and promote responsible precious metals transactions.
As part of its efforts to enhance integrity across the gold supply chain, the DMCC joined forces with the World Gold Council in 2022 to address the challenge of hand-carried gold linked to illicit trade. This partnership includes an annual training programme for the gold industry, engagement with bullion banks, the development of retail gold investment principles and the commissioning of consumer research to better understand market dynamics.
Trade data discrepancies can also arise between exporting and importing countries. While these often occur due to a number of understandable factors, such as time lags created by customs processing procedures, the rerouting of a commodity while in transit, or the impact of long-term warehousing, they nonetheless create challenges when monitoring illicit flows.
The UAE, however, reports its gold imports comprehensively and on time, including to international databases, aligning with OECD expectations for transparent mineral supply chains. What this means is that there are cross-border challenges at stake that call for shared international responsibility and require renewed and constant commitments by all concerned countries.
The UAE is working closely with the World Gold Council and other partners on several initiatives to strengthen the integrity of the gold market. This includes the development of an anti-money laundering training programme for the sector and running trade workshops with key industry bodies including the Dubai Jewellery Group and the DMCC. Work has also begun on a review of rules regarding hand-carried gold and rules to strengthen border enforcement.
We are also exploring innovative technology, from chemical “fingerprinting” to verify declared provenance, to mobile refining units for artisanal and small-scale miners. These measures reduce environmental damage, enhance traceability and help channel gold to legitimate buyers, including central banks, all in line with OECD-aligned responsible sourcing frameworks.
The bottom line is this: the UAE is not just trading gold, it is shaping the future of the gold industry, working transparently, responsibly and through international co-operation with other global standard-setters.
