Navigating Regulatory Changes in the UAE's Jewellery Sector

The UAE’s jewellery and gold sector has always symbolized trust, heritage, and prosperity. From family-owned shops in traditional souks to luxury boutiques in malls, jewellers are central to both local culture and international trade.

Today, this sector is under increased regulatory scrutiny.

Under the UAE’s Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) framework, most jewellery and gold businesses are now classified as Dealers in Precious Metals and Stones (DPMS). This classification means they are also considered Designated Non-Financial Businesses and Professions (DNFBPs). As a result, these businesses face significant obligations, inspections, and potential fines.

To assist the industry in navigating this landscape, Marensa Advisory FZ LLC has launched a specialized support service for UAE jewellery and gold businesses. This article explains why these changes matter, outlines the obligations in practice, and discusses how structured support can transform a regulatory burden into a manageable process.

From “Retail Business” to “Regulated DNFBP”

For many jewellers, the most significant shift is conceptual rather than operational.

Historically, jewellery shops were viewed as retail businesses. However, under Federal Decree-Law No. 20 of 2018 on AML/CFT and Cabinet Decision No. 10 of 2019, most jewellery and gold traders are now categorized as:

• Dealers in Precious Metals and Stones (DPMS)

• Part of the broader category of DNFBPs (Designated Non-Financial Businesses and Professions)

  
  

In practical terms, this means:

• Jewellers must understand their money-laundering and terrorist-financing risks.

• They need written policies and procedures to manage those risks.

• They must identify and verify customers, keep documentation, and

• They need to know when and how to report suspicious activity to the UAE Financial Intelligence Unit (FIU) via goAML.

  
  

These are not optional “best practices.” They are regulatory requirements, and inspectors are actively checking for compliance.

The AED 55,000 Threshold: Where Full Obligations Start

A crucial aspect of the rules for DPMS is the transaction threshold.

For jewellery and gold businesses, full AML/CFT obligations are triggered when:

• A single cash or cash-equivalent transaction reaches AED 55,000 or more, or

• Several linked or related transactions, taken together, reach AED 55,000 or more.

  
  

This does not only refer to a single large cash sale. It can also include:

• Multiple instalments for one purchase

• Trade-ins where old jewellery is exchanged, and the difference is settled in cash or cheque

• Certain cash-equivalent instruments and prepaid methods

  
  

Above this threshold, the jeweller is expected to:

• Identify and verify the customer’s identity (and, where relevant, the beneficial owner)

• Apply enhanced checks for higher-risk situations (for example, politically exposed persons or customers from higher-risk jurisdictions)

• Record key transaction details and retain them for at least five years

• Assess whether the transaction is suspicious and should be reported via goAML

  
  

These obligations are in addition to Targeted Financial Sanctions (TFS) requirements, where businesses must screen customers against sanctions lists and “freeze without delay” if a match is found.

The Cost of Getting It Wrong

In recent years, the UAE has shifted from awareness to active enforcement for DNFBPs, including jewellers. Public announcements from the Ministry of Economy have highlighted:

• Administrative fines starting around AED 50,000, reaching up to AED 5,000,000 per violation, depending on severity and whether the breach is repeated.

• Collective enforcement actions where DNFBPs across sectors were fined tens of millions of dirhams in a single inspection campaign.

  
  

For an individual jewellery business, a few findings can quickly accumulate to:

• Six-figure fines for not conducting proper customer due diligence (CDD), failing to register or use goAML, or not maintaining adequate records.

• Higher penalties for multiple simultaneous breaches or ignoring sanctions-related duties.

• Additional measures such as suspension or cancellation of the trade licence, restrictions on activity, and public mention in enforcement notices.

  
  

For family businesses with a long-standing reputation, the intangible damage and loss of trust with banks, partners, and customers can be even more painful than the financial penalty.

Why Many Jewellers Are Still Exposed

Most UAE jewellers are not malicious actors. They are busy business owners, often hands-on, focused on inventory, staff, customer service, and day-to-day survival.

Common pain points include:

• Unclear Responsibility: No dedicated person in charge of AML/CFT, or a “name on paper” without real support.

• Generic Templates: Policies copied from other businesses that do not reflect the store’s actual risk profile or operations.

• Staff Awareness: Employees unaware of the AED 55,000 threshold or unsure when to ask questions or request ID.

• Identifying Suspicious Patterns: No structured method to identify suspicious patterns, especially when customers try to keep transactions just below the threshold.

• Sanctions Screening: Not embedded in the process or carried out informally without documentation.

• Understanding goAML: Limited knowledge of how and when to use goAML, and fear of “getting it wrong” when reporting.

  
  

These gaps create a disconnect between legal expectations and actual practices in the store, a gap regulators are specifically targeting during inspections.

Introducing Jewellery AML Guard from Marensa Advisory FZ LLC

To help close this gap, Marensa Advisory FZ LLC has launched a specialized support service dedicated to UAE jewellery and gold businesses.

The service is designed for Dealers in Precious Metals and Stones (DPMS) and other DNFBPs who want to:

• Clearly understand their obligations

• Implement practical, workable controls

• Reduce the risk of costly fines while focusing on running their business

  
  

What the Service Covers

While each engagement is tailored, the core support typically includes:

1. Business-Specific AML/TF Risk Assessment: A structured review of the store’s customer base, transaction patterns, products, delivery channels, and geographies. The result is a written risk assessment that demonstrates to regulators that the business understands its exposure and is managing it.

   
   

2. Custom AML/CFT Policy and Procedure Manual: No generic downloads. Marensa designs a store-level policy aligned with UAE law and guidance for DPMS, covering:

3. CDD and enhanced due diligence

4. Handling transactions from AED 55,000 and above

5. Record-keeping and retention

6. Internal escalation and suspicious transaction reporting

7. Targeted Financial Sanctions and screening process

9. Roles and responsibilities (including the Compliance Officer)




10. goAML and Reporting Support: Assistance with registration and practical guidance on using goAML appropriately, including internal workflows for preparing and approving reports before submission.

    
    

11. CDD / KYC Templates and Registers: Ready-to-use forms and logs such as:

12. Customer information and identification forms

13. Beneficial owner declarations

14. Source of funds / source of wealth questionnaires

16. Transaction registers for high-value and linked transactions




17. Training for Front-Line and Management Staff: Focused, practical sessions that explain:

18. What AML/CFT means in simple terms

19. The AED 55,000 threshold and how it works

20. Realistic red flags in jewellery transactions

22. What to do when something doesn’t feel right




23. Ongoing Support and “Health Checks”: For clients who prefer continuous support, Marensa can:

24. Conduct periodic reviews of CDD files and transaction samples

25. Help prepare for inspections

26. Provide an external view on complex or suspicious cases

28. Offer co-sourced Compliance Officer support in appropriate structures

Turning Compliance into a Business Advantage

When done correctly, AML/CFT compliance is not just about avoiding fines.

For jewellery and gold businesses, a robust and documented compliance framework can:

• Make banking relationships smoother by demonstrating that the business takes AML seriously.

• Facilitate expansion and partnerships, especially where counterparties need assurance regarding regulatory risk.

• Enhance customer confidence, particularly for high-value clients who want to know they are dealing with a reputable, well-governed store.

• Protect the business and its owners if something goes wrong by showing that reasonable steps were taken in line with expectations at the time.

  
  

In other words, clean records support clean growth.

How to Engage with Marensa Advisory

Marensa has made the first step deliberately simple.

Jewellery and gold businesses in the UAE can request a complimentary AML “health check,” which typically includes:

• A short structured discussion

• A review based on a one-page AML/CFT checklist covering the essentials

• A brief, confidential note highlighting the most important gaps and priorities

  
  

If you would like to explore this further, you can:

• Send a WhatsApp message to +971 58 594 3306 with the text “Jewellery Guard”

• Visit www.marensa-advisory.com and submit an inquiry through the contact page

• Reach out directly to the Marensa Advisory team to arrange a discreet consultation

  
  

Whether you run a single shop or a chain of outlets, in a mall or a traditional souk, the message from regulators is clear: jewellery is now a regulated sector.

With the right guidance and structure, staying compliant with AML/CFT regulations doesn’t have to be overwhelming. It can become just another well-managed part of your business, one that protects your licence, your reputation, and the legacy you are building.