United Arab Emirates

Researcher's note: [not-read] Text not held (visitdubai.com 403); read by WebFetch and through the extract quoted in the CBUAE guidance held. [inferred] inForceFrom is the gazette date: the Regulation comes into force on publication. Survives FDL 10/2025 under its Art. 41(3) insofar as it does not conflict, until superseded; no superseding ICP disclosure instrument found.

Researcher's note: [not-read] The Policy the Decree says is attached is not in the MoET PDF.

Researcher's note: [not-read][blocked] The Decision and its later amendments were not obtained (uaelegislation.gov.ae challenge; FTA Designated Zones guide robots-blocked for WebFetch, queued for the Mac host). Only the 2017 list reproduced by Grant Thornton was read.

Researcher's note: [summary][blocked] Not held: uaelegislation.gov.ae download behind a Cloudflare challenge; Art. 4 read through WebFetch only (2026-09-28).

Researcher's note: [summary][blocked] Not held: Cloudflare challenge; Arts. 4, 6 and 20 read through WebFetch only (2026-09-28).

Researcher's note: [summary][blocked] Not held: Cloudflare challenge; the gold line was read through WebFetch only (2026-09-28).

Researcher's note: [not-read] The consolidation held runs to FDL 16/2024; FDL 16/2025 (effective 1 Jan 2026) is not incorporated. The FTA's 09-2026 consolidation is queued in laws/_work/ae-fetch.tsv.

Legal basis: Dubai Law No. 12 of 2016; SIRA Resolution No. 1 of 2018 (Implementing Bylaw), Art. 2(a), Art. 3(a)(6) (Money and Valuables Transport, incl. "precious metals, such as gold and silver"), Art. 8 (company licence one year, renewable), Art. 13(11), Art. 16 (individual licence two years)

Researcher's note: Dubai only; federal licensing outside Dubai and cargo-security document names at DXB/DWC not found. [unconfirmed] In force on publication in the Official Gazette (Art. 32); publication date not printed; issue date 12 Jul 2018 used. [not-read] Dubai Law 12/2016 itself not held. [unconfirmed] A secondary legal database (realLaw) lists a "Dubai Decision No. 1 of 2026 promulgating the Executive Regulations of Dubai Law No. 12 of 2016", which may replace the 2018 bylaw; the Dubai Legislation Portal still carries the 2018 Resolution and no 2026 text was found there (2026-09-28). Gulf News reports an amendment of Law 12/2016 itself (not read).

Legal basis: EBC UAE Good Delivery Accreditation Rules v1/2021, s.5.1 (criteria: net worth at least AED 55.1m, at least 10 t a year in each of the previous 3 years, 3 years operating), s.7.1 (bar specifications and marks), s.8.2(b), s.9.1(b), s.11 (fees)

Researcher's note: validFrom 2021-11-01 is from the DMCC fact sheet ("launched in November 2021"); the Rules print only "Version 1/2021". [time-limited] The membership list read is version 62 of 30 Jun 2025.

Legal basis: Federal Decree-Law 10/2025; Cabinet Resolution 134/2025, FDL 10/2025 Art. 20 (no DNFBP activity "without obtaining a license, registration, or enrolment from the Competent Authority or from the relevant Supervisory Authority"), Art. 18(1) (reports through "the electronic system designated by the Unit"); CR 134 Art. 3(3) (DPMS in scope for single or linked cash transactions of AED 55,000 or more), Art. 21-22 (policies and compliance officer), Art. 25(1) (records at least 5 years), Art. 49(18) (Supervisory Authority's prior approval of compliance officers)

Researcher's note: [summary] goAML is named only in the FIU goAML DPMSR guide v1.2 (2021; WebFetch, not held); FDL 10/2025, CR 134/2025 and the MoET DPMS Guidance 2026 do not name goAML. [unconfirmed] validFrom 2025-12-14 is the CBUAE Rulebook's date; the Resolution says it enters into force 30 days after gazette publication (Art. 71) and the gazette date is not printed in the copy held.

Legal basis: DMCC Authority Company Regulations 2024; DMCC Licensing Rules v3 (10 Oct 2024), Licensing Rules r.3.1.1 (licence categories), r.3.2.1, r.3.2.3(e) (other UAE authorities' licences and approvals), r.3.2.6 (Registrar issues the Licence), r.3.3.1-3.3.3 (renewal; no activity without a valid Licence)

Researcher's note: [not-read] The DMCC Authority Company Regulations 2024 (parent instrument) and the DMCC list of licence activities were not read, so the specific gold/precious-metals trading activity and any conditions attached to it are not confirmed. DMCC states it does not regulate gold imports or exports (federal: Ministry of Economy and Tourism). [unconfirmed] The DMCC renewal page says "Companies with Industrial, and selected regulated activities cannot apply for two, three or five years licence renewal" and that regulated activities need a third-party NOC before renewal; whether gold trading is such an activity is not stated.

Legal basis: DMCC Rules for Risk-Based Due Diligence in the Gold and Precious Metals Supply Chain v2/2020, Art. 1.1 (audit periods from 30 Sep 2020), Art. 3.1 (mandatory for Accredited Members), Art. 3.2 (voluntary for others), Rule 5.1 (annual public reporting)

Researcher's note: [conflict] See ae.div-dmcc-role: DMCC's July 2025 fact sheet says DMCC does not regulate the gold industry and refiner accreditation runs through the EBC's UAE Good Delivery; which firms are still DMCC Accredited Members is not stated.

Legal basis: EBC Rules for Risk Based Due Diligence in the Gold and Precious Metals Supply Chain v1/2021; UAEGD Accreditation Rules v1/2021, RBDG Rules Art. 1.1, Art. 3.1 (mandatory for Accredited Members), Rules 3.1, 4.6, 5.1, Annex 2 s.16.1 (Reviewer reports within 90 calendar days); UAEGD Rules s.2.3, s.5.1, s.9.1(b)

Researcher's note: [unconfirmed] validFrom: Art. 1.1 prints the start date in square brackets ("[1 February] 2022") in the copy read, which is hosted by a refiner, not the EBC.

Legal basis: Ministerial Decree No. 68 of 2024; MoE Due Diligence Regulations v1 (2022), Decree Art. 1(A) (supply-chain entities and precious-metals dealers: management systems, risk identification and strategy), Art. 1(B) (refiners: independent third-party auditor, DD report); Regulations Step 4, Step 5, Annex I s.12.1

Researcher's note: [not-read] The Policy attached to the Decree is not in the MoET PDF. [inferred] The 90-day period comes from the Regulations' Review Protocol, read as the content of that Policy.

Legal basis: DMCC Vault ownership/operating arrangement (DMCC gold page); SIRA Resolution 1/2018, SIRA Res. Art. 3(a)(23) (Safe Storage as a licensed security activity)

Researcher's note: The DMCC page says the Vault at Almas Tower is "Owned by DMCC and operated by Brink's Global Services". [inferred] Brink's would need a SIRA licence for Safe Storage in Dubai; no licence record seen. The earlier validFrom 2012-01-01 is not in any text read and was removed.

Legal basis: Dubai Customs Customer Guide v3.03; GCC common customs law; UAE list of exempted commodities, Customer Guide s.9 (duty suspended for goods admitted into free zones), s.15.12.2

Researcher's note: [summary][blocked] The GCC list is not held (Cloudflare); its gold line, read via WebFetch, prints "71060000" (silver's heading). The standard GCC duty is 5% of CIF (Customer Guide s.7).

Legal basis: Cabinet Decision 127/2024; FTA VATP043, Art. 1 (Goods: precious metals - gold, silver, palladium, platinum - precious stones and jewellery mostly of them), Art. 2(1)-(4), Art. 4 (repeals CD 25/2018)

Legal basis: Cabinet Decision No. 25 of 2018

Researcher's note: [not-read] CD 25/2018 itself not held; described in FTA VATP029 and VATP043. validTo from CD 127/2024 taking effect 26 Feb 2025. [inferred] validFrom 2018-01-01 is the VAT start date; CD 25/2018's own date not read.

Legal basis: Federal Decree-Law 8/2017 on VAT; Executive Regulation, Art. 3 (5%), 45(8), 48(1), 49; Exec. Reg. Art. 36(2), 48, 50(1)

Researcher's note: [inferred] Doré is below the 99% test and so standard-rated. [not-read] FDL 16/2025 (from 1 Jan 2026) not held. [conflict] DMCC's fact sheet calls gold bullion "exempt" - see ae.div-vat-exempt-wording.

Legal basis: Federal Decree-Law 10/2025; CBUAE Regulation on the Declaration of Currencies, BNIs, and Precious Metals and Stones (OG 703, 31 May 2021), FDL 10/2025 Art. 10 (duty to disclose, per the disclosure system issued by the ICP with the Central Bank), Art. 41(3) (regulations under FDL 20/2018 remain effective insofar as not conflicting), Art. 34 (penalty)

Researcher's note: The AED 60,000 threshold and cargo coverage come from the CBUAE Regulation (OG No. 703, 31 May 2021; issued under FDL 20/2018 Art. 8), quoted in CBUAE guidance dated 27 Sep 2021 (the earlier "in force 27/9/2021" was the guidance date). [inferred] The Regulation continues under FDL 10/2025 Art. 41(3); no new ICP disclosure system found. [unconfirmed] Its table covers precious metals "provided they are not intended for commercial purposes", so how the rule applies to commercial cargo is not settled. [not-read] Regulation text not held (visitdubai 403); read by WebFetch and through the guidance extract.

Legal basis: Cabinet Resolution 134/2025; MoET Supplemental Guidance for DPMS 2026, CR 134 Art. 3(3), Art. 25(1); Guidance s.1.4.1

Researcher's note: [summary] The DPMSR scope is from the MoET Guidance 2026 read via WebFetch (not held); goAML as the filing platform appears only in the FIU goAML DPMSR guide v1.2 (2021, WebFetch). CR 134/2025 Art. 3(3) and Art. 25(1) read in full.

Legal basis: Ministerial Decree 68/2024; MoE Due Diligence Regulations v1 (2022), Decree Art. 1(A), 1(B), Art. 3 (penalties under the AML law)

Researcher's note: [not-read] The Policy attached to the Decree is not in the PDF held. Art. 3 refers penalties to FDL 20/2018, since replaced by FDL 10/2025.

Researcher's note: Affects ae.st-18. [unconfirmed] Which applies today needs the current Dubai Customs notice.

Researcher's note: Affects ae.cr-imp-rbdgpm, ae.st-17, ae.st-23.

Researcher's note: Affects ae.tax-vat-import. The law prevails.