ANTI-MONEY LAUNDERING &
COUNTER-TERRORIST FINANCING (AML & CTF) POLICY
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1. Purpose
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This Policy sets out the AML/CFT framework for GoldTakas FZCO’s (hereinafter referred to as "GoldTakas") precious metals trading activities within the Dubai Multi Commodities Centre (DMCC). It ensures compliance with applicable international standards and, critically, the binding laws and regulations of the United Arab Emirates (UAE) for DPMS entities. The Policy aims to minimize AML/CFT risks across all operations and uphold an ethical environment among employees, business partners and clients.
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2. Scope
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This Policy applies to GoldTakas’s entire precious metals supply chain, commercial transactions and financial operations, including onboarding, trading, settlement, logistics, and ongoing monitoring. It is binding on all UAE-booked transactions, clients, suppliers, intermediaries and employees.
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3. Legal Basis and International Standards
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GoldTakas aligns with the following international standards:
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• Financial Action Task Force (FATF) Recommendations.
• United Nations Security Council Resolutions (UNSCR).
• OECD Due Diligence Guidance for Responsible Supply Chains of Minerals.
• OFAC and EU sanctions regimes (applied where contractually or jurisdictionally required).
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The following UAE legal instruments are binding for DMCC/DPMS operations and incorporated into this Policy:
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• Federal Decree-Law No. (10) of 2025 on Anti-Money Laundering, Combating the Financing of Terrorism and Financing of the Proliferation of Weapons.
• Cabinet Decision No. (10) of 2019 — Executive Regulations of the AML/CFT Law (including CDD/EDD, recordkeeping, internal controls and confidentiality).
• Cabinet Decision No. (74) of 2020 — Targeted Financial Sanctions (UN & UAE Local Lists) and UNSCR implementation (‘freeze without delay’).
• Cabinet Decision No. (58) of 2020 — Beneficial Owner (UBO) Procedures (register, maintain and update UBO data).
• Cabinet Resolution No. (71) of 2024 — Unified list of AML/CFT administrative violations & fines under MoE/MoJ supervision.
• UAE FIU goAML registration & reporting obligations for DNFBPs (including STR/SAR and DPMSR).
• MoE Circular No. 08/AML/2021 — DPMSR reporting for threshold transactions.
• DMCC Company Regulations 2020 and DMCC Practical Guidance & Rules for Risk-Based Due Diligence in the Precious Metals Supply Chain (aligned with OECD).
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4. Risk-Based Approach
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GoldTakas adopts a risk-based approach (RBA) to identify, assess, mitigate and monitor AML/CFT risks across customers, products/services, geographies, delivery channels and the supply chain.
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4.1 Principles
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• Risk identification and assessment for each client/relationship and transaction (low/medium/high).
• Proportionate mitigation via CDD/EDD, monitoring and escalation (focus on high-risk).
• Ongoing monitoring with periodic review and refresh cycles based on risk.
• Senior management approves AML/CFT policies and risk appetite; the Compliance Officer/MLRO oversees implementation and submits biannual reports to senior management and, where required, to supervisory authorities.
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4.2 Risk Factors
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GoldTakas considers various factors to manage risks in line with international standards and the applicable UAE AML/CFT regulations, including Federal Decree-Law No. (10) of 2025 and Cabinet Decision No. (10) of 2019. These factors are examined under four main headings:
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4.2.1 Client Risk Factors:
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• Client Nature: Is the client an individual, or a legal entity? Who is the ultimate beneficial owner (UBO)? The ultimate ownership structure and field of activity of legal entities are carefully examined.
• Client History: Has the client been previously linked to money laundering or financing of terrorism? Is he/she on sanction lists? All clients are screened against the UAE Local Terrorist List, the UN Consolidated List, as well as other applicable sanctions databases (OFAC, EU).
• Client Behavior: Are the transactions made by the client consistent with the size of the company and its field of activity? Are there any unusual or unexplained transaction behaviors?
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4.2.2 Geographic Risk Factors:
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• Geographic Location of the Client or the Transaction: GoldTakas evaluates whether the clients or transactions are from high-risk regions (e.g., risky regions in terms of money laundering or financing of terrorism, as determined by the FATF or identified by the UAE authorities).
• Countries of Operation: The level of compliance with AML/CFT laws and practices of the countries in which the transaction is made or which are in the supply chain is examined. Particular attention is given to jurisdictions identified by the UAE Central Bank or the FATF as high-risk.
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4.2.3 Product and Service Risk Factors:
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• Type of the Precious Metal: Certain types of metals may pose higher risks for money laundering and the financing of terrorism (e.g., liquid precious metals such as gold).
• Transaction Type and Volume: Cash-based transactions, cross-border transfers, and unusually large-volume transactions may pose higher risks. All transactions are monitored in accordance with the goAML reporting obligations in the UAE.
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4.2.4 Supply Chain and Third-Party Risks:
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• Examination of Suppliers and Business Partners: GoldTakas evaluates the AML/CFT compliance of all suppliers and business partners and ensures that precious metals from reliable sources are used. Suppliers are also screened against UAE and international sanctions lists.
• Traceability: Traceability of the supply chain is ensured and documented. Additional reviews are conducted in case of uncertainty or risk in any link of the supply chain. Supply chain documentation is maintained for at least five (5) years in compliance with UAE record-keeping requirements.
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4.3 Risk Management Tools
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GoldTakas applies a range of strategies and tools to manage AML/CFT risks in compliance with international standards and UAE requirements under Federal Decree-Law No. (10) of 2025 and Cabinet Decision No. (10) of 2019. These include:
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• Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD): Verification of identity and ultimate beneficial owners (UBOs); understanding the purpose and intended nature of the business relationship; obtaining information on the source of funds and source of wealth for higher-risk clients. Enhanced measures are applied where risk levels are high.
• Transaction Monitoring and Case Management: Automated rules, alerts, and monitoring tools are used to detect unusual or suspicious activity. All investigations, decisions, and outcomes are documented and subject to review.
• Suspicious Transaction Reporting (STR) / Suspicious Activity Reporting (SAR): All suspicious transactions are escalated to the MLRO and, where necessary, reported via the goAML platform operated by the UAE Financial Intelligence Unit (FIU). Decisions and reports are documented and retained.
• Designated Non-Financial Businesses and Professions (DNFBPs) Reporting: As a dealer in precious metals and stones, GoldTakas complies with the DPMSR reporting obligations in the UAE, ensuring timely and complete submission of reports and retention of acknowledgments from the system.
• Recordkeeping: All CDD files, transaction records, monitoring data, STR/SAR/DPMSR submissions, and related correspondence are retained for a minimum of five (5) years, and longer where investigations, audits, or legal holds require.
• Wire Transfers: In line with UAE AML regulations, international wire transfers of AED 3,500 or above must contain complete prescribed originator and beneficiary information. Transactions that fail to meet these requirements will not be processed.
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4.4 Additional Measures for High-Risk Clients/Transactions
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• Heightened verification of source of funds/wealth and beneficial ownership.
• Shorter KYC refresh cycles and enhanced ongoing monitoring.
• Senior management (or MLRO) approval prior to onboarding/continuation.
• Ability to decline or exit relationships where risks cannot be mitigated.
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5. Know Your Customer (KYC) & CDD Triggers
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GoldTakas performs CDD at minimum in the following cases:
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1. At onboarding of all customers.
2. For occasional transactions equal to or exceeding AED 55,000 (single or seemingly related).
3. For occasional wire transfers equal to or exceeding AED 3,500.
4. Where there is suspicion of a crime (regardless of amount).
5. Where there are doubts about the adequacy or veracity of previously obtained identification data.
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5.1 KYC Documentation (Baseline)
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• Individuals: ID / Passport; proof of address (e.g., utility bill/tenancy), bank details.
• Legal entities: Trade/Commercial License, Memorandum & Articles, authorised signatory list, UBO declaration and supporting IDs, proof of address, bank details.
• Any additional documentation reasonably required based on risk.
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5.2 Beneficial Ownership (UBO)
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For legal persons/arrangements, identify and verify UBOs (≥25% ownership/control or equivalent control) and maintain accurate, up-to-date UBO information consistent with Cabinet Decision No. (58) of 2020 and registrar requirements.
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5.3 DPMSR (Threshold Reporting)
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For qualifying transactions (e.g., cash ≥ AED 55,000 with individuals or B2B; international wire transfers meeting FIU/MoE criteria), the DPMSR is filed via goAML within the prescribed timeframe, with required identification and supporting documents attached.
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5.4 Responsible Sourcing (DMCC/OECD)
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For higher-risk or conflict-affected/high-risk sources, apply DMCC Practical Guidance and DMCC Rules for Risk-Based Due Diligence aligned with the OECD 5-step framework: (i) establish strong company management systems, (ii) risk assessment, (iii) risk mitigation and response strategy, (iv) independent third-party review, and (v) annual reporting.
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6. Suspicious Activity / Transaction Reporting (STR/SAR)
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Employees escalate suspicions promptly to the MLRO using the internal reporting process. Where suspicion is confirmed, GoldTakas files STR/SAR via goAML to the UAE FIU without undue delay. ‘Tipping-off’ is strictly prohibited.
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All STR/SAR records (including internal assessments) are retained for at least 5 years. Decisions and rationales are documented and available to supervisory authorities upon request.
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7. Working with Third Parties & Supplier Audit
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GoldTakas performs due diligence on third parties and suppliers prior to engagement and periodically thereafter, including KYC/UBO verification, assessment of AML controls, provenance/traceability, and sanctions/TFS screening (pre-onboarding and daily thereafter).
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8. Training and Awareness
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Role-specific AML/CFT training is delivered at least annually, covering KYC/EDD, identification and escalation of red flags, STR/SAR and DPMSR reporting, TFS procedures, and recordkeeping. Attendance and assessment records are maintained for ≥ 5 years.
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9. Internal Governance, Compliance & Audit
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GoldTakas appoints a Compliance Officer (MLRO) with appropriate seniority and expertise. The MLRO oversees the AML/CFT framework, investigates escalations, decides on STR/SAR/DPMSR filings, coordinates with authorities, and produces biannual reports to senior management (and where required, the supervisory authority).
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Independent audit/testing periodically assesses policy effectiveness and control adequacy. All AML/CFT policies, procedures, controls and workpapers are maintained and made available to supervisory authorities upon request.
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Records relating to CDD, monitoring, STR/SAR/DPMSR, and governance are retained for ≥ 5 years in accordance with the Executive Regulations.
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10. Targeted Financial Sanctions (TFS)
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• Daily screening against the UN Consolidated List and the UAE Local Terrorist List at onboarding and on an ongoing basis.
• On a confirmed match, immediately freeze funds/assets without prior notice (‘freeze without delay’) and cease services.
• Notify the UAE Executive Office and the competent supervisory authority (e.g., MoE) within the stipulated timelines (e.g., within 2 business days for freezing actions).
• Apply ownership/control tests to entities potentially controlled by listed persons; maintain detailed freezing/notification records.
• Handle exemption requests (e.g., basic/humanitarian expenses) strictly per guidance and with authority approvals.
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11. Sanctions and Discipline
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Internal breaches of this Policy may result in disciplinary action. Regulatory breaches may also trigger administrative penalties under Cabinet Resolution No. (71) of 2024 and other applicable measures.
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12. Updating the Policy
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This Policy is reviewed at least annually and whenever relevant UAE AML/CFT, TFS, UBO or DMCC requirements change, or internal audit/risk assessments identify a need for amendment.
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