Our commitment to preventing financial crime and ensuring transparent, compliant gold transactions
GOLD BRICK GOLD TRADING LLC is fully committed to the highest standards of Anti-Money Laundering (AML), Combating the Financing of Terrorism (CFT), Counter-Proliferation Financing (CPF), and Targeted Financial Sanctions (TFS) compliance. As a licensed precious metals trading company classified as a Designated Non-Financial Business or Profession (DNFBP) and Dealer in Precious Metals and Stones (DPMS), we adhere to Federal Decree-Law No. 20 of 2025, Cabinet Decision No. 134 of 2025, FATF Recommendations, and international best practices.
This Version 2.0 handbook has been comprehensively updated to align with the latest UAE regulations, including EOCN TFS Guidance (July 2025), Circular No. 4 of 2025 (UAE 2024 NRA), and Circular No. 8 of 2025 (High-Risk Countries). It outlines our framework for preventing, detecting, and reporting suspicious activities, sanctions matches, and proliferation-financing concerns related to gold trading.
Our AML/CFT program complies with the following regulations:
Primary UAE law on Anti-Money Laundering, Combating the Financing of Terrorism and Illegal Organisations — supersedes Federal Law No. 20 of 2018
Executive Regulations of Federal Decree-Law No. 20 of 2025 — implementing rules for CDD, EDD, and reporting obligations
Regulating violations and administrative penalties imposed on AML/CFT/PF procedure violators
Regulating Terrorist Lists and implementing UN Security Council Resolutions on the prevention and suppression of terrorism financing
Executive Office for Control & Non-Proliferation guidance on Targeted Financial Sanctions for DNFBPs, including screening, freezing, and reporting requirements
UAE 2024 National Risk Assessment (DPMS sector identified as high inherent risk) and updated Lists of High-Risk Countries
Financial Action Task Force standards for high-risk commodities, DNFBPs, and OECD Due Diligence for Responsible Gold Supply Chains
Registered under moses@goldbrick.ae for STR, DPMSR, FFR, and PMNR submissions
Comprehensive identity verification, UBO identification (≥25% threshold), and ongoing due diligence per Cabinet Decision No. 134 of 2025
Customers classified as LOW / MEDIUM / HIGH risk with corresponding CDD intensity, PEP screening, and EDD triggers
Continuous transaction monitoring, periodic review per risk class (12/24/36 months), and trade-based ML controls
Pre-onboarding and continuous screening against UAE Local Terrorist List, UN, OFAC SDN, and EU Consolidated Lists
Dedicated CPF controls aligned with UNSCR 1718 (DPRK) and UNSCR 2231 (Iran), including dual-use awareness for gold
FFR within 24 hours of confirmed match, PMNR for partial matches, STR via goAML, and DPMSR per AED 55,000 thresholds
Risk-based customer classification and mandatory documentation per Cabinet Decision No. 134 of 2025
Per Cabinet Decision No. 134 of 2025, every customer is classified at onboarding and reviewed periodically. Triggers include cash transactions of AED 55,000+ (interrelated or single).
| Risk Level | CDD Required | Review Frequency | Triggers |
|---|---|---|---|
| LOW | Standard CDD — core KYC documents, basic screening | Every 36 months | Established UAE entity, transparent ownership, no PEP exposure |
| MEDIUM | Standard CDD + enhanced transaction monitoring | Every 24 months | Cash-intensive sector, cross-border transactions, complex structure |
| HIGH | Full EDD — SOF, SOW, senior management approval, site visit if required | Every 12 months or sooner | PEP, FATF greylist/blacklist jurisdiction, adverse media |
All counterparties, UBOs (≥25%), authorised signatories, suppliers, and intermediaries are screened at onboarding and on an ongoing basis against four sanctions lists.
Published and updated by EOCN — actioned within 24 hours of notification
United Nations Security Council Consolidated Sanctions List, including UNSCR 1718 (DPRK) and UNSCR 2231 (Iran)
US Office of Foreign Assets Control — Specially Designated Nationals and Blocked Persons List
European Union Consolidated Financial Sanctions List
Upon a confirmed sanctions match, immediate freeze (within 24 hours), full audit trail, FFR filed via EOCN same business day where practicable. No release without express EOCN clearance.
On partial match, transaction paused, secondary verification (DOB, nationality, ID, alias). PMNR filed via EOCN before resuming relationship if match cannot be excluded.
Dealers in Precious Metals and Stones Reports filed via goAML for cash transactions ≥ AED 55,000 and international wire transfers ≥ AED 55,000 per Cabinet Decision No. 134 of 2025.
As a physical wholesale gold dealer, we recognise that precious metals can be vehicles for proliferation financing due to their high value, portability, and liquidity.
Indicators that trigger enhanced scrutiny or transaction rejection
Tipping-off the customer or any third party of suspicion or STR filing is a criminal offence under UAE AML/CFT law.
All employees complete mandatory AML/CFT/CPF/TFS induction training within 30 days of joining and annual refreshers thereafter, with formal attendance records maintained for minimum 5 years:
In compliance with UAE regulations, we maintain comprehensive records for a minimum of 5 years from the date of transaction completion, including:
All records are stored securely with restricted access and protected by encryption and backup systems.
Download our comprehensive compliance and operational policies
For inquiries related to our AML / CFT / CPF / TFS programme or to report suspicious activities:
GOLD BRICK GOLD TRADING LLC
Moses Jayaraj — Managing Director & MLRO
moses@goldbrick.ae
goAML / EOCN: moses@goldbrick.ae
+971 50 156 4019
Dubai, United Arab Emirates
Version 2.0 · Effective 07 April 2026 · Previous Version: 1.1 (01 February 2026)
Next review: 07 April 2027 or upon regulatory change. DET Licence 806677 · AML Reg. GMLMOEC467872254 · VAT TIN 100569836800003
