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Compliance and regulatory standards

Compliance as a Counterparty Guarantee

DET-Licensed · FATF-Aligned · Federal Decree-Law No. 10 of 2025

GOLD BRICK GOLD TRADING LLC operates under Federal Decree-Law No. 10 of 2025 and Cabinet Decision No. 134 of 2025 — the current UAE AML/CFT framework for Designated Non-Financial Businesses and Professions (DNFBPs). Our compliance programme is independently governed, regularly reviewed, and aligned with FATF Recommendations, LBMA Responsible Gold Guidance, and OECD Due Diligence Standards.

Trade Licence

DET 806677

AML/CFT Reg.

GMLMOEC467872254

VAT TIN

100569836800003

Policy Version

V2.0 — April 2026

Independent Audits & Certifications

Regulatory Oversight

  • UAE Dept. of Economy & Tourism (DET)

    Trade Licence 806677 — Dubai mainland. Full wholesale trading authorisation for precious metals.

  • UAE Ministry of Economy

    AML/CFT registration GMLMOEC467872254. DNFBP supervisory authority under Federal Decree-Law No. 10 of 2025.

  • UAE Financial Intelligence Unit (FIU)

    Active reporting entity on goAML. STRs filed within regulatory timeframes; tipping-off prohibition strictly observed.

  • UAE Federal Tax Authority (FTA)

    VAT Registration: 100569836800003. Quarterly reporting current.

Industry Alignments

  • LBMA Responsible Gold Guidance — Implemented
  • OECD 5-Step Due Diligence — Full framework adopted
  • FATF Recommendations for DNFBPs — Compliant
  • UN Guiding Principles on Business & Human Rights — Adhered

External Verification Partners

  • SGS Middle East — Assay & QC verification
  • Bureau Veritas — Independent quality certification

Technology-Enabled Compliance

Automated Sanctions Screening

  • Real-time OFAC, UN, EU, UK OFSI & CBUAE sanctions checks
  • Automated PEP (Politically Exposed Persons) flagging
  • High-risk jurisdiction scoring (FATF grey/blacklist monitoring)

Transaction Monitoring

  • Unusual pattern detection for large/irregular transactions
  • Source of funds verification for payments > $100,000
  • Beneficial ownership analysis via UAE CRS/AEOI framework

goAML Integration

  • Connected to UAE Financial Intelligence Unit (FIU)
  • Suspicious Transaction Reports (STRs) filed electronically
  • Threshold Transaction Reports (TTRs) automated for cash > AED 55,000

Refinery Partnership Due Diligence

Gold Brick only works with refineries that meet ALL of the following criteria:

LBMA Good Delivery Accredited OR DMCC Approved Refinery
Annual RJC (Responsible Jewellery Council) Audit (Preferred)
ISO 9001 Quality Management Certification
Full traceability systems for incoming doré
No conflict minerals sourcing (per OECD Annex II Red Flags)
RefineryLocationLBMADMCCGold Brick Relationship
Etihad Gold RefineryDMCC, DubaiIn ProgressYesPrimary partner (2022–present)
Emirates RefineryDubaiPendingYesSecondary capacity

Our Compliance Framework

Regulatory Governance

Licensed by the UAE Department of Economy and Tourism (DET), Dubai — Licence No. 806677. Gold Brick operates as a Dubai mainland company under the regulatory oversight of the UAE Ministry of Economy, complying with full DNFBP obligations under Federal Decree-Law No. 10 of 2025.

FATF Alignment

All procedures follow FATF standards for high-risk commodities and cross-border physical gold trading, including comprehensive AML/CFT controls.

AML/CFT Controls

  • • KYC / KYB for all counterparties
  • • Sanctions & OFAC screening
  • • PEP / high-risk jurisdiction scoring
  • • Ongoing monitoring via UAE goAML FIU

Third-Party Verification

All physical gold movements verified through SGS / Bureau Veritas assay, Brinks / Malca-Amit / Transguard logistics, and LBMA/DMCC-recognized refineries.

Customer Onboarding Process

Required for all buyers, sellers, and market participants

1

Expression of Interest

2

KYC/KYB Submission

3

AML/CFT Screening

4

NDA & Secure Exchange

5

Contract Documentation

6

Execution & Settlement

No advance fees. No broker chains. No cash transactions without full KYC.

Responsible Sourcing & Supply Chain Policy

Ethical, Transparent, Traceable — From Mine to Vault

OECD 5-Step Due Diligence Model

Step 1

Internal Systems

Step 2

Risk Assessment

Step 3

Risk Mitigation

Step 4

Third-Party Verification

Step 5

Reporting & Records

Our Compliance Structure Integrates:

  • • Federal Decree-Law No. 10 of 2025 (AML/CFT)
  • • Cabinet Decision No. 134 of 2025 (Implementing Regulations)
  • • FATF Recommendations 22, 23, 24, 25 — DNFBPs
  • • OECD Due Diligence Guidance + ASGM Supplement
  • • LBMA Responsible Gold Guidance
  • • UAE PDPL — Federal Decree-Law No. 45 of 2021

Zero-Tolerance Policies

Gold Brick will not transact with, or facilitate transactions for, any entity or individual engaged in:

  • • Conflict minerals or gold from areas of armed conflict
  • • Child labour, forced labour, or human trafficking in any part of the supply chain
  • • Undeclared or smuggled exports of any kind
  • • Bribery, corruption, or facilitation payments
  • • Proxy sellers, unlicensed traders, or misrepresented ownership structures
  • • Misdeclared origin, weight, or purity declarations
  • • Unverified cash transactions at or above AED 55,000
  • • Entities on UN, OFAC, EU, UK, or CBUAE sanctions lists
  • • Human rights violations or environmental law violations in mining operations

Breach of any of the above results in immediate termination of the relationship and, where legally required, a Suspicious Transaction Report filed with the UAE Financial Intelligence Unit via goAML.

AML Officer Independence

The AML Compliance function at Gold Brick operates independently from commercial and revenue-generating activities. The Compliance Officer holds authority to decline, suspend, or terminate any transaction or counterparty relationship without commercial override, and has direct access to the Managing Director for escalation of material compliance matters. This structure is maintained in accordance with Federal Decree-Law No. 10 of 2025.

Tipping-off Prohibition: Disclosure of a Suspicious Transaction Report (STR) or any related investigation to the subject or any third party is a criminal offence under UAE law. Gold Brick strictly observes this prohibition at all times.

Chain-of-Custody Verification

Every gram tracked from origin to vault

Documentation maintained includes:

Certificate of Origin
Export permit
Air Waybill (AWB)
Seller invoice
Movement reports
Refinery assay report
Vault receipt
Settlement confirmation

Chain-of-custody is never broken or outsourced.

Compliance Desk Contact

GOLD BRICK GOLD TRADING LLC

Compliance Department

compliance@goldbrick.ae

📞 +971 50 156 4019

📍 Dubai, United Arab Emirates

All communication under NDA and subject to KYC/KYB verification.