Scrap Gold Sales in the UAE Need an Audited Refiner

Only a buyer registered as a dealer in precious metals under Federal Decree-Law 10 of 2025 and supervised by the Ministry of Economy and Tourism may lawfully buy your gold-bearing scrap. Sell to a refiner that is UAE Good Delivery accredited or Dubai Good Delivery listed, settles off spot against a fire assay, and issues documents your auditor can file.

Who can legally buy scrap gold in Dubai and Sharjah?

Dealers in precious metals and stones sit inside the designated non-financial business perimeter. Article 3 of Cabinet Resolution 134 of 2025 lists six categories of designated non-financial businesses and professions, and dealers in precious metals and stones is one of them. Supervision for mainland dealers and for those in commercial free zones sits with the anti-money laundering department of the Ministry of Economy and Tourism. Confirm the ministry's current English naming on its own portal before you quote it in a procurement memo.

The sector carries a formal risk label. The UAE Financial Intelligence Unit's October 2022 guidance for dealers in precious metals and stones states that the money laundering and terrorist financing risk of the sector is assessed as high in both the mainland and the commercial free zones, drawing on the national and sectoral risk assessments. Your counterparty is being watched closely. So is the paper you hand them.

UAE Good Delivery and Dubai Good Delivery are two different things

DMCC established the Dubai Good Delivery standard in 2012 and issued its Rules for Risk Based Due Diligence in the Gold and Precious Metals Supply Chain in 2016, built on the OECD five-step framework and structured in parts covering an Approved Reviewer application, a review protocol, an appeal process and minimum reporting requirements. The UAE Good Delivery standard is separate. It was unveiled in November 2021 as a voluntary national standard, with rules on risk-based due diligence maintained by the Emirates Bullion Market Committee. DMCC's seventh edition responsible sourcing guidance programme runs a session specifically on the difference between the ministry's responsible sourcing regulations and the UAE Good Delivery rules, and names two deliverables: the assurance statement and the management report. Ask any refiner for both, current year, before material leaves your floor.

Accreditation is not decorative. Emirates Gold DMCC was suspended from the UAE Good Delivery list with effect from 7 July 2023, and the LBMA suspended the company's affiliate membership the same month citing a due diligence review. That was three years ago and the position may have changed, so pull the live UAE Good Delivery list and the live Dubai Good Delivery list on the day you sign. For background on how refiner numbers sit, LBMA's Spotlight on the UAE put the country at around ten active gold refineries, with ten active Dubai Good Delivery gold members of which three were UAE-based refineries. That chapter is more than two years old and one of the three named operations was suspended afterwards, so use it as context, not as a shortlist.

Which AML law applies now, and what changed on 14 October 2025?

Almost every compliance note circulating in the Dubai gold trade still cites Federal Decree-Law 20 of 2018 and Cabinet Decision 10 of 2019. Both are gone. Federal Decree-Law 10 of 2025 on combating money laundering, terrorist financing and the financing of illegal organisations came into force on 14 October 2025 and repealed the 2018 decree-law. Cabinet Resolution 134 of 2025, the executive regulations, took effect on 14 December 2025 and revoked Cabinet Decision 10 of 2019 together with Cabinet Resolution 24 of 2022. Corporate penalties under the new law are reported to reach AED 100 million, a figure drawn from a compliance summary rather than the gazette, so verify it against the text if you are quoting it to a board.

One related correction worth making inside your own policy documents: the UAE was removed from the FATF grey list in 2024, and the 2025 legislation is framed as consolidating that exit. If your supplier questionnaire still asks counterparties to explain grey-list exposure, it is dated. More regulation coverage for UAE material streams sits in our regulation archive.

Do I need to report selling gold over AED 55,000?

The reporting duty sits with the buyer, not with you, but you are the one who makes it possible. The Dealers in Precious Metals and Stones Report was created in goAML in June 2021, with requirements effective from 12 June 2021 under the UAE FIU submission guide, version 1.2 dated 29 July 2021. The threshold carried into Article 3(3) of Cabinet Resolution 134 of 2025 is AED 55,000, applying to a single cash transaction or to linked cash transactions. For corporate customers, transactions of AED 55,000 or more in cash or by international wire transfer are reportable. Compliance practitioners put the filing window at two weeks from the date the funds are received or paid, and the relevant ministry circular is 08/AML/2021. The threshold and article reference come from consultancy restatements, so confirm the gazetted text before you build an SOP around them.

What this means on your side of the table is simple. A legitimate buyer will ask for Emirates ID or passport of the authorised signatory, trade licence, and a source-of-goods declaration. A buyer who does not ask is either unregistered or is not filing. Treat silence on identification as the single clearest disqualifier in the market.

Does responsible sourcing apply to me, or only to the refinery?

It applies to you. The Due Diligence Regulations for Responsible Sourcing of Gold were published by the ministry in September 2022 and became mandatory for all gold refineries operating in the UAE in January 2023, obliging refiners to assess supply-chain risk, build a risk-monitoring strategy and commission independent third-party review under an audit plan. Ministry Circular 2 of 2024 confirmed that independent audits of due diligence measures run from 1 January 2023 and must be completed within 90 days of the effective date.

Then the perimeter widened. Ministerial Decree 68 of 2024, issued on 29 March 2024, requires all entities refining gold or recycling its products, plus supply-chain stakeholders including those in commercial free zones under ministry supervision, to follow the due diligence policy. It extends the first three steps of the regulations to those entities and to precious metals dealers, and Article Three provides administrative penalties. If you are a jewellery manufacturer in the Gold and Diamond Park or an e-scrap processor in Sharjah shipping gold-bearing connectors, you are a named participant in a regulated chain, and the refiner will push its step one to three obligations upstream as paperwork demands.

What is scrap gold actually worth per gram today?

The most expensive misunderstanding in this trade is the belief that the Dubai retail rate is the scrap rate. It is not. Gold and silver price off the LBMA benchmark set twice daily in London, the dirham is pegged at 3.6725 to the dollar, and the morning rate published by the Dubai Gold and Jewellery Group is a retail number carrying a local premium.

The gap between the DGJG 24K rate and spot-derived fine gold on 5 October 2026 was about AED 10.20 a gram, roughly 2.1%. Scrap does not settle at either number without adjustment. It settles at spot multiplied by assayed fine weight, multiplied by a payable percentage, less a refining charge. Even spot is a range: on 2 October 2026 one major dealer quoted gold at USD 4,100.80 bid against USD 4,156.60 ask, a spread of USD 55.80 an ounce.

How much does a 1% assay difference cost on a 5 kg lot?

Here is the arithmetic that should govern your contract drafting. On any 5 kg lot, one percentage point of assayed gold content is 50 grams of fine gold, worth AED 24,440 at 4 October 2026 spot, whatever the grade of the feed.

The grades above are assumptions chosen to show the mechanics, not surveyed UAE averages, so read the rows as "if your sweeps assay at 8%". The editorial point survives either way. On low-grade sweeps, an absolute one-point disagreement can exceed the entire payable value of the silver in the lot, and once the material is melted you cannot re-litigate it. Agree the umpire laboratory, the retained referee sample and the tolerance band that triggers a re-assay before the material ships.

Payable percentage moves money just as fast. On that 5 kg 18K lot holding 3,750 grams of fine gold, worth AED 1,833,000 at AED 488.80 a gram, one percentage point of payable is AED 18,330. The difference between a 95% payable and a 99% payable on one lot is AED 73,320. UAE refiners do not publish payable ladders, refining charges or melt-loss allowances, so we are not going to quote a market rate here. Get them in writing, per metal, before you commit.

When should the price be fixed?

2026 has punished anyone who left pricing open. Gold's nominal record of USD 5,602.22 an ounce was set on 28 January 2026. By 4 October 2026 it traded at USD 4,139.80, a drawdown of roughly 26% in about eight months. Silver's record of USD 121.67 an ounce was set on 29 January 2026, and by 5 October 2026 it sat near USD 61, roughly half. Even inside one week, gold per kilo ran from USD 137,782.35 to USD 132,179.44 in the week to 2 October 2026, a move of 3.31%.

Local retail tells the same story. The Dubai 24K rate fell from AED 539.25 a gram on 4 September 2026 to AED 499.00 on 5 October 2026, a drop of 7.5% in thirty days. Apply that AED 40.25 a gram move to 3,750 grams of fine gold and the swing on a single 5 kg lot is AED 150,938. On 5 kg of sweeps assaying 8%, the same month costs AED 16,100. Anyone who has watched the same volatility hit base metals this year will recognise the pattern from our note on copper scrap pricing against the LME run.

So name the fixing point in the contract. The four workable options are: fix on receipt and weigh-in, fix on assay sign-off, fix at a named LBMA auction on a stated date, or seller's option within a defined number of working days. Any of the four is defensible. "We will price it when we are done" is not.

What should you ask a refiner before sweeps leave your floor?

1. Do you incinerate, mill and homogenise sweeps before sampling, and may our representative witness the melt?
2. Is a retained referee sample provided, and for how long is it held?
3. Which assay method is contractual for settlement, fire assay by cupellation, XRF or ICP?
4. What is the stated turnaround in working days for clean jewellery scrap, and separately for low-grade sweeps?
5. Is a melt-loss allowance deducted, and at what percentage for filings, sweeps and plated rejects?
6. Is the refining charge quoted per kilogram of lot, per gram of recovered fine metal, or as a percentage, and is there a minimum lot charge?
7. What is the payable percentage for gold, silver, platinum and palladium, and below what content are silver or platinum-group metals not paid at all?
8. How many days from assay sign-off to cleared funds, and can settlement be made in metal rather than cash?
9. Which umpire laboratory applies in a dispute, who pays for it, and what tolerance triggers it?

Ask the same nine questions of two refiners and the spread in the answers will usually be worth more than the headline payable. For material that mixes precious and base metal recovery, the same discipline applies to other high-value residues, including the economics we set out for solar panel scrap in the UAE.

Red flags: how to spot an unlicensed cash buyer

1. They do not ask for identification. Obtaining Emirates ID or passport for cash at or above AED 55,000 has been a live duty since 12 June 2021.
2. They offer to split payment across days or entities to stay under AED 55,000. Linked transactions are covered.
3. They cannot name their goAML registration or their money laundering reporting officer.
4. They cannot produce a current third-party assurance statement and management report.
5. They refuse to issue a signed weight ticket on receipt, or refuse a witnessed melt.
6. They are not on the live UAE Good Delivery or Dubai Good Delivery list and cannot explain why.
7. They price off the Dubai retail rate with a vague discount rather than off spot with a stated payable and charge.
8. They propose to collect sludges, sweeps or plating residues themselves without showing a hazardous waste transport permit.
9. They want to settle a six or seven figure lot entirely in cash.
10. They will not sign a chain-of-custody document or accept a source-of-goods declaration.

What does your finance team need in the audit file?

• Buyer trade licence with activity codes, plus evidence of dealer registration in goAML.
• Buyer accreditation status and the current assurance statement and management report.
• Your source-of-goods declaration: what the material is, which production process generated it, over what period.
• Gross weight ticket signed at receipt, with seal numbers and photographs.
• Homogenisation and melt record, plus the retained referee sample receipt.
• Assay certificate naming the method, the laboratory and the date.
• Settlement statement showing gross weight, melt loss, fine content by metal, payable percentage, refining charge, net AED, the price-fixing date and the spot reference used.
• Proof of payment through a traceable banking channel, with the report filing reference where applicable.

Two items need checking rather than assuming. First, polishing sweeps, floor sweeps, spent plating solution and furnace residues can be valuable precious metal feed and classified hazardous waste at the same time, so confirm the transport permit and manifest position with Dubai Municipality, MOCCAE, Tadweer in Abu Dhabi or the Sharjah authorities for your specific stream before a truck moves. Second, the UAE applies a reverse-charge mechanism to certain gold and precious metals supplies between registered businesses and the rules have been amended, so get the current VAT treatment of residue sales confirmed with the Federal Tax Authority rather than copying last year's invoice.

Where does a marketplace help, and where does it not?

We will be direct about the limits. The legal buyer of your gold-bearing residue must be a registered dealer, and for anything beyond small lots that means an audited refiner. A marketplace does not replace that licence. What it does is fix the two problems that sit either side of the refining contract: finding counterparties whose identity you can verify, and moving money without taking cash. Our listings run on UAE PASS KYC verification, escrow through MyFatoorah, and a 48-hour buyer inspection window, with audit-ready records attached to each transaction. Metals listings are open to browse in the metals category.

The inspection window covers the lot as received: weight, seals and visual conformity to the declared description. It does not cover the assay outcome, which lands days later. That is what the umpire clause is for. And at a ticket size of AED 1.74 million to 1.81 million for a single 5 kg 18K lot, confirm escrow limits and fees before you assume one rail carries the whole value. A sensible split is escrow for the sample or consignment stage and bank settlement against the assay certificate for the balance.

Frequently asked questions