# Precious Metals and Stones Dealer Registration: Hong Kong, Singapore, UAE

> How dealers in precious metals and stones register in Hong Kong, Singapore and the UAE: HK$120,000, S$20,000 and AED 55,000 thresholds, cash transaction reports, supervision and penalties.

Author: Gordey Bolotko — Partner, Corporate & Commercial (https://wiki.private.law/en/authors/bolotko)
Last modified: 2026-10-05T00:00:00.000Z
Canonical: https://wiki.private.law/en/precious-metals-dealer-registration
Publisher: wiki.private.law (https://wiki.private.law)
Version: 072f8580fe362ecc469831df7767212a1ed003b4123911b8949c7dac2d25ecc2
Cite as: Precious Metals and Stones Dealer Registration: Hong Kong, Singapore, UAE. wiki.private.law. https://wiki.private.law/en/precious-metals-dealer-registration. Version 072f8580fe362ecc469831df7767212a1ed003b4123911b8949c7dac2d25ecc2.
Topics: structures, investments
Jurisdictions: hong-kong, singapore, uae
Functional tags: license
Product tags: compliance, company, investment
Semantic tags: license, compliance, company, investment

---

## Concept

**Registration of dealers in precious metals and stones** is an anti-money-laundering regime for a trading business: jewellers, bullion traders, refiners, wholesalers, auction houses and platforms that sell physical metal, stones and products made from them. FATF standards place these dealers among designated non-financial businesses and professions (DNFBPs), and Hong Kong, Singapore and the UAE have each built a separate regime for them, with its own register or record, supervisor and monetary threshold.

The reason is simple: gold and stones are valuable, compact and cross borders easily, and the retail trade in them has historically run on cash. The UAE Ministry of Economy and Tourism, in its [2026 sector guidance](https://www.moet.gov.ae/documents/20121/469920/Supplemental+Guidance+for+Dealers+in+Precious+Metals+%26+Stones+-+2026.pdf), cites the 2024 national risk assessment: high inherent money-laundering risk and a medium-high residual rating. Hong Kong Customs, explaining its regime, points to [a case it uncovered](https://www.drs.customs.gov.hk/img/medias/New_Registration_Regime_for_DPMS_en.pdf) of suspected laundering of about HK$3.5 billion through precious-metals trading.

### What registration gives and what it does not

Registration shows that a dealer is part of the anti-money-laundering system: it checks customers on large cash deals, keeps records, reports suspicious transactions and, depending on the country, reports every large cash transaction. It gives no right to offer investment products. Singapore's Ministry of Law expressly bars registered dealers from [presenting registration as supervision](https://acd.mlaw.gov.sg/regulated-dealers/regulation-coverage/) of anything beyond anti-money laundering and counter-terrorist financing, and warns that the Ministry neither approves nor regulates metal investment schemes.

This is how dealer registration relates to [financial licences](https://wiki.private.law/en/financial-licenses): it is a neighbouring regime under the same anti-money-laundering legislation, without prudential supervision. Once metal is packaged into a security, a collective scheme, a derivative contract or a virtual asset, financial regulation takes over.

### Three entry models

The three jurisdictions solve the same problem with different tools.

**Hong Kong: the threshold opens registration**

A dealer must register once it transacts HK$120,000 or more. Category A covers non-cash dealing only, Category B adds cash, and only Category B is under AML supervision.

**Singapore: registration for everyone**

Every dealer must register before trading, whatever its turnover. The S$20,000 threshold triggers customer checks and a report on the specific cash deal.

**UAE: recorded by licensed activity**

Onshore and in the commercial free zones the licensing authority records the dealer by activity; it registers on goAML and reports deals from AED 55,000. DIFC and ADGM have their own supervisors.

### Key parameters

The table sets the main parameters of the three regimes side by side.

| Parameter | Hong Kong | Singapore | UAE |
| --- | --- | --- | --- |
| Law and authority | AMLO (Cap. 615), Customs and Excise Department | PSPM Act 2019, Registrar at the Ministry of Law | Federal Decree-Law No. 10 of 2025; Ministry of Economy and Tourism, in DIFC the DFSA, in ADGM the FSRA |
| Who registers | A dealer transacting HK$120,000 or more | Every dealer before it starts trading | A company whose licence covers precious-metals trading: recorded by its licensing authority and on goAML |
| Threshold for AML measures | Cash of HK$120,000 or more | Cash exceeding S$20,000 | Cash and cash equivalents of AED 55,000 or more |
| Transaction report | Non-Hong Kong dealers only, within one day | Cash transaction report within 15 business days | DPMSR on goAML; for companies, wire transfers too |
| Term and conditions | A — open-ended while the annual fee is paid; B — normally 3 years | Renewed annually | Recorded by licensed activity, subject to security clearance |
| Dealing unregistered | Fine up to HK$100,000 and up to 6 months' imprisonment | Fine up to S$75,000, up to 3 years' imprisonment, or both | No goAML registration: fine of AED 50,000 – 200,000 |

The table shows the main difference: in Hong Kong the threshold decides whether registration is needed at all, while in Singapore and the UAE it only decides when mandatory measures apply to a deal.

## One deal in three jurisdictions

The mechanics are easiest to follow on one example. A trading company sells a gold bar to a walk-in buyer who pays in cash, just above the local threshold.

| Stage | Hong Kong | Singapore | UAE |
| --- | --- | --- | --- |
| Seller's status | Category B registrant | Registered dealer, Class B | Trading company recorded by its licensing authority and registered on goAML |
| Before the deal | Customer due diligence under Schedule 2 to the AMLO, copy of the ID | Prescribed customer due diligence before the transaction | Buyer's ID: Emirates ID or passport |
| After the deal | Records kept at least 5 years; on suspicion, a report to the JFIU | Report to the STRO within 15 business days, copy to the Registrar | DPMSR on goAML; records kept at least 5 years |

Splitting the payment changes nothing. Hong Kong treats as [linked](https://www.customs.gov.hk/hcms/filemanager/en/content_289/Registration_Guide.pdf) one customer's purchases with split invoices, and purchases by several people acting for one person. Singapore adds up sales to one customer in a single day. The UAE guidance works through instalments, deposits and payment in kind, where each part is below the threshold and the total is above it.

## Hong Kong: two categories of registration

The regime was introduced by amendments to the [Anti-Money Laundering and Counter-Terrorist Financing Ordinance](https://www.customs.gov.hk/en/service-enforcement-information/anti-money-laundering/supervision-of-dealers-in-precious-metals-and-ston/index.html) (AMLO, Cap. 615) and has applied since 1 April 2023. The Customs and Excise Department registers and supervises dealers.

### What triggers registration

A person must register if it carries on a precious metals and stones business in Hong Kong and transacts HK$120,000 or more, including the equivalent in another currency. Payments made and received both count, whether in a single operation or in several linked ones. A dealer whose transactions stay below the threshold, cash or non-cash, needs no registration.

The regime's subject matter is wide. Precious metals are gold, silver, platinum, iridium, osmium, palladium, rhodium and ruthenium; precious stones are diamond, sapphire, ruby, emerald, jade and pearl, natural or otherwise; precious products are jewellery and watches containing them. The fourth category is precious-asset-backed instruments: certificates entitling the holder to the metal, stones or products. A dealer is anyone who trades, imports or exports, manufactures, refines, issues or redeems such instruments, or acts as an intermediary in these activities. A logistics business that only imports or exports valuables in the ordinary course of that business is excluded.

Those exempt from registration (s. 53ZUA AMLO) include authorized institutions and licensed pawnbrokers, as well as SFC licensed corporations, insurers, insurance intermediaries and SVF licensees where the precious-metals business is ancillary to their principal business.

### Category A and Category B

The difference between the categories is cash.

| Category | When required | Supervision and term | Fees |
| --- | --- | --- | --- |
| A | Non-cash transactions of HK$120,000 or more only | No AML supervision; valid while the annual fee is paid | HK$260 to apply, HK$195 a year |
| B | Cash and non-cash transactions of HK$120,000 or more | AML supervision by Customs; normally 3 years, renewal at least 60 days before expiry | HK$1,970 plus HK$650 for each person subject to the fit and proper test |

Category A is a simple registration for dealers that settle only through banks. Category B is a supervised status carrying the full set of anti-money-laundering duties.

### Duties of a Category B registrant

The Customs guidance reduces the duties of a Category B registrant to a few standing requirements.

- The registrant, its partners, directors and ultimate owners remain fit and proper throughout the registration.
- A new partner, director or ultimate owner obtains Customs' written approval in advance.
- On a cash transaction of HK$120,000 or more, the registrant performs due diligence under Schedule 2 to the AMLO, copies the ID and keeps records for at least five years.
- The registrant appoints a compliance officer and a money laundering reporting officer (MLRO).
- Suspicious transaction reports go to the Joint Financial Intelligence Unit (JFIU).
- An annual return covering the previous calendar year is filed with Customs.
An ultimate owner is an individual who directly or indirectly owns or controls more than 25% of the capital or voting rights, or exercises ultimate control over management. Through this definition the fit and proper test reaches the beneficial owners behind a corporate dealer.

### Non-Hong Kong dealers

A non-resident with no place of business in Hong Kong that deals there for no more than 60 days in a calendar year is exempt from registration. Instead, it files a report on each cash transaction of HK$120,000 or more within one day, or before leaving Hong Kong if that is earlier. A local registrant files no such report: it reports to the JFIU on suspicion.

### Sanctions

The Hong Kong regime combines criminal liability with Customs' disciplinary powers.

| Breach | Consequence |
| --- | --- |
| Transacting without registration or claiming to be a registrant | Fine up to HK$100,000 and up to 6 months' imprisonment |
| Non-Hong Kong dealer fails to file a cash transaction report | Fine up to HK$50,000 and up to 3 months' imprisonment |
| Category B registrant breaches Schedule 2 to the AMLO or registration conditions | Public reprimand, remedial order, pecuniary penalty up to HK$500,000 |
| Remedial order not complied with on time | Up to HK$10,000 for each day of default |

Where a director caused the contravention, the same disciplinary powers apply to the director personally.

## Singapore: registration for all, threshold for deals

Singapore regulates dealers under the [Precious Stones and Precious Metals Act](https://sso.agc.gov.sg/Act/PSPMPMLTFPFA2019) 2019 (PSPM Act), in force since 10 April 2019. In its current version (last amended by Act 6 of 2024, from 1 May 2024) the Act's title also covers proliferation financing. The Registrar of Regulated Dealers sits in the Ministry of Law's Anti-Money Laundering/Countering the Financing of Terrorism Division (ACD).

### Who is a regulated dealer

A [regulated dealer](https://acd.mlaw.gov.sg/regulated-dealers/regulatory-regime/) is any person carrying on a business of selling, purchasing for resale, importing for sale, possessing for sale or manufacturing precious stones, metals and products, of selling or redeeming asset-backed tokens, or of acting as an intermediary in such business. Auction houses and trading platforms count as intermediaries. Alloys with at least 2% by weight of a precious metal count as precious metal; a product counts as precious if it derives 50% or more of its value from stones or metal, or costs more than S$20,000.

There is no threshold for registration: s. 6 of the Act prohibits acting as, or holding oneself out as, a regulated dealer without registration. Exempt are pawnbrokers, persons licensed or regulated by MAS, and foreign dealers doing business in Singapore for no more than 90 days a year. A foreign dealer must still carry out customer due diligence, keep records and file cash and suspicious transaction reports.

### Registration classes and fees

Registration comes in two classes and is renewed annually; [fees](https://acd.mlaw.gov.sg/regulated-dealers/registration/) are charged per outlet.

| Class | Condition | Annual fee |
| --- | --- | --- |
| A | Every item sold costs less than S$2,000 | S$250 per outlet |
| B | No value limit | S$350 per outlet |

A first application adds a S$120 fee, and processing takes about four weeks. The application discloses directors, partners, managers, the company secretary, substantial shareholders and the compliance officer, and, for multi-layered structures, the ownership chain up to individuals.

### A cash deal above the threshold

The Act's key concept is the designated transaction: a sale for which the dealer receives cash or a cash equivalent [exceeding S$20,000](https://sso.agc.gov.sg/Act/PSPMPMLTFPFA2019?ProvIds=pr15-), two or more sales to the same customer in a single day for that total, or a secondhand dealer's cash purchase from a member of the public above the threshold. Before such a transaction the dealer performs prescribed customer due diligence (s. 16), and afterwards files a cash transaction report with the Suspicious Transaction Reporting Office (STRO), copying the Registrar (s. 17).

The Ministry sets out the deadlines in its [Guidelines for Regulated Dealers](https://isomer-user-content.by.gov.sg/473/be58a019-5dc4-4779-b186-62f68f9d1c56/guidelines_for_regulated_dealers_120526_v5_1.pdf) (version 5.1 of 12 May 2026): a cash transaction report within 15 business days, a suspicious transaction report as soon as reasonably practicable and no later than five business days, and within one business day for sanctions cases. A semi-annual return with the current risk assessment and internal policies is due within one month after each half-year, that is, in January and July.

### Sanctions and supervisory practice

The Act separates criminal liability from the Registrar's measures.

| Breach | Consequence |
| --- | --- |
| Dealing without registration (s. 6) | Fine up to S$75,000, up to 3 years' imprisonment, or both; up to S$7,500 for each day it continues |
| No customer due diligence before a designated transaction (s. 16) | Fine up to S$100,000 |
| No cash transaction report, or an incomplete one (s. 17) | Fine up to S$20,000, up to 2 years' imprisonment, or both |
| Breach of registration conditions or of non-criminal provisions (s. 10) | Cancellation, suspension up to 6 months, financial penalty up to S$100,000 |

[Section 10](https://sso.agc.gov.sg/Act/PSPMPMLTFPFA2019?ProvIds=pr10-) also lists, as a separate ground for cancellation or suspension, using the registration in a way that creates an impression of supervision beyond AML.

In September 2026 the Ministry used both measures. On 11 September it [cancelled the registration](https://acd.mlaw.gov.sg/news/mlaw-cancels-spme-registration-as-registered-dealer/) of Singapore Precious Metals Exchange: after serious breaches in risk assessment, customer due diligence and ongoing monitoring, the Registrar found that its continued business was not in the public interest. On 14 September the Ministry [suspended](https://acd.mlaw.gov.sg/news/the-registrar-of-regulated-dealers-suspends-the-registrations-of-puregold-sg-pte--ltd---puregold-sg-international-mint-pte--ltd---puregold-singapore-pte--ltd---puregold-sg-mint-pte--ltd--and-goldpay-sg-pte--ltd-/), for up to six months, the registrations of five companies — four companies of the Puregold group and Goldpay — over serious deficiencies in customer due diligence and risk management.

## UAE: registration by activity, threshold for deals

In 2025 the UAE renewed its anti-money-laundering framework. [Federal Decree-Law No. 10 of 2025](https://www.moet.gov.ae/documents/20121/0/Federal+Decree+by+Law+No.+%2810%29+of+2025+Regarding+Anti-Money+Laundering%2C+....pdf/f1b57509-f374-822c-daa6-f3e15da756f7?t=1779431480167), issued on 30 September 2025, repealed Decree-Law No. 20 of 2018, and [Cabinet Resolution No. 134 of 2025](https://www.moet.gov.ae/documents/20121/0/Cabinet+Resolution+No.+%28134%29+of+2025+Regarding+the+Executive+Regulations+of+Federal+Decree+by+Law+No.+%2810%29+of+2025+Regarding+Anti-Money+Laundering%2C+and+Combating+the+Financing+of+Terrorism+and+Proliferation++%281%29.pdf/14685a2d-5a5c-fb21-95ef-0756fef890f8?t=1769671101654) of 29 October 2025 replaced the earlier executive regulations, Cabinet Decision No. 10 of 2019.

Two things need to be kept apart in the UAE. Recording of the dealer and goAML registration follow from the licensed activity. The threshold governs something else: mandatory measures on a deal — customer due diligence and a report — apply when the dealer carries out a cash transaction, or several linked ones, of AED 55,000 or more. The Ministry's [2026 guidance](https://www.moet.gov.ae/documents/20121/469920/Supplemental+Guidance+for+Dealers+in+Precious+Metals+%26+Stones+-+2026.pdf) treats cash equivalents as cash: cashier's cheques and other bearer negotiable instruments, and goods taken in part-exchange.

### Who registers and who supervises

Onshore and in the commercial free zones there is no separate permit for trading metal: a company operates under a trade licence from an emirate authority or a free zone, and it is recorded by the activity stated in that licence. [Ministerial Decision No. 253 of 2025](https://www.moet.gov.ae/documents/20121/0/%D8%A7%D9%84%D9%82%D8%B1%D8%A7%D8%B1.pdf/453868ac-37c5-b24d-e614-ca100b5e7e89?t=1774849088077), issued on 11 December 2025, gives licensing authorities four duties.

- Determining with the Ministry which activities fall within DNFBPs, and registering such companies under the Ministry's supervision (Art. 2).
- Security clearance of all related persons, including non-residents, on registration and on any change, and verification of the ownership structure up to the beneficial owner (Art. 3).
- Screening of related persons against UN and national sanctions lists (Art. 4).
- Records of applications received, approved and refused, reported to the Ministry (Art. 6).
Registration can therefore end in refusal. The Ministry supervises dealers onshore and in the commercial free zones, which its sector [guidance](https://www.moet.gov.ae/documents/20121/469920/Supplemental+Guidance+for+Dealers+in+Precious+Metals+%26+Stones+-+2026.pdf) covers.

> 💡 DMCC, the country's largest gold cluster with more than 1,500 precious-metals member companies, [states itself](https://dmcc.ae/hubfs/July%202025%20Business%20Fact%20Sheets/Business%20Fact%20Sheet_Gold%20and%20Precious%20Metals_2025_07.pdf?hsLang=ar) that it is not involved in regulating the gold industry: regulation is carried out at federal level by the Ministry. The free zone issues the trade licence and runs the infrastructure; the Ministry oversees the dealer's anti-money-laundering duties.

The Ministry [requires goAML registration](https://www.moet.gov.ae/en/registering-companies-in-goaml) — the Financial Intelligence Unit's system for suspicious transaction reports and threshold reports — from every DNFBP, and its questionnaire identifies a dealer by activity, not by cash. A wholesaler that settles only through banks therefore registers too. [Cabinet Resolution No. 71 of 2024](https://www.moet.gov.ae/documents/20121/0/Cabinet+Resolution+No.%2871%29+of+2024+Regulating+Violations%2C+Administrative+Penalties+Imposed+on+Violators+of+Measures+for+Confront.pdf/a20a7f19-088b-d0dc-3908-a733c5c0ba2e?t=1737017239826) set a fine of AED 50,000 to AED 200,000 for failing to register. It was made under the previous law and applies until replaced: Art. 41 of Decree-Law No. 10 keeps earlier resolutions in force insofar as they do not conflict with the new law.

### The DPMSR report

Since 12 June 2021, under the Ministry's [Circular No. 08/AML/2021](https://www.moet.gov.ae/documents/20121/294745/Circular+No.+8-2021+for+DPMS+goAML+Circular.pdf/a8c348ed-b588-5a6b-e219-fadaace704d8?t=1673858893648), a dealer obtains the customer's ID and files a Dealers in Precious Metals and Stones Report (DPMSR) on goAML in three cases; records are kept for at least five years.

- A cash transaction with a resident individual of AED 55,000 or more.
- A cash transaction with a non-resident individual of AED 55,000 or more.
- A transaction with a company of AED 55,000 or more, in cash or by wire transfer.
The report does not depend on risk and is filed even when due diligence raised no concerns. The 2026 guidance also warns that the threshold is a minimum legal trigger: below it the dealer still applies risk-based measures, and transactions split to avoid the threshold are scrutinised whatever their value.

### Sanctions

Article 17 of Decree-Law No. 10 allows the supervisor to issue a warning, impose a fine of AED 10,000 to AED 5,000,000 per violation, ban the violator from the sector, restrict or suspend managers, suspend the activity, revoke the licence and publish the penalties imposed. The fine may increase for a repeat violation within a year.

### DIFC and ADGM

The financial free zones work differently. In DIFC a dealer in precious metals and stones registers with the DFSA as a DNFBP: in June 2023 the DFSA [fined](https://www.dfsa.ae/news/dfsa-takes-action-against-two-firms-regulatory-breaches) Alessandro Faro Trading USD 25,200 (AED 92,610) after a settlement discount for dealing in precious metals and stones without ever having registered. In ADGM dealers in precious metals or precious stones are subject to the [FSRA's AML rules](https://assets.adgm.com/download/assets/Key+AML+CFT+CPF+Obligations.pdf/28cd2c304a9d11f1b7250e13429a42cc) alongside other DNFBPs. Ministerial Decision No. 253 covers only DNFBPs under the Ministry's supervision.

> ⚠️ The regime's risks sit in details that are easy to miss. In Hong Kong linked operations are aggregated, so a series of linked cash payments of HK$100,000 can require Category B registration. In Singapore an expired registration cannot be renewed; a new application is needed. In the UAE a DPMSR on a company deal is due even when it pays by wire. In Singapore, describing oneself as "regulated by the Ministry" without the AML qualifier is a ground for suspension or cancellation.

## The boundary with a financial licence

All three regimes end where metal becomes a financial product. Hong Kong excludes from precious-asset-backed instruments securities, futures contracts, interests in collective investment schemes, structured products, OTC derivatives and virtual assets. Singapore likewise excludes from asset-backed tokens securities, derivatives contracts, commodity contracts and digital payment tokens under the Payment Services Act (PSA).

> 🧭 A certificate for a specific bar that a dealer sells and redeems stays within the dealer regime. A gold token that qualifies as a virtual asset moves to the virtual-asset service provider regime — for Hong Kong see [Hong Kong: virtual-asset dealing and custody licences](https://wiki.private.law/en/hk-virtual-asset-dealing-custody), for Singapore's payment regime for digital payment tokens see [Singapore's PSA payment licences](https://wiki.private.law/en/singapore-psa-payments). In Dubai outside DIFC, issuing a token referenced to a real-world asset (ARVA) [is a Category 1 issuance](https://rulebooks.vara.ae/entiresection/472) requiring a VARA licence. A fund, structured product or derivative on metal falls under securities law: the SFO in Hong Kong, the SFA in Singapore.

The boundary also runs the other way: banks in Hong Kong and MAS-licensed or regulated persons in Singapore are exempt from dealer registration. The UAE's financial licences — CBUAE, VARA, DFSA, FSRA and SCA — are mapped in the [UAE licence map](https://wiki.private.law/en/uae-license-map).

Storing metal is a separate subject. Where and how to hold bars, how allocated differs from unallocated and what a freeport offers are covered in [Precious metals vaults and freeports](https://wiki.private.law/en/precious-metals-vaults). Dealer registration concerns only those who buy and sell metal as a business.

> ⚠️ The dealer's supervisor is not the only one checking where metal comes from. The EU prohibits buying, importing and transferring gold of Russian origin exported from Russia after 22 July 2022 (Art. 3o of Regulation (EU) No 833/2014; see [Precious metals vaults and freeports](https://wiki.private.law/en/precious-metals-vaults)), and a European buyer or vault will ask for supply-chain documents. In the UAE, [Ministerial Decree No. 68 of 2024](https://www.moet.gov.ae/documents/20121/376320/Ministerial+Decree+No.+%2868%29+of+2024.pdf/b349cc52-534c-cffc-8c71-ad55d5c9c334?t=1717189374321) requires refiners and gold supply-chain participants, dealers included, to run a due diligence policy on responsible sourcing.

The rest of a dealer's anti-money-laundering work — risk assessment, source-of-funds checks, sanctions screening, training — is built from the same elements as a financial licensee's: roles and systems are described in [Compliance stack for a licensed operator](https://wiki.private.law/en/compliance-stack), and checks on a customer's money in [Source of funds and source of wealth](https://wiki.private.law/en/source-of-funds).

> 🍓 The three jurisdictions measure the same risk differently. Hong Kong brings a dealer into the regime on any payment of HK$120,000 or more and supervises only cash dealing, Singapore registers every dealer and requires a report on cash exceeding S$20,000, and the UAE, onshore and in the commercial zones, records the dealer by activity and collects reports from AED 55,000, including wire payments by companies; in DIFC and ADGM the dealer answers to the DFSA and the FSRA.

## Q/A

### Registration

### Does a Hong Kong dealer need registration if customers pay only by bank transfer?

Yes, if transactions reach HK$120,000: it needs Category A. This is a simple registration without AML supervision, with a HK$260 application fee and a HK$195 annual fee. Category B is needed only if the dealer receives or pays HK$120,000 or more in cash.

### Does a small Singapore jeweller without large cash deals need registration?

Yes. Singapore law requires every regulated dealer to register before trading, whatever its turnover. If every item costs less than S$2,000, Class A applies, at S$250 per outlet a year.

### Does DMCC authorise gold trading for AML purposes?

No. DMCC is a commercial free zone: it issues the trade licence, while the Ministry of Economy and Tourism supervises the dealer's anti-money-laundering duties, unlike in the financial free zones of DIFC and ADGM. The company registers on goAML and files DPMSRs in the same place as a dealer with an onshore licence.

### Where does a dealer in DIFC or ADGM register?

In DIFC, with the DFSA as a DNFBP; dealing unregistered is fined, as in the 2023 Alessandro Faro Trading case (USD 25,200 after discount). In ADGM the dealer is subject to the FSRA's AML rules. Ministerial Decision No. 253 covers only DNFBPs under the Ministry's supervision.

### Does a wholesaler without cash deals need goAML registration?

Yes. The Ministry requires goAML registration from every DNFBP and identifies a dealer by activity, not by cash; failing to register carries a fine of AED 50,000 – 200,000. The AED 55,000 threshold triggers measures on a specific deal, not registration.

### Are a dealer's owners vetted?

Yes, in all three countries. In Hong Kong the fit and proper test covers directors and ultimate owners holding more than 25%, and a new owner needs Customs' prior approval. In Singapore the application discloses substantial shareholders and the ownership chain up to individuals. In the UAE the licensing authority obtains security clearances for all related persons, including non-residents.

### Transactions and reporting

### Must a Hong Kong registrant report every large cash transaction?

No. A local Category B registrant performs due diligence, keeps records and reports suspicious transactions to the JFIU. A report on the cash transaction itself of HK$120,000 or more is filed only by a non-Hong Kong dealer operating without registration, within one day or before leaving.

### How is the threshold counted when payment is made in parts?

By the total of linked operations. Hong Kong aggregates operations that are linked or appear to be linked. Singapore adds up sales to one customer in a single day. The UAE guidance treats instalments and deposits as a transaction above the threshold where the total exceeds AED 55,000, even though each payment is smaller.

### Do the three thresholds mean the same thing?

No. Hong Kong and the UAE apply an "at or above" test: HK$120,000 or AED 55,000 and more. Singapore applies "exceeding" S$20,000. In the UAE the threshold for company deals also covers wire transfers, while in Hong Kong and Singapore the mandatory transaction measures are tied to cash.

### The boundary with financial regulation

### Can a dealer registration be used to sell gold investment products?

No. Registration covers physical metal, stones, products and certificates for specific assets. Securities, funds, derivatives and virtual assets based on metal fall under securities and virtual-asset law, and dealer registration does not extend to them.

### Does a bank or broker need a separate dealer registration?

In Hong Kong banks are fully exempt, and SFC licensed corporations are exempt where the metals business is ancillary to their regulated activity. In Singapore every person licensed or regulated by MAS is exempt.

---

## Factual claims

- The regime was introduced by amendments to the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO, Cap. 615) and has applied since 1 April 2023. The Customs and Excise Department registers and supervises dealers.
- A person must register if it carries on a precious metals and stones business in Hong Kong and transacts HK$120,000 or more, including the equivalent in another currency.
- An ultimate owner is an individual who directly or indirectly owns or controls more than 25% of the capital or voting rights, or exercises ultimate control over management.
- A non-resident with no place of business in Hong Kong that deals there for no more than 60 days in a calendar year is exempt from registration.
- There is no threshold for registration: s. 6 of the Act prohibits acting as, or holding oneself out as, a regulated dealer without registration.
- A first application adds a S$120 fee, and processing takes about four weeks.
- Section 10 also lists, as a separate ground for cancellation or suspension, using the registration in a way that creates an impression of supervision beyond AML.
- In September 2026 the Ministry used both measures.

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