Bullion dealers, refiners, mints, scrap-metal buyers and commodity-finance banks are regulated entities under national AML laws and the FATF Recommendations — most importantly Recommendation 22 covering dealers in precious metals and stones. Listed below, alphabetical by short name, are the supervisors, financial intelligence units and standard-setting bodies whose mandate directly covers the metals sector. Each entry cites the body's own published mandate page.
FATF Recommendation 22 extends customer due diligence obligations to DNFBPs, and Recommendation 23 requires those same DNFBPs to file suspicious transaction reports (STRs) — explicitly stating that dealers in precious metals and dealers in precious stones should be required to report suspicious transactions when they engage in any cash transaction with a customer equal to or above the applicable designated threshold (CFATF, FATF Recommendation 23 — DNFBPs: Other Measures). The FATF Interpretive Note to Recommendations 22-23 fixes the designated threshold for casinos at USD/EUR 3,000 and for dealers in precious metals and precious stones at USD/EUR 15,000 for cash transactions, and requires that transactions carried out in a single operation or in several operations that appear to be linked be aggregated against that threshold — a structuring-resistance mechanic aimed squarely at cash-splitting through repeat visits or shell counterparties.
Because the FATF standard is a floor, not a ceiling, individual jurisdictions calibrate their own DPMS triggers above it. The UAE's AML-CFT Decision No. (20) of 2018 sets a domestic DPMS threshold of AED 55,000 (roughly USD 15,000 at the pegged rate, but assessed independently under UAE law) for single or linked transactions, and requires that any object where 50% or more of its monetary value derives from precious metals or stones be treated as a PMS for AML purposes regardless of whether the trading form is physical or virtual (Dubai Diamond Authority, DPMS AML/CFT Guidance). The UAE Ministry of Economy's Supplemental Guidance for Dealers in Precious Metals & Stones — 2026 reaffirms the AED 55,000 DPMSR (Dealers in Precious Metals and Stones Report) filing trigger for transactions with resident individuals and layers on Kimberley Process Certification Scheme (KPCS) verification requirements for rough diamonds and origin-verification obligations for gold, with enhanced scrutiny specifically flagged for "scrap" or personal-holding gold claims that do not match commercial trading volumes (UAE Ministry of Economy, Supplemental Guidance for Dealers in Precious Metals & Stones, 2026).
UAE Ministry of Economy Circular No. (8) of 2025, dated 25 December 2025, explicitly names "dealers of precious metals and precious stones" among the DNFBPs required to apply enhanced due diligence and countermeasures against FATF's grey-listed and black-listed jurisdictions, cross-referencing FATF's official October 2025 increased-monitoring list (UAE Ministry of Economy, Circular No. 8 of 2025; FATF, High-Risk and Other Monitored Jurisdictions — Increased Monitoring, October 2025). The UAE itself was removed from FATF's grey list in February 2024, a decision criticized as premature by watchdog groups citing continued evidence of the country's role as a transit and refining hub for gold of contested origin (FATF, Increased Monitoring List, October 2025). The tension between formal grey-list exit and continued DPMS-specific countermeasure obligations is precisely why TSM's counterparty due diligence framework treats UAE gold-refinery provenance as a distinct risk tier, independent of the jurisdiction's headline FATF status.
Post-2018 UAE refinery reform has moved to close the gap: leading refiners including Al Etihad Gold, Emirates Gold, and SAM Precious Metals have aligned responsible-sourcing programs with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and now mandate annual third-party assurance reviews under approved conformance schemes (Golden Ark Reserve, UAE Gold Refining Reforms, 9 May 2026).
FATF amended Recommendation 15 in October 2018 to explicitly bring virtual assets and virtual asset service providers (VASPs) within the AML/CFT perimeter, and operationalized the change through the June 2019 Interpretive Note to Recommendation 15 (INR.15). FATF's October 2021 updated guidance expanded implementation detail across six areas: VA/VASP definitional scope, application to stablecoins, tools for addressing peer-to-peer and unhosted-wallet risk, updated licensing/registration guidance, Travel Rule implementation guidance, and principles for information-sharing among VASP supervisors. The Travel Rule itself sets a USD/EUR 1,000 threshold above which the originating VASP must transmit the originator's name, account or wallet address, and physical address or unique identifying number, plus the beneficiary's name and account or wallet address, to the beneficiary VASP before or simultaneously with the transfer (Elliptic, FATF's Virtual Asset Guidance: What You Need to Know).
FATF's June 2025 sixth targeted update on Recommendation 15 implementation, covering 67 jurisdictions responsible for an estimated 98% of global VASP activity, found that 97% of surveyed jurisdictions had completed a virtual-asset risk assessment, 90% were enacting or had enacted VASP licensing/registration regimes, but only 76% had actually licensed or registered VASPs in practice, and 85% were enacting or had enacted Travel Rule requirements (TRM Labs, FATF Updates on Recommendation 15 Implementation, June 2025). A broader FATF survey covering 117 jurisdictions found 85 (73%) had passed Travel Rule legislation, up from 65 the prior year, yet only 29% of jurisdictions were rated "largely compliant" with Recommendation 15 overall — up only marginally from 25% in 2024, underscoring how slowly enforcement-grade compliance is catching up to legislative intent seven years after the 2018 amendment (AMLBot, FATF Crypto Standards: Recommendation 15 Status, 25 May 2026).
FATF's March 2026 Targeted Report on Stablecoins and Unhosted Wallets reaffirmed that stablecoin issuers and the intermediary VASPs that facilitate their transfer are covered by Recommendation 15-aligned AML/CFT controls, closing a structuring ambiguity that tokenization platforms had previously used to argue that asset-referenced tokens sat outside the VASP definition (AMLBot, FATF Crypto Standards: Recommendation 15 Status, 25 May 2026). For metals tokenization specifically, this closes the same gap for gold-backed and silver-backed tokens: any issuer or intermediary facilitating transfer of a token redeemable for physical metal is treated as a VASP subject to the full Recommendation 15 obligation stack — risk assessment, licensing, customer due diligence, ongoing monitoring, sanctions screening, transaction monitoring, STR filing, recordkeeping, and Travel Rule compliance.
FinCEN Alert FIN-2022-Alert001, issued 16 March 2022 as "FinCEN Alert on Real Estate, Luxury Goods, and Other High-Value Assets Involving Russian Elites, Oligarchs, and Their Family Members," identifies four asset classes used to evade Russia-related sanctions: commercial and high-end residential real estate, artwork, precious metals, stones, and jewelry (PMSJ), and other high-value assets such as yachts and aircraft (FinCEN, Alert FIN-2022-Alert001, 16 March 2022). The alert specifically cautions that sanctioned Russian oligarchs may use PMSJ to evade sanctions because Russia is a major exporter of many of the raw materials used to produce them, directing financial institutions to scrutinize (i) transactions involving PMSJ trading companies with a nexus to sanctioned individuals, and (ii) high-value or frequent transactions tied to mining operations with opaque or complex corporate structures owned or controlled by sanctioned Russian persons. Financial institutions filing related suspicious activity reports are instructed to reference the key term "FIN-2022-RUSSIALUXURY" in Field 2 of the filing (FinCEN, Alert FIN-2022-Alert001). A companion FinCEN/BIS joint alert issued 24 June 2022 addresses export-control evasion tactics and directs related SAR filings to reference "FIN-2022-RUSSIABIS" (FinCEN and BIS, Joint Alert, 24 June 2022). Executive Order 14024 underpins both alerts, authorizing sanctions against persons using deceptive or structured transactions — including transactions in gold or other precious metals — to circumvent Russia-related sanctions.
A 2021 Global Witness investigation, based on an EY-conducted supply-chain compliance audit of Kaloti Jewellery International's 2012 operations, found that Dubai's largest gold refiner failed to report suspicious cash transactions totaling approximately US$5.2 billion over the course of a single year, and knowingly accepted roughly four tonnes of gold disguised as silver imported from Morocco under falsified paperwork, alongside inadequate supply-chain documentation for gold sourced from Sudan (The National, Dubai Refiner Kaloti Denies Report Over Gold-Sourcing Compliance). Kaloti disputed the conflict-gold sourcing characterization, with its managing director describing the underlying issues as "documentation anomalies" that were "swiftly rectified." The episode predates — and is widely credited as a catalyst for — the UAE's subsequent formalization of DPMS AML obligations under the 2018 AML-CFT Decision, its 2025 grey-list countermeasure circular, and the 2026 supplemental DPMS guidance detailed in Section 1 above, illustrating a decade-long regulatory-response arc from a single refiner's compliance breakdown to jurisdiction-wide structural reform.
No Wolfsberg Group publication addresses DPMS by name, but two of the Group's standing papers are directly transferable to bullion-bank and refiner counterparty risk. The Wolfsberg Guidance on Sanctions Screening sets out risk-based principles for calibrating screening programs against cross-border, trade-related, and payable-through exposures — the same fact pattern bullion trade finance and refiner settlement present (Wolfsberg Group, Guidance on Sanctions Screening, 2019). The Wolfsberg Trade Finance Principles, developed jointly with the ICC and BAFT, extend the same risk-based framework to letter-of-credit and documentary trade structures used to finance concentrate and refined-metal shipments (Wolfsberg Group, ICC and BAFT Trade Finance Principles). For tokenized-metals issuers building institutional onboarding flows, the practical takeaway is that counterparty due diligence on refiners and bullion banks should mirror correspondent-banking-grade rigor — beneficial-ownership transparency, supply-chain documentation, and sanctions-list screening — rather than relying on LBMA Good Delivery status as a standalone AML control.