Gold and precious metals carry some of the UAE's highest AML exposure. Here's how we keep the chain of custody clean.
BullionShield™ is FinComp's methodology for gold, precious metals and precious stones businesses — built to operationalise the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals, drawing on senior banking experience overseeing precious metals and commodity trade financial-crime exposure.
Long before an audit finding, there's an opportunity to protect market access.
A clean, demonstrable due-diligence trail is what keeps a dealer's relationships moving — with refiners who expect supply chain evidence, banks financing precious metals trade, and international buyers who increasingly ask for provenance before they ask for price. It isn't something that only matters once a review goes wrong.
As the UAE cements its position as one of the world's largest gold trading hubs, the market itself is raising the bar on provenance and responsible sourcing — regulators, refiners and exchanges are moving in the same direction. DPMS businesses that can show governance keep pace with that shift instead of being slowed by it.
That's what it means to transform compliance into a strategic business advantage — in the precious metals trade as much as anywhere else.
If your business touches gold, precious metals or precious stones, DPMS obligations are part of doing business.
Precious metals supply chains run from extraction through refining, trading and distribution — and compliance risk travels with the metal at every stage. Our methodology is built for businesses that need to demonstrate provenance and due diligence clearly, at whichever stage they sit.
Gold, precious metals & precious stones dealers
DMCC, Gold & Diamond Park and Deira Gold Souk-based DPMS with DPMSR filing, customer due diligence and goAML registration obligations.
Refiners & assayers
Businesses preparing for LBMA Responsible Gold Guidance or equivalent third-party accredited audits, with OECD Annex II annual reporting obligations.
Cross-border precious metals & commodity traders
A natural extension into our CorridorShield™ methodology, where trade finance and TBML exposure sits alongside supply chain due diligence.
Banks & financial institutions financing precious metals trade
Independent capacity to support due diligence on precious metals counterparties, supply chains and high-risk jurisdiction exposure.
Wherever a consignment sits between mine and market, provenance has to be provable. Our role is to make that provenance visible, documented and defensible.
Six capabilities. One OECD-aligned methodology.
From a single chain-of-custody review to a full annual due diligence report, our methodology connects the elements of precious metals supply chain risk into one consistent control framework.
Supply chain due diligence
— validation of air waybills, customs declarations, refining certificates and bills of lading.
Responsible sourcing (OECD-aligned)
— management systems, supply chain risk identification and risk-response strategy built on the OECD 5-Step Due Diligence Framework for mineral supply chains.
Chain-of-custody reviews
— assessing traceability and supply chain integrity from mine to market.
Mine-to-market controls
— counterparty due diligence across extraction, refining, trading and distribution, including high-risk jurisdiction exposure.
Third-party audit readiness
— documentation and gap closure ahead of LBMA Responsible Gold Guidance and other accredited third-party supply chain audits.
Annual due diligence reporting
— OECD Annex II-aligned annual reporting on supply chain due diligence, plus DPMSR regulatory reporting.
One methodology. Documented at every stage. A defensible supply chain, mine to market.
What each step means in practice, and what BullionShield™ delivers against it.
Board-level policy, roles and escalation lines for supply chain due diligence, benchmarked to your existing responsible sourcing commitment.
Counterparty, jurisdiction and transaction-level risk assessment across extraction, refining, trading and distribution — including CAHRA (conflict-affected and high-risk area) exposure screening.
Documented mitigation plans for red flags identified in step 2, with clear escalation and remediation ownership.
Documentation, gap closure and mock review ahead of LBMA Responsible Gold Guidance or equivalent accredited third-party audits.
An OECD Annex II-aligned annual report on supply chain due diligence, ready for counterparty disclosure or DPMSR filing.
A bigger market, a clearer rulebook.
As the UAE's precious metals trade has grown, so has the regulatory framework around it — giving DPMS businesses a clearer standard to build against, not a moving target.
Ongoing advisory, or a focused audit-readiness engagement.
BullionShield™ Advisory
Delivered through our standard Specialist Advisory™ and Compliance Monitoring Programme™ plans — from AED 1,500/month, scaled to your transaction volume and supply chain complexity.
RegReady™
A focused, time-bound engagement that keeps your supply chain due diligence and DPMS reporting continuously audit-ready — already prepared for an LBMA Responsible Gold Guidance review or a Ministry of Economy and Tourism inspection, not scrambled together before one. The payoff: faster turnaround times, fewer RFIs from banks and auditors, and a compliance record that strengthens your standing with banks and customers alike.
Supply Chain Due Diligence Health Check
A fast, one-off review of your chain-of-custody documentation — assay certificates, air waybills, customs declarations and refiner records — before it goes to a buyer, refiner or auditor, so gaps are caught early instead of surfacing during the review itself. Available alongside either engagement above, or on its own.
We already buy exclusively from LBMA-accredited refiners — why do we need BullionShield™?
LBMA accreditation covers the refiner's own supply chain, not your dealing entity's obligations under UAE DPMS rules. You still need your own OECD-aligned management systems, risk assessment and DPMSR reporting — we build and document that layer.
Is this only for large bullion houses and refiners?
No — the same OECD 5-Step framework scales down for smaller dealers and traders, right-sized to your transaction volume and risk profile.
Can you review our supply chain documentation before a specific buyer or audit review?
Yes — the Supply Chain Due Diligence Health Check is built exactly for that: a fast, standalone review of your chain-of-custody documentation, done in time to catch gaps before they surface in a review.
Know a dealer, refiner or trader that needs this? Send them here.
Tell us a little about the business — where it sits in the supply chain, current controls, upcoming audits — and we'll give you a plain, practical read on where BullionShield™ would help most.
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