6
Distinct load factors
19
Markets served
5
Service lines
100%
Operator-side
02What this sector carries
02
A precious metals and stones business is a movement of value that looks like a shop. The activity spans a wide arc: gold and silver bullion, coins and bars, rough and polished diamonds, coloured stones, refined and scrap metal, jewellery at retail and wholesale, assaying and hallmarking, vaulting and consignment.
Each step carries an AML and sanctions load a general licence does not resolve. These exposures are concrete, known to every supervisor, and tested on live transactions, not read from a manual. Six decide most examinations.
R/01
Cash intensity
Walk-in trades settle in cash more than any bank flow. Structuring below reporting thresholds is the classic typology, and the examiner tests how you catch it.
R/02
Portability and convertibility
A kilogram of gold crosses a border in a coat pocket and converts to clean funds in a day. The sector features heavily in trade-based money laundering and sanctions-evasion cases.
R/03
Source-of-metal risk
Conflict gold, artisanal and unregulated mining, smuggled stones. Responsible sourcing and supply-chain due diligence are now part of the AML expectation, not a separate ESG exercise.
R/04
Sanctions and export-control exposure
Precious metals are a named channel in several sanctions regimes. Counterparty screening, ownership tracing and origin checks all sit inside the programme.
R/05
The FATF Travel Rule and value transfer
Where a dealer touches value transfer or works alongside a payment or crypto rail, transfer-information obligations follow the transaction.
R/06
Beneficial-ownership opacity
Trade companies, free-zone shells and nominee buyers obscure who is really behind a purchase. Ownership verification is the control that fails first under examination.
03The exam
What an examiner tests for in this sector
A DPMS examination is not a document review. The supervisor tests whether the programme works on a live transaction. The pressure points are specific, and each is checked against evidence, not intention.
Test
Enterprise risk assessment tuned to metals and stones. Not a generic template: product, channel, customer and geography risk scored against how the business actually trades.
Test
Customer due diligence and the cash threshold. Identification and verification triggered at the applicable occasional-transaction threshold, with enhanced due diligence where risk rises. Expect a walk-in cash sale to be tested.
Test
Beneficial ownership. Who owns the buyer, who owns the counterparty refinery, who sits behind the trade company. Verified, not asserted.
Test
Sanctions and PEP screening. Names, vessels and entities screened at onboarding and on an ongoing basis, with a defensible match-handling process.
Test
Source of funds and source of metal. Documented for high-value and high-risk dealings, including responsible-sourcing checks on the supply chain.
Test
Transaction monitoring and structuring detection. Rules that catch layered cash purchases, rapid buy-sell cycles and threshold avoidance.
Test
Suspicious transaction reporting. A clean, timely reporting line to the national financial intelligence unit, with the internal decision trail preserved.
Test
Governance and the responsible officer. A named compliance officer with authority, training records, and independent oversight of the programme.
04The build
What Black Sea builds and runs for a DPMS operator. Five service lines. We build the programme, or we run it, or both.
S/01
Licensing and new-regime programme build
We build what the registration assumes.
For a new dealer, refiner or bullion desk entering a designated-business regime, we build the AML and sanctions programme from the risk assessment up: policies, CDD and EDD tuned to cash and high-value dealing, screening design, monitoring rules and the reporting line. Costed plan within 48 hours, fixed scope, fixed fee.
S/02
Remediation, post-enforcement or post-finding
The programme after the finding.
When a supervisor has issued a finding or enforcement action against a metals or stones business, we run the remediation: gap analysis, control rebuild, file look-backs and the evidence pack that closes the matter. We are the reviewer, not the seller.
S/03
Outsourced and bridge MLRO, plus a managed financial-intelligence function
The programme as a live function.
Many DPMS operators cannot justify a full-time senior compliance officer. We provide the outsourced or bridge responsible officer and run a managed financial-intelligence (FIU) function: alert triage, structuring review, STR drafting and the regulator-facing reporting line. Senior only.
S/04
Independent AML audit
The reviewer, not the seller.
The independent test the framework requires and the examiner respects. We audit the DPMS programme against the applicable rules and against real transactions, then hand over a findings report a supervisor will accept. Independent and conflict-free: we sell no software and take no commissions.
S/05
Sanctions, export-control and integrity due diligence, including the FATF Travel Rule
Screening that holds.
The sector's sharpest exposure. We build and run counterparty screening, ownership tracing, source-of-metal and responsible-sourcing checks, export-control review, and Travel Rule handling where value transfer is in scope.
05Coverage / 19 markets
The DPMS programme, served across all 19 markets
Gold and DPMS is one of nine sectors we serve, to the same depth in every market. No single market is the flagship. What changes is who supervises the dealer and under which framework, so we ground each build in the correct body. A selection of the verified supervisors:
UAE
The Ministry of Economy and Tourism (MoET) supervises dealers for AML; DMCC operates as the free-zone registrar in Dubai.
Saudi Arabia
The Ministry of Commerce, alongside the Ministry of Industry and Mineral Resources.
Turkey
Borsa Istanbul operates the Precious Metals and Diamond Market; MASAK, the Financial Crimes Investigation Board, is the AML authority.
South Africa
The South African Diamond and Precious Metals Regulator (SADPMR), with the Financial Intelligence Centre (FIC) on the AML side.
Kazakhstan
The Ministry of Finance (including the Assay Chamber for hallmarking), with the Financial Monitoring Agency (AFM) as AML supervisor for DPMS dealers.
Ghana
The Ghana Gold Board (GoldBod), with the Financial Intelligence Centre (FIC) supervising dealers as DNFBPs.
Nigeria
The Mining Cadastre Office under the Federal Ministry of Solid Minerals Development, with SCUML on AML.
Bahrain
The Ministry of Industry and Commerce (MOIC).
Qatar
The Ministry of Commerce and Industry, AML/CFT Section.
Kuwait
The Ministry of Commerce and Industry, with the Kuwait Financial Intelligence Unit receiving suspicious transaction reports.
Oman
The Ministry of Commerce, Industry and Investment Promotion, with hallmarking and assaying under the Directorate General for Standards and Metrology.
Egypt
DNFBP dealers supervised under the AML law, with the Egyptian Money Laundering and Terrorist Financing Combating Unit (EMLCU) as the financial intelligence unit.
Pakistan
The Federal Board of Revenue, Directorate General of Designated Non-Financial Businesses and Professions.
We work to the same standard in the remaining covered markets:
- Azerbaijan: Financial Monitoring Service.
- Georgia: Ministry of Finance.
- Jordan: Ministry of Industry, Trade and Supply, with the AML/CFT unit.
- Kenya: State Department for Mining, with the Financial Reporting Centre.
- Kyrgyzstan: Precious Metals Department under the Ministry of Finance, with the State Financial Intelligence Service.
- Uzbekistan: State Assay Control under the Ministry of Economy and Finance.
Even coverage. 19 markets. One programme, calibrated per supervisor.
BahrainMOIC
KuwaitMOCI / KwFIU
OmanMOCIIP / DGSM
QatarMOCI
Saudi ArabiaMoC / MIM
UAEMoET / DMCC
EgyptEMLCU
JordanMITS / AMLU
GhanaGoldBod / FIC
KenyaSDM / FRC
NigeriaMCO / SCUML
South AfricaSADPMR / FIC
AzerbaijanFMS / AZSTAND
GeorgiaMoF
KazakhstanMinFin / AFM
KyrgyzstanMoF / SFIS
UzbekistanState Assay Control
TurkeyBIST PMDM / MASAK
PakistanFBR DG-DNFBP
06Note / limits
Where the activity is channelled or limited
Some markets channel precious-metals activity through a state assay authority, a national board or a single exchange rather than an open dealer licence. Where the activity is restricted or effectively closed to private dealers, we say so before you scope anything, and we build only what the real framework allows. We do not sell a programme for a licence a market does not grant.
State assay route
Kyrgyzstan and Uzbekistan route metals dealing through a state assay department.
Single exchange
Turkey concentrates the wholesale precious-metals market inside Borsa Istanbul's Precious Metals and Diamond Market.
National board
Ghana centralises gold trading through the Ghana Gold Board (GoldBod).
We verify first
The dealing position is checked against the named supervisor before we scope.
07Market x sector
The sector page tells you what we build. The market pages tell you who examines it. A handful of the Gold & DPMS combinations:
08Proof
Real proof, no invented case studies
PartnershipLocal partnersSigned partnership with an AIFC firm licensed by the AFSA. Licensed local legal standing paired with our operator-side build.Partners →
CredentialsCAMS / ICACredentialed practitioners, with front-line KYC and financial-intelligence experience on the team.The firm →
Fresh proofVerifiable todayWe lead on dated, verifiable evidence rather than client references. We publish no client names and invent no case studies.The record →
The registration is the easy part. We build what sits behind it.
Tell us the market, the activity and where you stand. Fixed scope, fixed fee, no hourly billing. Response < 48h.