AML Training for DPMS

AML training for DPMS (Dealers in Precious Metals and Stones) is a regulatory requirement in many countries, as this sector is vulnerable to money laundering and terrorist financing due to the high value, portability, and anonymity of precious commodities.

AML Training for DPMS (Dealers in Precious Metals and Stones)

Purpose of Training

To ensure that all employees and stakeholders in the DPMS sector understand:

• AML/CTF laws and obligations
• How to identify suspicious transactions
• How to comply with reporting and record-keeping requirements
• The importance of risk-based approaches in high-value transactions

Who Needs Training?

• Owners, directors, and compliance officers
• Frontline staff handling transactions
• Staff involved in customer due diligence (CDD)
• Internal audit and legal teams

Key Training Modules

Introduction to Money Laundering & Terrorist Financing

• What is money laundering?
• Stages of money laundering: Placement, Layering, Integration
• Why DPMS is a high-risk sector

Applicable Laws and Regulations

Tailor this section to local/jurisdictional laws. Examples:

• UAE: Federal Decree Law No. (20) of 2018 on AML and CFT

Customer Due Diligence (CDD) & Enhanced Due Diligence (EDD)

• Identity verification requirements
• When to apply EDD (e.g., cash transactions > threshold, high-risk jurisdictions)
• Beneficial ownership checks

Recognizing Suspicious Transactions

Red flags specific to DPMS:

• Cash purchases of high-value items
• Transactions just under reporting thresholds
• Reluctance to provide ID
• Unusual payment methods (e.g., crypto, third-party payments)
• Frequent purchases inconsistent with a customer's profile

Record-Keeping Obligations

• What records must be kept (ID, invoices, transaction history)
• Retention period (commonly 5–10 years)
• Secure storage and access

Reporting Requirements

• Suspicious Transaction Reports (STRs)
• Threshold reporting (e.g., cash transactions over $10,000 in many jurisdictions)
• Timelines and procedures for filing reports

Internal Controls and AML Programs

• Designation of a compliance officer
• Internal AML policies and procedures
• Independent audit and testing

Penalties for Non-Compliance

• Administrative fines
• Criminal liability (for owners or staff)
• Reputational damage