Illicit gold imports to UAE: compliance and supply-chain risks for project teams
Reviewed by Tom Sullivan

First reported on MINING.com
30 Second Briefing
At least 591 tonnes of illicit gold worth about $74 billion entered the UAE in 2024, including 453 tonnes from African producers and 137 tonnes from countries under international sanctions, accounting for 42% of the country’s total gold imports, SWISSAID reports. Despite 2023 regulations tightening due diligence, only 2 of 52 reviewed Emirati refineries fully apply the new rules, with most still relying on intermediaries and weak traceability. SWISSAID urges reinstating the UAE on the FATF grey list, tougher and public penalties, stronger customs controls, and full disclosure of mined-gold suppliers, warning Swiss refiners—importing 420 tonnes from the UAE in 2024—of elevated sourcing risks.
Technical Brief
- SWISSAID’s assessment draws on 2021–2025 trade data and interviews with over 150 stakeholders.
- Illicit flows include gold smuggled without traceability and metal sourced from conflict zones such as Russia, Yemen and Sudan.
- Business-friendly regulation and comparatively weak penalties in the UAE have structurally lowered barriers for high‑risk supply.
- Only 2 of 52 Emirati refineries reviewed for 2023–2025 production fully implemented the 2023 due‑diligence rules.
- Many refineries still buy via intermediaries, avoiding mine‑site visits and direct chain‑of‑custody verification.
- SWISSAID urges reinstating the UAE on the FATF list for strategic AML/CFT deficiencies to force tighter controls.
- Recommended measures include public, tougher sanctions for non‑compliance and mandatory disclosure of all mined‑gold suppliers.
- Conflict‑affected regions are not to be boycotted outright; SWISSAID argues robust due diligence can de‑risk legitimate artisanal and small‑scale production.
Our Take
With 42% of UAE gold imports in 2024 assessed as illicit, Switzerland’s 400–420 t/y intake from the UAE places European refiners and traders squarely inside the same risk envelope, meaning EU/Swiss due-diligence regimes will likely face pressure to tighten around Emirati-origin bullion rather than only mine-of-origin checks.
The SWISSAID work here mirrors its role in other ASM-focused pieces in our database, where artisanal gold and coltan supply chains have already forced majors like AngloGold Ashanti and Southern Copper to halt field activities; this suggests that reputational and compliance risk from informal supply is now material not just for African producers but also for downstream hubs such as the UAE and Switzerland.
For copper and polymetallic project developers like Hudbay’s Copper World in Arizona, the scale of documented illicit gold flows into the UAE signals that financiers and offtakers may increasingly demand integrated ESG and chain-of-custody assurances across all by-product metals, not just the primary copper output.
Prepared by collating external sources, AI-assisted tools, and Geomechanics.io’s proprietary mining database, then reviewed for technical accuracy & edited by our geotechnical team.
Related Articles
Related Industries & Products
Mining
Geotechnical software solutions for mining operations including CMRR analysis, hydrogeological testing, and data management.
CMRR-io
Streamline coal mine roof stability assessments with our cloud-based CMRR software featuring automated calculations, multi-scenario analysis, and collaborative workflows.
HYDROGEO-io
Comprehensive hydrogeological testing platform for managing, analysing, and reporting on packer tests, lugeon values, and hydraulic conductivity assessments.
GEODB-io
Centralised geotechnical data management solution for storing, accessing, and analysing all your site investigation and material testing data.


