Governance &
Compliance

METTALIX LLC FZ is based in Dubai, United Arab Emirates. Commercial activities must remain within the scope of the relevant business licence and any additional approvals required for the activity.

Commercial licensing, security approval, refinery authorisation and industry accreditation serve distinct purposes. Their scope and validity must be assessed separately; one does not establish the others.

The UAE framework covers money laundering, terrorist financing and proliferation financing. Controls must reflect business and transaction risks, with ongoing review and enhanced measures where required. Unusual payment routes and unexplained funds require further assessment; bribery is prohibited in public and private dealings.

Mandatory sector reports and suspicious-transaction reports are separate obligations. Suspicion may require reporting regardless of value or completion. Required records must be retained for the applicable statutory periods, and reporting confidentiality must be respected.

Relevant checks cover the UAE Local Terrorist List, the UN Consolidated List, ownership and control, and transaction parties. Other regimes may apply through the jurisdictions involved. Potential matches require identification checks and the applicable suspension, freezing and reporting action without delay.

For potentially controlled goods, technical specifications, destination, end-user and end-use determine the assessment and required permits. Screening must remain current as lists and circumstances change.

Responsible sourcing examines the material’s origin and its route through the supply chain. UAE gold requirements include company-specific due diligence policies, risk assessment and documented responses to identified risks. The review should address conflict financing, serious human-rights abuses and misrepresentation of origin.

Mined and recycled gold require different source evidence, including relevant producer, export and custody records. A recycled description alone does not establish a credible source.

Refinery review concerns the facility, authorised activities and the scope of any accreditation. Certificates and assurance reports should be checked against the issuer, covered site, product and validity. Accreditation does not automatically extend to a trader or every shipment.

Commercial terms should establish quantity, purity or grade, sampling, assay and settlement arrangements. Refining and recycling businesses also have specific gold-sourcing audit and reporting obligations.

Due diligence establishes each counterparty’s identity, authorised representatives, beneficial owners and commercial purpose using reliable, independent evidence. Higher-risk cases may require additional source-of-funds or source-of-wealth information. Politically exposed person status requires the applicable assessment and approvals, rather than an assumption of wrongdoing.

A submitted questionnaire or external report is not transaction approval. Where legally required checks cannot be completed, the relationship or transaction must not proceed. METTALIX remains responsible for its compliance obligations when using external support.

Relevant sources include UAE AML/CFT/CPF legislation, Ministry of Economy and Tourism guidance, targeted financial sanctions requirements and UAE gold-sourcing rules.

The OECD minerals guidance provides an international reference. Its legal effect depends on applicable law or contractual incorporation. References to these frameworks do not imply certification, membership or endorsement.