SE Asia Consulting Pte Ltd

Dubai Good Delivery

Maryam Al Hashmi

Dubai Good Delivery

This week’s Blog Q&A has a very distinguished guest, please allow me to introduce Maryam Al Hashmi Director, The UAE Kimberly Process and Director of Precious Metals and Stones (Dubai Multi Commodities Centre) at DMCC (Dubai Multi Commodities Centre)

1. Dubai is well known as a gold refining hub for Africa, what plans are there to tie up with African nations such as Ghana to improve the trade flow and tighten controls of gold movements and payments?

DMCC logo 300x96 1

Dubai’s strategic geographic location between gold producing and consuming nations, and its close proximity to the African continent, means we have a competitive advantage. For its part, DMCC is a world leading Free Zone established to enable and facilitate commodity trade flows through Dubai. We offer world class infrastructure and state-of-the-art facilities alongside a wide range of products and services to enable businesses to trade with confidence. We also have a robust regulatory framework in place in line with international standards, such as the OECD Guidance, to ensure the responsible sourcing, refining and trading of gold. As a result, we have successfully created one of the world’s leading physical gold markets.

The African content presents a host of opportunities across a variety of sectors – and gold is an obvious one. In fact, we already have a number of African companies registered in DMCC. We work closely with all stakeholders across the value chain to promote collaboration and partnerships and will continue to do so to highlight Dubai’s unique ecosystem for the industry.

2. Would Dubai consider better tie ups with countries like Hong Kong, Singapore & India to give the Dubai Good Delivery a push in Asia and help with transparency in trade flows?

DMCC Office 300x213 1 1

Transparency is one of the core values at DMCC. The establishment of the Dubai Good Delivery (DGD), which created a globally accepted benchmark for the sourcing and production of gold, is testament to our commitment to transparency and traceability.

We also strongly encourage knowledge sharing and coexistence in the industry as we believe this supports confidence across the entire value chain. We already have strong ties and partnerships in the Indian and Asian markets when it comes to the gold trade and are always looking for opportunities to strengthen collaboration. Of course, we would be open to sharing best practice when it comes to setting standards to further boost trade flows.

3. Gold is accepted within Singapore exempt from tax if it meets certain criteria under The Inland Revenue Authority of Singapore (IRAS), this essentially means LBMA approved for the most part. Why has Dubai not made a move to have Dubai DGD refineries gold accepted into Singapore duty free? Has anyone contacted Enterprise Singapore or the Singapore Bullion Market to discuss this initiative?

As DMCC, we have had some initial discussions with the Singapore Bullion Market that we will be pursuing over the course of the coming period.

4. Given there are over 10 active gold refineries in Dubai, why are there only two local refineries on the DGD list and what more can be done to add to this list?

DMCC Good Delivery Standard 300x201 1

The DGD was launched in 2005 to formally acknowledge refineries that have proven to meet a high standard of business practice, responsible sourcing, governance and quality control when refining, measuring, storing and trading gold. It is continually enhanced in collaboration with relevant international bodies, industry stakeholders and market participants and in alignment with OECD Guidelines.

As with London Bullion Market Association (LBMA)’s ‘Good Delivery List‘ and ‘Global Precious Metals Code‘ – and the many other standards available in the US, UK and Switzerland – DGD is voluntary in nature. Companies that qualify to appear on the DGD List receive international recognition for the integrity of their business practice.

We strongly encourage every refiner to become a member as we believe this in turn positively impacts their business and the industry as a whole. We are making good progress and are confident we will have more members on the list in the coming period.

5. Can you tell us why there has been a delay in announcing the details behind the new policy on governance, sustainability and innovation of the gold industry that was recently announced?

In October 2019, the UAE Cabinet committed to developing a policy to enhance the country’s position as a global hub for gold and jewellery trade, along with initiatives and tools to support its implementation.

The policy has three main pillars – governance, sustainability and innovation – with some strategic programmes and initiatives, also including the establishment of a federal platform for gold trading and a federal database for tracking, international marketing of the gold sector, and the use of technology in the production of gold.

A policy of this nature takes time, and the federal government will make details of the policy available in due course. The steps in implementation of the initiatives are progressing and all we can say at this time is please stay focused for the announcements coming out from our leadership in the coming months.

6. Gold flows from Africa gets refined in Dubai and ultimately ends up in Switzerland (despite their claims otherwise) which is based on the global ETF demand which is where the appetite for investors seems to be these days. With the DMCC having its own Dubai Good Delivery initiative do you see an opportunity to create a Dubai based ETF contract that is based off the Shari’ah Compliant Spot Gold contract (DGSG) that would allow for gold to remain in Dubai vaulting facilities?

Dubai Good Delivery

There is already an ETF on the Dubai Gold & Commodities Exchange (DGCX) Shari’ah Compliant Spot Gold in Saudi Arabia.

If someone is interested in launching an ETF, we would of course provide them with all the necessary infrastructure and support. Obviously, there are few players like the Saudi based ETF who are thinking in this direction and we are providing all the support from our side, hope we will have some good news in the near future.

7. The London Fix is often referenced using the LBMA AM or PM Price (formerly known as the Fix before the banks were caught for price manipulation) to settle gold transactions. Why doesn’t Dubai create a Dubai Fix for global gold settlement (I am sure many data providers would happily carry and publish that if made available)?

Gold Tolas Dubai 300x300 1

As DMCC, we have focused our efforts on developing world class infrastructure, products and services to enhance the trade of gold to and through Dubai, in line with international standards. A Dubai based price determination would happen when the market requires it and as previously mentioned DMCC is an enabler of trade and we will provide the required support when the market requires it.

8. The UAE accounts for approx. 14% of the global gold trade yet is marred with bad press. Do you think that more can be done within Dubai by the DMCC in the media to ensure such stories from NGO’s get coverage of both sides of the story?


Let me start by clarifying that DMCC registers companies that wish to establish operations within its Dubai-based Free Zone only, and provides the license required to conduct commercial activity. DMCC is not a regulator, nor is it responsible for regulating commodities trade – including gold or any other precious metal – in Dubai or the six remaining emirates of the UAE.

When it comes to the gold sector, DMCC has a robust regulatory framework that includes strict responsible sourcing rules. The rules are aligned with the OECD Guidance – the international benchmark for responsible sourcing – to ensure an inclusive and compliant, conflict-free supply chain.

In the global gold industry, DMCC is currently one of the member of the OECD’s Multi Steering Group (MSG) and continues to provide inputs for matters discussed at the OECD MSG that may impact the global implementation and policy of the OECD Guidance.

In the past, DMCC has signed agreements with various leading programs within the supply chain to bring best practice and compliance to its members. For example, DMCC has signed a Memorandum of Understanding with the (RJC), a global standards-setting and certification organisation for the entire jewellery supply chain, to work cooperatively on advancing the shared objectives of improving corporate social responsibility and responsible supply chain efforts in the jewellery supply chain. Over the years, we have made significant progress and will continue to work with all the stakeholders to ensure the integrity of the industry. The gold policy that the UAE government is developing will provide strong support here.

9. There are as you know zero refineries in Dubai that have been given LBMA Good Delivery status. I have heard stories told that senior LBMA Good Delivery committee members using such reasoning as “conflict in the region” to “Dirty Gold” as their justifications as to why no Good Delivery status has been given. Do you think there is too much self-protectionism within the LBMA as a self-governing organisation run by a handful of people who have self interest in the business, especially the bullion banks?

LBMA 150x150 1

Each institution has its own processes and criteria for accreditation. What we can confirm is that DMCC Rules for Risk Based Due Diligence in the Gold and Precious Metals Supply Chain are aligned with the globally accepted OECD Guidance and other similar international standards.

10. The recent CME Group decision to list then delist Al Etihad was a poor one on their behalf according many in the industry as well as the Executive Chairman of the DMCC Ahmed Bin Sulayem on his LinkedIn profile. Many of the industry are aware of what it takes to go through such a process and a knee jerk reaction to remove them was uncalled for especially when Al Etihad Gold had done nothing wrong and a single bank and an NGO made a Al Etihad Goldcomplaint which in one move Al Etihad have had their approval removed in 23 days of listing. Why do you think an industry can allow and trust an exchange like COMEX if a single bank and an NGO can make such a sweeping statement and get away with these claims against the whole of Dubai on a single refinery who had clearly worked hard to get that status?

We are not in a position to comment on this case as we have no information other than what was disclosed publicly.

11. A number of industry players we talk with think the World Gold Council would be a better fit for global gold governance and oversight as they see everything from the mines through to refining of end products. They have a global presence, deep pockets and over 100 staff worldwide, not a dozen people sitting in London who rely on conferences to maintain their overheads. Would the DMCC be open to a discussion around creating a new global group in conjunction with groups such as the WGC and other groups such as the SBMA where independence can be established and assist the industry instead of the current set up where you are either in the old boys club or you’re not?


As I indicated at the outset, DMCC is always open to an inclusive approach. We believe in collaboration and knowledge sharing across the industry. Over the years, we have always cooperated with stakeholders that are motivated by upholding the integrity of the global precious metals trade – and will continue to do so. Our ultimate aim is to elevate the standards of gold trade and drive meaningful value across the entire value chain. This stands to benefit all the stakeholders – miners, refiners and traders included.

You can contact the DMCC via their website or follow them on LinkedIn or Twitter

Since this was published the Dubai Good Delivery has been superseded by the UAE Good Delivery!

Scroll to Top