Regulatory Reporting Obligations for Gold Companies

Singapore: A Leading Hub for Regulatory Reporting in Gold

Singapore has cemented itself as a trusted hub for precious metals trading, thanks to its tightly regulated financial system and proactive stance on regulatory reporting enforcement. Gold companies must comply with multiple frameworks, including tax regulation, MAS reporting, and anti-money laundering (AML) compliance.

For entities dealing with over-the-counter (OTC) derivatives, the Monetary Authority of Singapore (MAS) imposes strict regulatory reporting under the Securities and Futures (Reporting of Derivatives Contracts) Regulations 2013. All gold derivatives transactions must be reported to licensed repositories, capturing details on the counterparty, product, price, notional amount, and trade lifecycle. Failure to comply with these regulatory reporting requirements can result in significant penalties.

Singapore also enforces stringent GST rules as part of its regulatory reporting framework. Effective 1 January 2025, changes to the GST administrative concession for trade-in gold jewellery will take effect. Businesses must ensure input tax claims and invoices comply precisely with IRAS’ updated regulatory reporting requirements or face audit and rejection of refunds.

In addition to fiscal regulatory reporting, AML and counter-financing of terrorism (CFT) laws require rigorous due diligence, client verification, and suspicious transaction monitoring. The Singapore Bullion Market Association (SBMA) provides helpful guidance.

Despite this robust regulatory reporting infrastructure, some market participants view Singapore’s environment as overly cautious. There are anecdotal reports of gold flows being diverted to Hong Kong where regulatory reporting is lighter and less scrutinised. The Chinese Gold and Silver Exchange Society (CGSE) continues to attract volumes, with market players calling it the “wild west.” Similarly, concerns persist around Shenzhen’s jewellery trade being exploited for cross-border capital movement disguised as personal ornaments.

United Kingdom: LBMA Oversight and SFTR Regulatory Reporting

London continues to dominate the global gold trade, with the London Bullion Market Association (LBMA) acting as the sector’s unofficial regulator, setting standards for regulatory reporting. The LBMA’s rules are the basis for global best practices, but UK firms also face legally binding regulatory reporting obligations under the Securities Financing Transactions Regulation (SFTR).

SFTR mandates comprehensive regulatory reporting for dealers and institutions involved in gold-related repos, loans, and collateral transactions, requiring all activities to be reported to a trade repository. This enhances transparency in financial markets and allows regulators to monitor systemic risk. Non-compliance with SFTR regulatory reporting may lead to fines or reputational damage with clearing banks and institutional partners.

In parallel, gold businesses in the UK must maintain full AML and sanctions compliance as part of their regulatory reporting obligations. All supply chain partners must be vetted, and due diligence extended to include upstream miners, refiners, and logistics handlers. Responsible sourcing declarations are no longer optional and must be documented under LBMA's Responsible Gold Guidance and OECD Annex II Risk Assessment protocols.

Brexit has shifted regulatory reporting pressures slightly, with the UK now managing independent oversight regimes. However, rather than relaxing rules, many firms report increased scrutiny. Gold traders must now double down on internal controls, from trade execution to physical delivery, to meet regulatory reporting standards and avoid triggering Financial Conduct Authority (FCA) reviews or third-party audits.

Moreover, recent trends show growing interest from the UK’s HMRC in scrutinising VAT compliance across gold imports and intra-EU transactions, further emphasizing the need for robust regulatory reporting. Transparency and automation in trade documentation are no longer technical upgrades—they are critical regulatory reporting requirements.

UAE: Strengthening Regulatory Reporting in the Global Gold Trade

For decades, Dubai has operated as a free-trade sanctuary for global gold movement—booming in volume but attracting scrutiny for weak regulatory reporting oversight. Now, the UAE is working to strengthen its regulatory reporting framework to prevent black-market bullion from passing through its refineries and souks.

The UAE Good Delivery Standard was established to mirror the LBMA's framework, introducing stricter traceability and enhanced regulatory reporting for source material, warehousing procedures, and compliance documentation from refiners. UAE’s Ministry of Economy now maintains oversight of these regulatory reporting procedures as part of its National AML Strategy.

Despite these regulatory reporting reforms, media investigations continue to raise concerns. The Middle East Eye's exposé on Dubai's 'blood gold' paints a troubling picture of shadow trades enabled by poor on-ground enforcement. According to industry whispers, certain illicit networks simply adapted to new regulatory reporting rules by shifting operations off-book or using intermediaries in less-regulated regions.

Nonetheless, the UAE has taken strides with public messaging, new sanctions compliance tools, and mandatory due diligence requirements for gold license holders to bolster regulatory reporting. However, until these measures are enforced with regular audits and prosecutions, many international investors remain wary.

For businesses operating in or through Dubai, the burden now lies in independently verifying compliance through supply chain audits, transport documentation reviews, and third-party certification to meet global regulatory reporting standards. Treat UAE regulatory reporting as a critical part of your global strategy, not a checkbox.

Final Thoughts on Regulatory Reporting Compliance

The gold industry is undergoing a quiet revolution, with regulatory reporting at the heart of this transformation. Compliance, once treated as a back-office afterthought, is now central to operations. Authorities in Singapore, the United Kingdom, and the UAE are aligning toward stricter regulatory reporting and enforcement. For gold sector businesses, this is both a risk and an opportunity. Those who proactively comply with regulatory reporting will gain access to premium markets and financial partnerships. Those who resist change may find themselves excluded from the most lucrative trade corridors.

Whether you operate a refinery, bullion trading desk, logistics firm, or jewellery export house, staying updated on regulatory reporting requirements is essential. From MAS trade repositories to SFTR filings, UAE sourcing protocols, and shifting GST obligations, the regulatory reporting landscape is growing more complex by the day.

Need help navigating regulatory reporting challenges? That’s where we come in.

SE Asia Consulting supports gold businesses across Asia, the Middle East, and Europe to implement internal controls, risk management strategies, AML programmes, and regulatory reporting systems. Explore more below:

• Anti-Money Laundering Compliance for Gold
• Internal Audit Strategies
• Risk Management for Gold Businesses

📩 Contact us today to safeguard your gold operations from regulatory reporting failures, avoid penalties, and position your business as a trusted player in the global market.