OECD Due Diligence Guidance for Responsible Supply Chains of Minerals
Third Edition, including Annex I (Five-Step Framework), Annex II (Model Supply Chain Policy), Annex III (Suggested Measures), and the dedicated Supplement on Gold.
COMPLIANCE & RESPONSIBLE SOURCING
Compliance is not a department. It is how we do business.
MD Overseas FZCO conducts its business in accordance with the laws and regulations of the United Arab Emirates, and applies documented, risk-based due diligence to its counterparties and to the material it handles.
★ Responsible Business Conduct & AML/CFT/CPF Policy Manual (Version 2026) — Effective 01 Jan 2026
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VERSION 2026Senior Management Approved
goAML REGISTEREDUAE FIU Integrated
OECD ALIGNEDFive-Step Due Diligence
5-YEAR MINIMUMAudited Record Retention
INTERNATIONAL BENCHMARKS
Standards We Are
Aligned To.
Our policies, due diligence procedures, and supply chain controls are written in strict alignment with recognised international responsible sourcing frameworks.
OECD Guidelines for Multinational Enterprises on Responsible Business Conduct
Comprehensive implementation of responsible business conduct principles, integrated alongside the OECD Due Diligence Guidance for RBC.
Responsible Jewellery Council Code of Practices 2024
Adherence to ethical, social, human rights, and environmental standards governing responsible precious metals commerce.
FATF 40 Recommendations
Global standards on Anti-Money Laundering and Countering the Financing of Terrorism, together with guidance for Dealers in Precious Metals and Stones (DPMS).
What Alignment Means
Our policies and procedures are written to these standards and our due diligence follows the OECD five-step framework. MD Overseas FZCO does not hold certification, accreditation or membership under any of them, and does not represent itself as certified. Where we describe our practices on this page, we describe what our internal compliance framework requires of us.
STATUTORY COMPLIANCE
UAE Regulatory
Framework.
MD Overseas FZCO operates in full adherence to the federal statutes, executive regulations, and cabinet resolutions of the United Arab Emirates.
Combating AML / CFT / CPF
Federal Decree-Law No. 10 of 2025 on Combating Money Laundering, the Financing of Terrorism and Proliferation of Weapons, and its Executive Regulations under Cabinet Resolution No. 134 of 2025.
Precious Metals & Stones Trade
Statutory provisions concerning monitoring trade in precious metals and stones, hallmark verifications, and applicable executive enforcement regulations.
Responsible Sourcing of Gold
Ministry of Economy and Tourism Due Diligence Regulations for Responsible Sourcing of Gold, establishing mandatory supply chain audits.
Terrorist Lists & Targeted Sanctions
Implementation of the UAE Local Terrorist List and UN Security Council resolutions on the prevention and suppression of terrorism and terrorist financing.
Beneficial Owner Procedures
Procedures regulating the identification, verification, and registration of Ultimate Beneficial Owners (UBO) at or above the 25% threshold.
Violations & Administrative Penalties
Enforcement provisions governing compliance violations, risk remediations, and administrative penalties under the UAE AML/CFT framework.
SUPPLY CHAIN INTEGRITY
Responsible Gold & Precious Metals
Supply Chain Policy.
A zero-tolerance commitment against human rights violations, conflict financing, financial crime, and environmental degradation.
Zero Tolerance for Human Rights Abuses
MD Overseas FZCO will neither tolerate nor knowingly profit from, contribute to, assist with or facilitate serious human rights abuses associated with the extraction, transport or trade of minerals — including torture, forced labour, child labour, gross human rights violations, war crimes, or crimes against humanity.
Zero Support to Armed Groups
We will not knowingly provide direct or indirect support to non-state armed groups or public/private security forces engaged in unlawful control of mine sites, transportation routes, trading points, or upstream actors in the mineral supply chain.
Bribery, Fraud & Financial Crime Control
We identify and manage risks relating to bribery, fraudulent misrepresentation of mineral origin, money laundering, non-payment of legitimate taxes and royalties, sanctions exposure, and terrorist financing. We comply fully with UN Security Council sanctions and UAE domestic enforcement.
Risk-Based, Not Geography-Based Sourcing
Our sourcing decisions are risk-based, not geography-based. We do not automatically avoid a region solely because it is conflict-affected or high-risk. We apply enhanced due diligence and respond proportionately — unless legal prohibitions or unacceptable risks require immediate disengagement.
SYSTEMATIC DUE DILIGENCE
The OECD Five-Step Framework
In Practice.
How our internal compliance management system executes the five steps of the OECD Due Diligence Guidance.
01
Management Systems
Establish strong company management systems
Documented supply chain policy, senior management accountability, KYC/KYS onboarding checks, beneficial ownership verification, chain-of-custody and transaction records, supplier engagement, due diligence record retention, staff training, and an accessible grievance mechanism.
02
Risk Identification
Identify and assess risks in the supply chain
We obtain and review information on supplier identity, ownership, business activity, source and type of material, country or area of origin, transport route, counterparties and applicable red flags, and determine whether enhanced due diligence (EDD) is required.
03
Risk Response
Design and implement a strategy to respond to identified risks
Material findings are reported to designated senior management and addressed under a documented risk management plan: continuing trade with measurable time-bound mitigation; temporarily suspending trade while mitigating; or disengaging where risk is unacceptable.
04
Independent Audit
Carry out independent third-party audit, where applicable
Where independent assurance or audit applies to our position in the supply chain, we cooperate fully, provide all requested records, and address any non-conformance through documented corrective action plans. Our AML/CFT programme is subject to periodic independent review.
05
Annual Reporting
Report annually on supply chain due diligence
We are committed to reporting at least annually on our responsible sourcing due diligence policies and practices, in a form appropriate to stakeholders and subject to legitimate confidentiality, security and legal considerations.
CAHRA PROTOCOLS
CAHRA Identification & Risk Assessment
We maintain a documented process for identifying Conflict-Affected and High-Risk Areas using credible, current international indices — including conflict indicators, governance weakness, widespread violence, human rights abuses, political instability, and illicit financial flows.
CAHRA screening is conducted before any sourcing relationship is established or materially expanded. The sources consulted, assessment date, conclusion and rationale are permanently documented.
- Multi-factor counterparty risk rating (geographic, profile, beneficial owner)
- Logistics routing and transit jurisdiction checks
- Mandatory Enhanced Due Diligence (EDD) upon red flag trigger
PROVENANCE CONTROLS
Origin, Traceability & Chain of Custody
Our procedures require every precious metal receipt to be linked to an approved counterparty and supported by commercial invoices, packing lists, customs clearance, assay certificates, and verified origin documentation.
We strictly distinguish between mined gold, recycled gold, and other eligible inputs. Recycled material claimed on inconsistent or opaque terms receives enhanced scrutiny.
- Lot & batch references reconcile total physical receipts against outputs
- Zero tolerance for falsification, alteration, or concealment of origin
- Immediate compliance escalation for unverified routing or weight variance
FINANCIAL CRIME PREVENTION
AML, CFT & CPF
Compliance Programme.
A senior-management-approved programme proportionate to the size, nature, and risk profile of our precious metals trading activities.
Designated MLRO
Appointed Compliance Officer / MLRO registered on the UAE FIU goAML system, given complete independence and unrestricted access to customer, transaction, and UBO data.
Business Risk Assessment
Documented assessment evaluating sector-specific exposure across cash intensity, scrap anonymity, supply chain complexity, and CAHRA sourcing — reviewed annually.
Customer Due Diligence
Every counterparty is verified using independent source documents before transacting. For corporates, this includes legal status, control structures, and authorized signatories.
Beneficial Ownership (UBO)
Natural persons holding directly or indirectly 25%+ of shares or voting rights are verified per Cabinet Decision 109/2023. Senior managing officials recorded where no 25% owner exists.
EDD & Politically Exposed Persons
Enhanced due diligence applied to high-risk transactions. PEP relationships require senior management sign-off, source of funds validation, and continuous monitoring.
Targeted Sanctions Screening
Real-time automated screening against UN Security Council lists and the UAE Local Terrorist List before onboarding and on an ongoing transaction-by-transaction basis.
Cash Controls & Anti-Structuring
Cash transactions at or above the DPMS threshold are reported via goAML. Structuring or splitting transactions to circumvent statutory thresholds is strictly prohibited.
Transaction Monitoring
Continuous testing of trading velocity against declared turnover profiles, monitoring for third-party payment requests, unusual routing, and assay inconsistencies.
STR / SAR Filings via goAML
Immediate internal reporting to MLRO and prompt filing of Suspicious Transaction Reports with the UAE FIU. Strict statutory non-tipping-off provisions enforced.
5-Year Secure Records
Due diligence files, UBO records, transaction receipts, screening logs, and FIU filings are retained for a minimum of 5 years in secure, tamper-protected digital archives.
Staff Training & Independent Audit
Mandatory induction and refresher training for all trading personnel. Complete segregation of duties maintained between trade execution and compliance oversight.
Senior Management Review
Annual audit results, risk assessments, and compliance health reports are presented directly to the shareholders for policy review and strategic remediation.
ETHICAL OPERATING CODE
14 Business Conduct
Commitments.
Our 2026 policy commitments establish clear operating standards across our operations and for work performed on our behalf.
Child Labour
Strictly prohibited. Minimum employment age of 18 with robust age verification built into recruitment controls.
Forced Labour
All forms prohibited. No retention of identity documents, no recruitment deposits, no debt bondage or coercion.
Human Rights
Guided by Universal Declaration of Human Rights, ILO conventions, and the OECD Guidelines for Multinational Enterprises.
Bribery & Corruption
Zero tolerance in all forms. Facilitation payments prohibited, except to protect immediate human life or safety.
Product Integrity
Accurate product descriptions, invoices, assay reports, weights, and fineness. Zero tolerance for falsification or omission.
Product Security
Rigorous physical controls over receipt, vaulting, transit, and dispatch, with unbroken chain-of-custody tracking.
Health & Safety
Hazard identification, training, protective gear, emergency preparedness, and no-retaliation hazard reporting.
Environment
Compliance with environmental law, pollution prevention, waste management, and efficient use of natural resources.
Employment & Remuneration
Compliance with UAE labour law, fair wage compensation, working hours regulations, and social security mandates.
Non-Discrimination
Fair decisions based on merit. Harassment, abuse, coercion, and intimidation are strictly prohibited.
Security Personnel
Security protocols proportionate to legitimate risk, fully respecting human rights and prioritising de-escalation.
Conflicts of Interest
Prompt disclosure of actual or perceived conflicts. Cash gifts, secret commissions, and kickbacks are prohibited.
Responsible Claims
No marketing or contractual claim made without evidentiary support. Certification scopes described with absolute accuracy.
Diversity & Inclusion
Fostering an inclusive workplace with fair opportunity, dignity, and equitable access to professional advancement.
COUNTERPARTY ONBOARDING
Supplier Expectations
Counterparties dealing with MD Overseas FZCO are expected to maintain the highest standards of transparency, integrity, and compliance:
Provide accurate, complete, and timely due diligence documents and corporate records.
Promptly notify us of material changes in ownership, management, source country, or identified risk.
Cooperate with enhanced due diligence, independent verification, and on-site assessments.
Accept that we may impose corrective action plans, suspend trading, or terminate the relationship based on risk.
*No supplier is approved simply because it has produced documents. We assess whether the information provided is coherent with the supplier's actual commercial profile.
EARLY WARNING MECHANISM
Grievance, Complaints & Whistleblowing
We maintain an accessible grievance channel for employees, suppliers, customers, and stakeholders to raise concerns regarding responsible sourcing, human rights, financial crime, or policy breaches:
- Concerns may be raised in good faith without fear of retaliation, discrimination, intimidation or adverse employment consequence.
- Confidentiality is protected so far as reasonably practicable and permitted by law.
- Anonymous reports are considered where sufficient information is available to assess the allegation.
- Every complaint is logged, assessed, investigated where appropriate, and tracked through to closure.
- Investigators are sufficiently independent of the matter complained of, and must disclose conflicts of interest.
- Allegations indicating serious human rights abuses, corruption, money laundering, sanctions violations or conflict financing are escalated promptly to senior management and, where required, to competent authorities.
- Where a grievance is substantiated, proportionate corrective or remedial action is taken and implementation monitored.
REPORTING CHANNELS
To Raise a Compliance Concern
Email Channel
✉ compliance@mdoverseasfzco.com
Reporting Form
🔒 Confidential Reporting Form (Available on Request)
Postal Mail
Strictly Confidential — Compliance Officer
CONTROLLED GOVERNANCE DOCUMENTS
Policies & Annual Disclosures
Responsible Gold Supply Chain Policy
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Code of Business Conduct & Ethics
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Grievance & Whistleblower Mechanism
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Annual Responsible Sourcing Report
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DILIGENCE & COUNTERPARTY INQUIRIES
Connect with our
compliance team.
For questions regarding our onboarding requirements, KYC pack, responsible gold policy, or regulatory disclosures, contact our compliance desk.
Contact Compliance Officer →