37 Questions Reveal to 'Commerce' the Risks of 'Money Laundering' in Gold and Jewelry

- Identification of high-net-worth individuals with net assets exceeding two million dinars.

- Detailed data on activities and clients, including total transactions for 2026.

- Identification of sales exceeding 3,000 dinars during 2024.

- 2026 if settled with a foreign card.

- Counting politically exposed persons (PEPs), their family members, and associated parties.

The Ministry of Commerce and Industry directed 37 questions to gold, jewelry, and precious metals traders. These questions aim to assess money laundering, terrorist financing, and proliferation financing risks within the gold and jewelry sector, support risk-based supervision, and measure the extent of compliance of establishments with regulatory requirements.

The Ministry sent a questionnaire to relevant stakeholders via the "Sahel" platform, requiring the submission of detailed data on activities, transactions, and clients. This includes the total value of transactions for 2026, with the values of purchases and sales specified separately, and the percentage of cash sales, if determinable. The responses must cover all branches and licenses associated with the commercial registration, not just a specific branch.

The questionnaire also monitors whether the establishment sells gold bars or watches from well-known brands that may exceed a value of 3,000 dinars, the available electronic payment mechanisms, and the types of devices used. It specifies the number of sales exceeding 3,000 dinars and those exceeding 5,000 dinars, as well as whether the establishment faced attempts by clients during the year to conduct transactions or settle purchase values in cash.

The questionnaire monitors sales of high-value products exceeding 3,000 dinars if their value was settled during 2024–2026 using foreign payment cards, specifying the approximate amount paid and the country of issuance of the card. Its scope extends to payment methods, by monitoring the acceptance of prepaid cards and the total amounts transacted using them during 2024–2026. It also inquires about transactions conducted by establishments for clients dealing in virtual currencies over the past three years, specifying the total amounts involved during the same period.

Furthermore, the questionnaire monitors cases where a third party paid on behalf of the buyer during 2024–2026 for sales of products exceeding 3,000 dinars in value, specifying the value of the funds paid by that third party.

It also monitors sales made indirectly via the internet, phone, or email, where purchased goods were sent via postal services or transport services. It specifies the number of transactions conducted in this manner and clarifies the country from which precious metals, gemstones, or products containing them, such as jewelry and luxury watches, are imported.

The questionnaire inquires whether the establishment purchases gold in exchange for cash or similar services, including used items and diamonds. If such activity exists, it specifies the payment methods available to customers, whether cash, bank transfer, or otherwise.

The questionnaire dedicates a section to client data for 2026, starting with the total number of clients, then classifying them into natural persons residing in Kuwait and non-residents, and companies registered in Kuwait and abroad. It also requests the identification of the number of politically exposed persons among clients, including clients or beneficial owners who are politically exposed persons, their family members, or associated parties.

The monitoring also covers the number of customers or beneficial owners with high net worth—namely, natural persons whose net assets exceed two million Kuwaiti dinars—as well as customers or beneficial owners who hold residency or citizenship in countries listed on the Financial Action Task Force (FATF) black or grey lists, or who have close commercial, financial, or personal ties to such countries. It further identifies customers or beneficial owners linked to countries ranked among the top 20 in the Global Terrorism Index.

The questionnaire also asks whether the institution has conducted an assessment of money laundering and terrorist financing risks, specifying the date of the most recent assessment and attaching a copy of the risk assessment study. It requires confirmation of whether the institution maintains records of all due diligence procedures and executed transactions, the method of storage (whether paper-based or electronic), and the retention period in years. Additionally, it verifies the existence of a system enabling the institution to screen names against terrorist lists. The questionnaire also requests disclosure on whether senior management, the compliance officer, and other staff have received training on money laundering and terrorist financing risks.