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Follow the Money: Mongolia A Rapid Assessment of Gold and Financial Flows linked to Artisanal and Small-Scale Gold Mining in Mongolia FOLLOW THE MONEY: MONGOLIA October 2017 PB FOLLOW THE MONEY: MONGOLIA FOLLOW THE MONEY: MONGOLIA i ii FOLLOW THE MONEY: MONGOLIA FOLLOW THE MONEY: MONGOLIA iii A Rapid Assessment of Gold and Financial Flows linked to Artis- anal and Small-Scale Gold Mining in Mongolia FOLLOW THE MONEY: MONGOLIA October 2017 ii FOLLOW THE MONEY: MONGOLIA FOLLOW THE MONEY: MONGOLIA iii © UNIDO 2017. All rights reserved. This document has been produced without formal United Nations editing. The designations employed and the presentation of the material in this document do not imply the expression of any opinion whatsoever on the part of the Secretariat of the United Nations Industrial Development Organization (UNIDO) concerning the legal status of any country, territory, city or area or of its authorities, or concerning the delimitation of its frontiers or boundaries, or its economic system or degree of development. Designations such as “developed”, “industrialized” or “developing” are intended for statistical convenience and do not necessarily express a judgement about the stage reached by a particular country or area in the development process. Mention of firm names or commercial products does not constitute an endorsement by UNIDO. Unless otherwise mentioned, all references to sums of money are given in United States dollars. References to “tons” are to metric tons, unless otherwise stated. All photos © UNIDO unless otherwise stated Cover photo by Magnus Arrevad, October 2016 iv FOLLOW THE MONEY: MONGOLIA FOLLOW THE MONEY: MONGOLIA v Acknowledgments This report was authored by Marcena Hunter of the Global Initiative against Transnational Organized Crime and Yolande Kyngdon-McKay and Kate MacLeod of Levin Sources. The authors would like to thank the United Nations Industrial Development Organization (UNIDO) who funded the research in the framework of the preparatory work of the regional project covering Mongolia and the Phil- ippines entitled “Contribution towards the elimination of mercury in the ASGM sector: from miners to refiners” that is financed by the Global Environment Facility and jointly implemented by UN Environment (UNEP). The project is encompassed and receives financial support from the Global Environment Facility program: Global Opportunities for Long-term Development of the ASGM Sector (GEF Gold). The objective of GEF Gold is to re- duce the use of mercury in the artisanal and small-scale gold mining (ASGM) sector in the participating countries through facilitating the access to finance to artisanal miners and mining communities for the introduction of low and non-mercury technologies and techniques and through the development of sustainable ASGM gold supply chains. To achieve this objective, at its October 2016 meeting the GEF Council approved a $45 million global pro- gram with $135 Million in co-financing to address the ASGM sector. The authors drew on the expertise of the Global Initiative against Transnational Organized Crime and Levin Sourc- es. In particular the team would like to acknowledge the expert editorial contributions of Laura Adal from the Global Initiative against Transnational Organized Crime and Khandarmaa Ayush and Holger Grundel from Levin Sources. iv FOLLOW THE MONEY: MONGOLIA FOLLOW THE MONEY: MONGOLIA v Table of Contents Preface ...................................................................................................................................... 1 1. Executive Summary .............................................................................................................. 5 2. Overview of Gold and ASGM in Mongolia ......................................................................... 10 3. ASGM Governance .............................................................................................................. 15 4. ASGM Gold Supply Chain .................................................................................................... 22 5. Key Stakeholders and Financial Flows ................................................................................ 28 6. Recommendations .............................................................................................................. 37 7. Works Cited ......................................................................................................................... 39 vi FOLLOW THE MONEY: MONGOLIA FOLLOW THE MONEY: MONGOLIA vii List of Figures and Tables Figure 1 Map of ASGM Activities in Mongolia (source: authors) ............................................ 12 Figure 2 Land Area of Mongolia and Other GEF Gold Child Project Countries ........................ 12 Figure 3 Estimate of Mongolian Gold Production (tonnes/year) ........................................... 14 Figure 4 Mapping of Regulatory Bodies .................................................................................. 16 Figure 5 Mongolia ASGM Gold Supply Chain .......................................................................... 23 Figure 6 Financial Flows and Stakeholder Mapping ................................................................ 29 Table 1 Mongolia’s Key Demographic Indicators ..................................................................... 11 Table 2 Government Stakeholders .......................................................................................... 15 Table 3 Development Organizations Active in the Mongolian ASGM Sector .......................... 21 Table 4 Case Study: Mandal Soum – mining and gold supply chains ...................................... 24 Table 5 Case Study: Mandal Soum – financial flows................................................................ 30 Table 6 Formalisation costs for ASMers .................................................................................. 33 Table 7 Processing plants in Mongolia .................................................................................... 35 vi FOLLOW THE MONEY: MONGOLIA FOLLOW THE MONEY: MONGOLIA vii Acronyms and Abbreviations ARM Alliance for Responsible Mining ASGM Artisanal and Small-Scale Gold Mining ASM Artisanal and Small-Scale Mining ASMers Artisanal and Small-Scale Miners BOM Bank of Mongolia FRM Frugal Rehabilitation Methodology GDP Gross Domestic Product Global Environment Facility project: Global Opportunities for Long-term Development of GEF GOLD the ASGM Sector GIFF Gold and Illicit Financial Flows GoM Government of Mongolia Law with Long Name: To Prohibit Mineral Exploration and Mining Operations at Headwa- LNL ters of Rivers, Protected Zones of Water Reservoirs LSM Large-Scale Mining MNT Mongolian Tughrik MoET Ministry of Environment and Tourism MoMHI Ministry of Mining and Heavy Industry MRPAM Minerals Resources and Petroleum Authority of Mongolia MSM Medium-Scale Mining NGO Non-Governmental Organization NRGI Natural Resource Governance Index OECD Organization for Economic Cooperation and Development OH&S Occupational Health and Safety SAM Sustainable Artisanal Mining SDC Swiss Agency for Development and Cooperation SPEAK Survey on Perceptions and Knowledge of Corruption in Mongolia UB Ulaanbaatar viii FOLLOW THE MONEY: MONGOLIA FOLLOW THE MONEY: MONGOLIA ix Interviews Listed below are the occupations and coded references for the interviews conducted during this study. Occupation Reference Date of interview Goldsmith GSA24032017 23 March, 2017 Environmental NGO in Mandal soum ENM23032017 23 March, 2017 ASM Federation Representative ASM17032017 17 March, 2017 Mandal Police Officer BOM22032017 22 March, 2017. State-Owned Processing Plant Representative PPM21032017 21 March, 2017 Buyer/Runner of a Processing Plant BPP23032017 23 March, 2017 Head of ASM Partnership ASP20032017 20 March, 2017 Mandal soum Government Representative SGM20032017 20 March, 2017 Local Researcher HDA23032017 23 March 2017 State-Owned Processing Plant Representative SPP21032017 21 March, 2017 Assay Office Representative AOR20032017 20 March, 2017 Head of ASM Partnership SOA22032017 22 March, 2017 Local Reporter LMR21022017 21 March, 2017 MRPAM’s Division of Mining production and technology PAM17032017 16 March, 2017 representative viii FOLLOW THE MONEY: MONGOLIA FOLLOW THE MONEY: MONGOLIA ix Preface In artisanal and small-scale gold mining (ASGM)1, a sector that employs approximately 15 million people around the world, mercury is often used to help extract gold from mined ore. Although inexpensive and relatively -ef fective in extracting gold from ore, mercury emissions and releases can cause serious harm to people and the environment when handled unsafely.2 Recognising the threat, a call for global action was initiated in 2009 which culminated in 2013 when the Minamata Convention on Mercury was adopted. The Convention mandates a re- duction, and elimination, if possible, in mercury usage around the world, including in ASGM.3 As of this writing, the 50th instrument of ratification has been submitted to the Minamata Secretariat and the Convention will enter into force on Aug. 16, 2017. Signatories to the Convention include many gold-mining countries, including Mon- golia and the Philippines. While ASGM is a significant global sector, the vast majority of ASGM is informal (and/or illicit) and unregulated, i.e. operating without the required licenses or legal approval. Pervasive informality is a result of several factors, including: onerous licensing requirements that create a barrier to entry for many miners; a lack of clarity in le-
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