Critical Minerals Crime: Lessons to Learn from Gold Mining

As global demand for critical minerals accelerates, ensuring that these resources are sourced responsibly is essential to reducing opportunities for organised crime to infiltrate international supply chains. The current volatile and weak pricing of critical minerals presents a narrow window of opportunity to introduce the necessary safeguards, before prices rise, Nonetheless, the risks of criminality in critical mineral supply chains remain poorly understood and, in many cases, overlooked. 

Gold provides an instructive, cautionary example of the dangers of failing to address these risks early. In gold mining hotspots in the Amazon Basin and parts of sub-Saharan Africa, soaring prices have turned illegal gold mining into a major source of revenue for organised crime and conflict actors, harming communities and the environment. 

To consider how critical mineral supply chains can prepare for similar risks of criminal infiltration and exploitation, RUSI and the International Council on Mining and Metals (ICMM) held a roundtable discussion on 15 October 2025 with 35 experts from the mining industry, the financial sector, UK government departments – including the Department for Business and Trade (DBT), the Foreign, Commonwealth & Development Office (FCDO) and His Majesty’s Revenue and Customs (HMRC) – and intergovernmental organisations and civil society. 

The roundtable was divided into two sessions. The first discussed the effectiveness of interventions to date to tackle two core dimensions of criminality in gold supply chains: the infiltration of artisanal and small-scale mining (ASM) by crime and conflict actors, and their use of gold as a money laundering vehicle. The second session explored whether the same risks can be mapped to critical mineral supply chains as demand increases, and to what extent the sector is prepared to tackle these challenges. 

Methodology

This Insights Paper is mainly derived from unattributable discussions from the roundtable. However, open sources are used in some cases to corroborate and supplement participants’ insights. Given space limitations, this paper does not aim to address the full spectrum of market challenges but instead highlights the key observations made by participants.

Reviewing Interventions Against Illegal Gold Mining

Speakers from RUSI and ICMM opened the session by observing that the soaring price of gold, combined with weak governance and poor traceability, have made it an increasingly attractive commodity for organised crime and conflict actors active in fragile, gold-rich geographies with limited state presence. 

The spot price of gold has skyrocketed over the past decade, more than doubling from roughly $40,000 per kg in 2015 to $85,000 per kg in 2024. By November 2025, one month after the roundtable, the price had risen to just over $130,000 per kg. The price boom has largely been attributed to the appeal of gold as a safe financial asset amid growing geopolitical uncertainty and economic instability. By diversifying into illegal gold mining and laundering illicit gold into legal supply chains, these groups have gained a lucrative income stream and a money laundering mechanism through which to legitimise proceeds from other illicit activities. 

Participants from the mining sector recognised that to gain access to this lucrative enterprise, illegal armed groups have increasingly infiltrated ASM communities in their areas of operation – many of which were previously operating relatively sustainably and on a small scale, but without official licences. Criminal actors are known to finance and source mining inputs such as fuel, equipment and mercury and provide protection for ASM operations. In exchange, they extort illegal miners, taking the lion’s share of the proceeds. Although little is left for ASM communities, participants observed that gold mining still generates more income than other livelihood options, which can be limited in rural areas.

In many areas, organised crime involvement in ASM has caused illegal gold mining to balloon, both in terms of geographic scope, with the invasion of protected environmental areas or encroachment on large-scale mining (LSM) concessions, and in terms of sophistication, with the employment of machinery such as bulldozers, excavators and dredgers. Participants from the mining sector recognised that this, combined with harmful methods of extraction, such as mercury use, has had devastating consequences for human health and the environment. Illegal gold mining has also become increasingly violent in many cases, with lethal clashes arising between armed illegal miners and LSM workers or security personnel.

Addressing Criminal Infiltration and Exploitation of ASM

Participants acknowledged that governments in gold producing countries have largely responded to the criminal infiltration of illegal gold mining through punitive militarised strategies that have had limited effectiveness. In Ghana, corruption was reported to have undermined militarised interventions against illegal miners. Other participants observed that such strategies invariably end up penalising the lowest-hanging fruit – ASM actors with limited alternative livelihood options – rather than the real beneficiaries of these crimes. It was noted that recent efforts in Colombia showed promise, including a focus on targeting illegal mining through seizures of large machinery and investigations into financial assets. They do not, however, appear to have meaningfully quelled the activity. Elsewhere, such as in Brazil, raids against illegal miners have reportedly displaced illegal gold mining to neighbouring Venezuela, providing a temporary fix in one location while driving the problem elsewhere.

Faced with these limitations, several participants emphasised the need for more holistic, context-specific approaches. These include efforts to apply more incisive enforcement techniques such as financial investigation, address the root causes of criminal infiltration of the ASM sector and build greater trust and cooperation between government, the corporate sector and communities.

Civil society representatives observed that ASM has historically been widely stigmatised. Governments often see ASM as an inconvenient barrier to formal investment, sector modernisation and economic growth. In turn, elite capture and misappropriation of mineral-related revenues by state officials has led to widespread mistrust of government among many ASM communities. For their part, mining companies were observed to view ASM as a reputational and investment risk and an obstacle to natural resource access. 

Criminal actors are reported to instrumentalise these frictions, and in some places have armed and galvanised illegal miners to encroach on LSM concessions and attack workers, providing ASM with access to resources of which they have historically been deprived. Risk aversion in the financial sector has also led investors and creditors to overwhelmingly perceive ASM as a compliance risk, restricting access among ASM communities to legitimate sources of finance. Because of these perceptions, participants observed that ASM has struggled to find legal pathways to market to date. In this vacuum, organised crime and conflict actors have often taken on state-like functions, providing ASM with the finance, security provisions and social safety net required to generate income. 

Participants therefore emphasised the need and potential to engage ASM communities as a positive and strategic partner. According to the World Gold Council, the ASM sector is responsible for about 80% of gold mining employment, providing an important source of wealth creation in fragile contexts. In engaging with the sector, industry participants recognised that effective interventions must provide incentives for ASM that out-compete those offered by criminal actors. This may include the formalisation of their activities through licensing, a competitive wage, safer operating conditions and access to finance, according to participants. Some mining company representatives reported having introduced incentives, such as better pay and safety guarantees. An intergovernmental representative noted that regional banks in the Democratic Republic of the Congo (DRC) had begun to offer microfinance services to ASM to improve the sector’s access to finance and creditworthiness. 

Gold is also fungible. Participants noted that as soon as gold is refined or smelted, it loses any identifiable features and its origin and derivation can be easily disguised. These traceability constraints make traditional ‘follow the money’ strategies challenging. One participant pointed out that refineries, as natural bottlenecks along the gold supply chain, provide important entry points for traceability interventions and other controls. The same participant added that efforts have been made to improve responsible sourcing of gold through the London Bullion Market Association’s (LBMA) ‘Good Delivery List’ of refineries that have been audited in line with industry standards. Nonetheless, challenges were reported around the LBMA auditing process and there are reports of illegal gold continuing to enter LBMA-approved refineries. Participants pointed to reports of low quantities of ASM gold entering refineries, despite the World Gold Council estimating that ASM accounts for 20% of annual gold supply. They noted that the majority of gold in LBMA refineries – and approximately a fifth of gold in the EU market – is classified as ‘recycled’, despite the existence of an ambiguous definition and suspicions that this can be used as a cover for illegally sourced gold. These insights illustrate the importance of refineries and buyers conducting greater due diligence on the original source of recycled gold.

Participants pointed to examples of good practices in traceability and due diligence by buyers. One participant noted that a Swiss jewellery establishment had developed a verification and traceability system, adding a percentage to their premium to assure customers that the gold was responsibly sourced. While such value-addition operations can build costs into pricing structures, it was noted that this becomes trickier in scenarios where gold is used as an investment.

Emerging technologies also provide opportunities for improving gold traceability. One participant pointed to research into the unique morphological signature of gold – its ‘DNA’ – to trace the origin of gold. In one example, the Polícia Federal do Brasil (Federal Police of Brazil) have begun to use this technique to map seized gold to its place of origin to determine whether it originates from a legal mine. Nonetheless, gold’s fungibility remains a problem. As soon as gold is smelted and recycled, it is impossible to use this method. To address this gap, Brazil has imposed stricter controls on smelters, requiring them to conduct due diligence on the origin of incoming gold. However, countries cannot control what happens to gold once it crosses national borders. Participants therefore emphasised the importance of cross-border cooperation and information exchange, as well as harmonised regulatory frameworks in neighbouring countries, to disrupt criminal operations. 

Nonetheless, challenges remain. Industry representatives acknowledged the challenges of identifying legitimate stakeholders, which has complicated efforts to formalise ASM. One participant noted that in Peru, for example, the introduction of the Registro Integral de Formalización Minera (Reinfo, Integral Registry of Mining Formalisation) in 2016 has largely been seen as a failure, conflating well-meaning and ill-intentioned actors and allegedly providing the latter with a front to conduct illegal activity. Another mining company representative noted that the sheer scale of illegal gold mining poses significant challenges, observing that for every new miner formalised, there is a seemingly endless supply of individuals moving into illegal mining, due to the lack of equally profitable alternative economic opportunities. Industry representatives also emphasised the need to understand the specificities of local contexts and engage the right stakeholders in each case. Earlier attempts at formalisation of ASM in Ghana, for example, reportedly struggled to engage the appropriate community leaders.

Tackling Gold as a Money Laundering Vehicle

Participants recognised that certain features make it easy to integrate illegal gold into legitimate supply chains. This enables organised crime and conflict actors both to profit from illegal gold mining activity and to launder proceeds from other crimes, such as drug trafficking. 

First, gold is portable and easy to smuggle. Participants noted that the relative value of gold compared to its size makes it a convenient money laundering mechanism. Notably, amid soaring prices at the time of writing, one bar of gold is significantly less bulky than the equivalent value in cash, making it easy to conceal. Recent studies have stressed the opportunities this provides for human couriers to smuggle gold bars in passenger luggage on international flights. Other participants noted that customs declaration requirements for gold are often more lax than cash requirements, meaning that large quantities of gold can be transported across international borders without being declared.

Civil society participants observed that the Financial Action Task Force (FATF) has an important role to play in raising awareness of illicit gold flows among member countries and ensuring that they are sufficiently assessing their exposure in national risk assessments (NRAs). Participants noted that gold was mentioned only in passing in the UK’s recent NRA and was not identified as a priority risk. Some experts observed that the FATF could usefully provide updated guidance, given that the last FATF assessment on money laundering risks linked to gold was published in 2015.

Participants likened responses to illicit gold flows to a game of ‘whack-a-mole: if any one part of the system lacks integrity, illicit actors are likely to exploit these gaps, causing interventions elsewhere to fail. A whole-of-society approach is therefore needed, with what one participant referred to as a ‘suite of interventions’ across multiple sectors required to address vulnerabilities at different stages of the supply chain. 

Mapping Lessons from Gold to Critical Minerals

Dubbed ‘the oil, steel and electricity of the 21st century’, critical minerals form the backbone of modern societies. They are crucial for the energy transition, digital technologies and contemporary defence. Demand is expected to rise significantly over the next decade. However, geopolitical tensions, trade uncertainties and the geographic concentration of key supply chains in China have raised concerns in Europe and the US, spurring efforts to develop more resilient supply chains. Critical mineral prices have not surged in the same way as gold, due to oversupply in some cases, among other factors. As demand rises, however, it is likely that prices will adjust. 

There is, therefore, a narrow window of opportunity to introduce more rigorous governance measures before elevated prices make the sector more attractive to organised crime actors. In some fragile geographies, participants flagged that criminal infiltration of critical mineral supply chains has already been seen. There is a risk that this infiltration increases as mineral values rise. Nonetheless, a UN Office on Drugs and Crime (UNODC) report published in 2025 found that ‘research and enforcement efforts have largely focused on gold, precious metals and gemstones’ and collective understanding of risks and vulnerabilities of the critical minerals sector to organised crime remain limited. 

Overlapping Vulnerabilities in Gold and Critical Minerals

Participants perceived that critical mineral supply chains face some overlapping vulnerabilities to criminality, as seen in the case of gold. Significant ASM is seen in the mining of certain critical minerals, too. For example, participants pointed to substantial ASM activity in the copper sector in Peru, 3T minerals (tin, tungsten and tantalum), cobalt and copper in the DRC and rare earths in Myanmar. There are also reports of ASM involvement in lithium extraction in Zimbabwe. As with gold, there have been concerns around illegal actors co-opting and benefitting from ASM communities’ extraction of these minerals. With similar challenges around traceability, illicit minerals can be laundered into legitimate supply chains, financing organised crime, conflict and violence in similar ways to gold. 

Participants noted that ASM in some critical mineral supply chains is similarly stigmatised, creating barriers to formalisation and access to finance. In the global race to secure a reliable supply of critical minerals, others flagged that ASM potentially offers a faster route than LSM, which can take years to establish operations. The 2025 UNODC ‘Minerals Crime’ report found that, while ASM currently accounts for a small portion of global critical mineral output, there is potential for this to grow as demand for critical minerals increases. Participants recognised that, if done well, new investment and exploration in the sector could provide an important source of employment for rural communities with limited livelihood options, while reducing opportunities for illicit actors. However, failing to account for the risks of criminal infiltration of ASM could lead to similar challenges to those faced by the gold sector. 

Civil society participants noted the importance of mining companies and investors in the critical minerals sector not avoiding complex environments but instead recognising the valuable role they can play in providing livelihood opportunities. Here, similar interventions to those called for in the gold sector are needed – including engaging ASM communities through an alignment of incentives and livelihoods initiatives and providing opportunities for supportive networks of organisations to assist these efforts. As with gold, participants noted that such interventions have been attempted in some cases, but these efforts have been fragmented and uncoordinated. 

Some participants pointed to the relevance of export restrictions established by key countries. Examples include Indonesia’s ban on nickel ore exports in 2020 and the DRC’s temporary cobalt export ban in 2025. Often, these moves are made to control pricing and encourage foreign investment in domestic refining, to retain ownership of domestic natural resources and ensure the sector supports local job creation. Participants noted that export restrictions potentially offer opportunities for criminal actors to smuggle minerals to neighbouring countries. In one example, 5 million tons of nickel ore were reportedly illegally exported from Indonesia in mid-2023 to circumvent the export ban. 

Structural and Regulatory Differences

While ASM plays an important role in some critical mineral supply chains, participants observed that this is not the case across the board. In many cases, exploration and production of critical minerals are dominated by large-scale industrial players, with access to mineral resources controlled through permitting. While reducing the risk of criminal infiltration of ASM communities, UNODC’s 2025 ‘Minerals Crime’ report found that this potentially creates opportunities for different criminal typologies, drawing on document fraud and corruption.

Another key difference relates to traceability. Participants observed that critical minerals may face traceability issues, but gold is unique in its dual nature as both a financial asset and a tradeable good. This feature means that gold functions as a safe-haven asset during times of economic uncertainty and can also be used to launder illicit proceeds into seemingly legitimate financial assets. Other minerals do not share this quality; by contrast, critical minerals are not used to store value as a financial asset and their prices can be volatile, potentially holding lower strategic appeal for organised crime.

Participants highlighted other significant differences between gold and critical minerals, some of which provide potential opportunities to counter criminal risk. For example, compared to gold supply chains – which are fragmented and diffuse – critical minerals are often more concentrated markets. Gold refining, for example, is dispersed, with LBMA refineries in 25 countries. By contrast, the International Energy Agency has assessed that China is the leading refiner for 19 out of 20 strategic minerals.1.  Participants suggested that this concentration could provide an opportunity to strengthen sourcing standards and simplify the mapping of end-to-end structures, actors and risks, supporting efforts by the financial sector and industry players to mitigate investment risk and reduce opportunities for illicit actors in critical mineral production and trading.  

However, participants noted that the concentration of critical mineral refining in China also brings challenges. Chinese data protection and other legislation potentially complicate supply chain transparency efforts and create a black box for understanding refining practices and mineral flows. Heightened geopolitical competition and trade tensions between China and the US risk further complicating efforts to coordinate and cooperate on mining standards and best practice. Beyond this, one participant pointed to limited representation of major market players in international forums, impeding the ability of these meetings to promote coordination and reduce the regulatory asymmetries that provide opportunities for illicit actors. 

Other participants noted that critical minerals markets are often less developed than gold, with fewer opportunities for oversight. For instance, tantalum and tungsten are not traded on the London Metals Exchange, highlighting how many minerals lack standardised, transparent market mechanisms. This absence of formal market infrastructure compounds transparency and traceability challenges. By contrast, gold benefits from the LBMA’s Responsible Sourcing Programme. Although imperfect, due diligence standards exist for refiners, and non-compliant actors can face removal. This creates financial and reputational incentives to behave responsibly.

Conclusion

Generally, the roundtable highlighted that critical minerals share some features with gold, but that each mineral supply chain is different and complex. Participants emphasised the need to understand these nuances, and their implications for risks and vulnerabilities to organised criminal infiltration. In this context, a catch-all approach to enhancing the resilience of critical mineral supply chains was flagged as unlikely to be effective. The meeting concluded with participants agreeing that there is a need for targeted, systematic research to map risks of organised crime and illicit financial flows for each individual mineral supply chain. Mapping risks will better equip financial institutions, industry actors and regulators with the intelligence they need and improve preparedness of the sector to manage risks as demand scales. 

The roundtable discussions indicated that the need for this research is urgent. It must be undertaken before criminality in critical mineral supply chains expands into the kind of entrenched, unwieldy challenge already evident in the case of gold. As the roundtable suggested, a proactive approach that meaningfully engages ASM communities as strategic partners, incorporates thorough due diligence and targets supply chain vulnerabilities is required to strengthen resilience.