Africa Gold Advisory — Risks and Considerations for Businesses and Individuals with Exposure to Entities Responsible for Illicit Gold Trade

31 CFR 1010.100(t). <!-- page break --> Africa Gold Advisory – 27 June 2023 are reminded of their obligations to comply with AML and CFT regulations implementing the Bank Secrecy Act (BSA).28 A. OECD Framework for Gold The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, formally adopted by the OECD in 2011 (the OECD published the current 3rd edition of the Guidance in 2016), provides an over-arching, five-step approach to due diligence, with Annex II of the Guidance setting out a “model” corporate policy for a responsible global supply chain. The five-step approach includes: 1. Establish strong company management systems 2. Identify and assess risk in the supply chain 3. Design and implement a strategy to respond to identified risks 4. Carry out independent third-party audits of supply chain due diligence at identified points in the supply chain 5. Report on supply chain due diligence The OECD framework was recognized by the Securities and Exchange Commission in 2012 as an approved framework for due diligence reporting in the context of implementation of Dodd-Frank Section 1502. The OECD’s 2012 amendment to the Guidance added a separate Gold Supplement to focus more specific attention on the unique concerns related to gold. The OECD continues to convene actors in the gold supply chain through periodic forums and to release reports that provide additional guidance for companies and governments. The OECD framework and Gold Supplement underpin the numerous industry frameworks discussed below and provide an overarching approach to due diligence for all companies, regardless of membership in other initiatives. These documents should be reviewed carefully by all private sector actors potentially engaged in the gold trade in or related to sub- Saharan Africa. By fully adopting the OECD’s framework, participants can make valuable progress towards reducing the upstream risks associated with the gold trade in sub-Saharan Africa.29 But notwithstanding the merits of the OECD’s guidance, additional efforts are needed for industry participants to further reduce the risks associated with their practices while ensuring that the costs are not prohibitive so as to prompt de-risking. These are covered in the sections below. B. Anti-Money Laundering Gold dealers and retailers conducting business in the United States and who purchased and sold more than $50,000 worth of gold in the prior calendar or tax year typically fall under the U.S. Department of the Treasury’s Financial Crimes Enforcement Network’s (FinCEN’s) regulations covering dealers in precious metals, precious stones, and jewels (“PMSJ dealers”).30 The regulations require PMSJ dealers to have an AML program that must include: the 28

31 CFR Chapter X. 29 OECD, FAQ: Sourcing Gold from Artisanal and Small-Scale Miners (2016). 30

31 CFR 1027.100. <!-- page break --> Africa Gold Advisory – 27 June 2023 designation of an AML compliance officer; implementation of internal controls to prevent money laundering, terrorist financing and other financial crimes; training; and independent testing of the program. PMSJ dealers must file with the Internal Revenue Service and FinCEN reports relating to currency in excess of $10,000,31 and may voluntarily file with FinCEN Suspicious Activity Reports (SARs), commonly known in the international community as Suspicious Transaction Reports (STRs). Violations of these AML requirements may result in significant monetary penalties.32 In addition, entities with ties to the U.S. financial system should be aware that U.S. financial institutions have AML/CFT compliance requirements under the BSA. In complying with these AML/CFT requirements, U.S. financial institutions are expected to take a risk-based approach to identify, assess, and mitigate the money laundering and terrorist financing risks to which they are exposed and take measures commensurate with those risks in order to mitigate them effectively. Compliance with the BSA is essential to detecting, investigating, and deterring criminal activity. The BSA imposes a range of obligations across a wide sector of financial institutions, including establishing AML programs,33 filing currency transaction reports,34 and reporting suspicious activity35 to FinCEN. Additionally, as noted above, FATF, GIABA, and ESAAMLG, have published multiple typology documents that set out red flags for the conduct of anti-money laundering due diligence related to gold.3637 These reports identified certain “red flags”—common indicators of problematic upstream conduct—that industry participants should be aware of, avoid, and report. Such “red flags” include: ● “Licensed mines where the production has decreased with no apparent explanation.”38 ● “Buying gold above market price using cash and goods (barter)”39 ● “Sudden influx of gold miners into abandoned mining sites;”40 ● “Making payments for minerals purchased locally to an account abroad”41 31

31 CFR 1027.330 and 31 CFR 1010.330. 32

31 CFR 1010.820 and 31 CFR 1010.821. 33 See 31 U.S.C. § 5318(h)(4)(A) and 31 CFR 1010.201, See 31 CFR 1020.210(a) (banks with a Federal functional regulator, 31 CFR 1020.210(b) (banks without a Federal functional regulator); 31 CFR 1021.210 (casinos and card clubs); 31 CFR 1022.210 (money services businesses); 31 CFR 1023.210 (brokers or dealers in securities); 31 CFR 1024.210 (mutual funds); 31 CFR 1025.210 (insurance companies); 31 CFR 1026.210 (futures commission merchants and introducing brokers in commodities); 31 CFR 1027.210 (dealers in precious metals, precious stones, or jewels); 31 CFR 1028.210 (operators of credit card systems); 31 CFR 1029.210 (loan or finance companies); and

31 CFR 1030.210 (housing government sponsored enterprises). 34 See generally 31 CFR 1010.310 35 See generally 31 CFR 1010.320, 1020.320, 1021.320, 1022.320, 1023.320, 1024.320, 1025.320, 1026.320, 1029.320, and 1030.320. 36 FATF Report, 2015. 37 See GIABA, at 7; ESAAMLG, 2022. 38 FATF, at 23. 39 GIABA, at 59. 40 GIABA, at 59. 41 GIABA, at 59. <!-- page break --> Africa Gold Advisory – 27 June 2023 All of these “red flags” could signal an attempt to conceal the gold’s origin and its relation to illicit activity. Additionally, echoing the OECD’s guidance, the organizations recommend that downstream industry participants commit to collecting, analyzing, certifying, and reporting information about their supply chains to ensure that their gold is not extracted from sites associated with illicit conduct.42 C. Minamata Convention Under the Minamata Convention on Mercury, parties that have artisanal and small-scale gold mining and processing within their territory in which mercury amalgamation is used to extract gold from ore are obligated to take steps to reduce, and where feasible eliminate, the use of mercury in such activities, along with associated emissions and releases. The Convention also restricts most mercury trade. Although many sub-Saharan countries have joined the Convention, there are several significant non-parties, including the DRC, Angola, Ethiopia, Sudan, Liberia, and Mozambique. Parties are required to develop National Action Plans that provide a roadmap for reducing mercury use in ASGM. Many sub-Saharan countries have received support from the Global Environment Facility to address ASGM, including an inventory of mercury use, along with estimates of gold production from the sector. Relatedly, a number of development initiatives and private sector entities are working to provide mercury alternatives to ensure that mitigation of environmental concerns is possible. D. Industry Frameworks A number of industry organizations have developed frameworks that both their members and non-members can use to conduct due diligence against identified risks. These guidelines generally begin with an incorporation of the OECD Guidance and the Gold Supplement and then advance recommendations specific to the sector of the supply chain they apply to, whether miners, refiners, jewelers, or others. Private sector actors should review which frameworks, if any, and organizational memberships may be beneficial for them as they conduct enhanced due diligence. These initiatives include, but are not limited to: ● World Gold Council – WGC maintains the Responsible Gold Mining Principles, which include the WGC Conflict-Free Gold Standard and intends to implement the OECD Guidance and other global frameworks. In sum, the Principles seek to “address key environmental, social and governance issues for the gold mining sector.” ● London Bullion Market Association – LBMA maintains the Responsible Sourcing Programme for member refineries. The Programme is based on the LBMA’s Responsible Gold Guidance, which states that it “follows the five-step due diligence framework set out in the OECD Guidance and requires [approved] refiners to demonstrate their efforts to combat money laundering, terrorist financing and human rights abuses, and respect the environment globally.” 42 See, e.g., ICGLR, at 61; GIABA at 9-13. <!-- page break --> Africa Gold Advisory – 27 June 2023 ● Responsible Minerals Initiative – RMI maintains the Responsible Minerals Assurance Program, which seeks “to create the enabling conditions for companies to exercise due diligence over gold supply chains in accordance with the OECD Due Diligence Guidance” and “provides independent third-party assessments through an OECD-aligned industry mechanism for gold refiners.” Member companies come from an array of downstream sectors, including electronics, automotive, and manufacturing. ● Responsible Jewellery Council – RJC maintains the Code of Practices, which it states is the “global standard for the responsible jewelry and watch industry, focusing on business ethics and responsible supply chains.” Member companies come from the mining, refining, trading, manufacturing, and retail sectors. <!-- page break --> Africa Gold Advisory – 27 June 2023

Annex 1 – Table of Recent Gold-Related Sanctions Actions In the past five years, the United States has taken a number of sanctions actions with respect to gold and gold-related actors. In a number of cases, the sanctions action may not have been taken directly based on the individual’s or entity’s activities in the gold trade, but these are included to demonstrate the ways in which malign actors are connected to the trade. The following table includes a selection of those actions across a number of sanctions programs, including those related to certain countries in sub-Saharan Africa or other regions, e.g. Russia, Venezuela, and Nicaragua. Sanctions from outside sub-Saharan Africa are included for reference and as illustrations of the types of measures that can be applied to the sector. In some cases, gold-related activities may not have been the direct basis for the sanctions action taken, but the connection to the sector is relevant to note in light of the risks discussed in this Advisory. The designated persons identified below are listed for informational purposes only, as of the date of this advisory, June 27, 2003. For the current list of persons included on OFAC’s SDN List, please visit https://ofac.treasury.gov. Designee Date Name/Description Authority Connection to the gold sector 6/27/2023 Midas Resources SARLU, E.O. 14024 Designation of entities in the Central Diamville SAU, and African Republic, UAE, and Russia related entities associated with Yevgeny Prigozhin’s Wagner Group, including with respect to Wagner’s role in CAR’s gold industry. 6/1/2023 Al Junaid Multi Activities E.O. 14098 Designation of an entity that operates Co. Ltd.43 across multiple economic sectors in Sudan, including the gold mining industry, which “has become a vital source of revenue for the [Rapid Support Forces and its leader].” 10/24/2022 Nicaraguan General E.O. 13851 Designation of an entity that “is an Directorate of Mines44 important piece of state-controlled gold operations” of which Ortega and his cronies continue to benefit. 6/28/2022 Russian Gold Importation E.O. 14068 Prohibition on the importation into the Prohibition45 United States of Russian gold to deny 43 https://home.treasury.gov/news/press-releases/jy1514 44 https://home.treasury.gov/news/press-releases/jy1046 45 https://home.treasury.gov/news/press-releases/jy0838 <!-- page break --> Africa Gold Advisory – 27 June 2023 Russia revenue needed to fund its war in Ukraine. 6/17/2022 Ruy Delgado Lopez E.O. 13851 Designation of Nicaragua’s sate- (Nicaragua); Empresa owned mining company and its Nicaraguense de Minas President to prevent Ortega’s regime (ENIMINAS)46 form deriving benefit from its operation. 6/6/2022 Ali Qasir, Meghdad E.O. 13224 Designation of leaders of a network Amini; Morteza that financed Hizballah and IRGC- Hashemi47 QF, including through the gold trade. 6/2/2022 Nord Gold48 E.O. 14024 Designation of a major global gold mining company due to ownership by a sanctioned Russian oligarch, as part of broader effort to deprive Putin’s enablers of benefits form economic activity. 3/17/2022 African Gold Refinery in E.O. Designation of an individual, his Uganda and related 13413, as primary company, and his derivative network49 amended networks for illicit movement of hundreds of millions of dollars’ worth of gold and contributing to violence and instability in DRC. 2/23/2022 Said al-Jamal; Garannti E.O. 13224 Designation of an individual and his Gold and Exchange50 broader trade network—including his gold exchange—for contributing to the financing of the Houthi’s war against the Yemini government. 1/10/2022 Ramon Humberto E.O. 13851 Designation for being an official of Calderon Vindell51 the Government of Nicaragua, including for being president of the 46 https://home.treasury.gov/news/press-releases/jy0822 47 https://home.treasury.gov/news/press-releases/jy0806 48 https://www.state.gov/promoting-accountability-and-imposing-costs-on-the-russian-federation-and-its-enablers- for-putins-aggression-against-ukraine/; https://home.treasury.gov/policy-issues/financial-sanctions/recent- actions/20220602 49 https://home.treasury.gov/news/press-releases/jy0664 50 https://home.treasury.gov/news/press-releases/jy0603 51 https://home.treasury.gov/news/press-releases/jy0552 <!-- page break --> Africa Gold Advisory – 27 June 2023 board of directors of ENIMINAS, Nicaragua’s state gold company. 9/17/2021 Omid E.O. 13224 Designation of individuals and entities Yazdanparast, Mohammad related to the financing of Hizballah Ali Damirchilu, Samaneh and IRGC-QF through illicit gold Damirchilu, Mohammad activities. Reza Kazemi 52 9/23/2020 Prigozhin's network in E.O. 13848 Designation of companies and CAR: Russia-based M (and individuals associated with Yevgeny Finans and CAR-based others) Prigozhin’s Wagner Group. Lobaye Invest. Specific Individuals: Dmitry Sergeevich; Yevgeny Khodotov; Alexander Yuryevich Kuzin 7/15/2020 Prigozhin's Network in E.O. 13848 Designation of companies and Sudan Entities: M Invest, (and individuals associated with Yevgeny Meroe Gold. Individuals: others) Prigozhin’s Wagner Group, including Andrei Mandel, Mikhail with respect to Wagner’s role in Potepkin, Sudan’s gold industry. 9/13/2019 Kale Kayihura53 E.O. 13818 Designation of a Ugandan official for human rights abuse and corruption, including corruption related to gold smuggling. 9/10/2019 Al Hebo Jewelry E.O. 13224 Designation of a Turkish company Company54 through which ISIS converted gold into cash. 3/19/2019 VG Compania General de E.O. 13850 Designation of Venezuela’s state gold Mineria de Venezuela CA mine and its president for their Minerven And Antonio contribution to Maduro’s regime. Perdomo Mata55 52 https://home.treasury.gov/news/press-releases/jy0362 53 https://home.treasury.gov/news/press-releases/sm775 54 https://home.treasury.gov/news/press-releases/sm772 55 https://home.treasury.gov/news/press-releases/sm631. Antonio Perdomo Mata was removed from the SDN List on March 30, 2023 (https://ofac.treasury.gov/recent-actions/20230330) <!-- page break --> Africa Gold Advisory – 27 June 2023 2/5/2019 Guidon Shimiray E.O. 13413 Designation of the founder of an Mwissa56 (as armed group in the DRC (NDC-R), amended) for—among other illicit conduct— illegally taxing gold and using revenues to purchase weapons. 11/1/2018 E.O. 13850: Venezuela, Issuance of Authorization for broad sanctions Including Gold Sector E.O. 13850 relating to corruption in Venezuela, Sanctions including specifically in the gold industry. 56 https://home.treasury.gov/news/press-release/sm0279 <!-- page break --> Africa Gold Advisory – 27 June 2023

Annex 2 – Descriptions of Gold-Related U.S. Government-Supported Programs The U.S. supports industry, communities, and partner governments to enhance responsible extraction and value chains, with an emphasis on human rights, fair labor, and environmental stewardship. The following programs are supported by the U.S. government: ● CLEAN GOLD (ZAHABU SAFI): USAID supports the scaling-up of exports and sales of conflict-free, artisanal and small-scale gold from eastern DRC by developing market linkages between mining cooperatives and responsible gold supply chain actors. Activities address barriers throughout the artisanal gold supply chain by: 1) increasing demand and co-investment, 2) increasing the volume of exports by increasing the ability of upstream and midstream supply chain actors to adhere to due diligence and gold traceability standards, and 3) improving the commercial viability of gold cooperatives through training to improve business operations and governance. ● SUSTAINABLE MINE SITE VALIDATION: USAID improves current methods to validate mine sites as conflict-free to responsibly export artisanal gold, tin, tantalum and tungsten from the DRC. This approach promotes rigorous and transparent traceability of minerals through security analysis, continuous community-level monitoring of mine sites, and capacity building of DRC Ministry of Mines personnel. USAID has qualified 400 mine sites in North and South Kivu, trained government mine inspectors and established community monitoring committees with the assistance of the Bureau d’Elaboration des Projets et d’Application Technique (BEPAT), raised awareness of Local Monitoring Committee members, and developed guidance and tools on how to fight against child labor, provided technical support to raise awareness about sexual and gender-based violence as well as the role of women in mining, and established whistleblowing hotlines for violations observed locally. ● PUBLIC-PRIVATE ALLIANCE FOR RESPONSIBLE MINERALS TRADE: Established in 2011, the Public-Private Alliance for Responsible Minerals Trade (PPA) is a public-private partnership hosted by USAID, Department of State, and Department of Labor and also sustained through membership from civil society, the private sector, and academia to support conflict-free mineral supply chains from the Great Lakes Region. The PPA facilitates dialogue among international and regional actors to harmonize responsible sourcing efforts. The PPA finances pilot projects to develop due diligence and other tools, including a project promoting mobile access to finance for artisanal mining. The PPA has recently expanded outside the Great Lakes region to include programming worldwide. ● INVESTIGATING CONFLICT FINANCING, DUE DILIGENCE AND SOCIO- ECONOMIC DYNAMICS ALONG ARTISANAL MINING SUPPLY CHAINS IN THE DRC: The objective of this USAID-supported activity is to obtain and publish up- to-date information on mining and armed group or criminal involvement in the minerals sector in eastern DRC, thereby enabling supply chain actors and policymakers to make informed decisions based on the latest field realities. Research includes the dynamics around mineral supply chains and conflict financing, including transnational organized <!-- page break --> Africa Gold Advisory – 27 June 2023 crime and armed groups. The project produces maps of artisanal mine sites in eastern DRC, notably Ituri, Tshopo, Haut-Uele, North and South Kivu, Maniema, and Tanganyika provinces. ● GARAMBA ALLIANCE ACTIVITY: Through USAID’s Health, Ecosystems and Agriculture for Resilient, Thriving Societies (HEARTH) initiative, USAID partners with the private sector to promote transformational solutions to cross-sectoral development challenges in biodiverse landscapes in the DRC. In Haut-Uele province, USAID works with a broad alliance of public and private institutions, including anchor partnerships with Garamba National Park and Kibali Gold Mine. Illegal artisanal mining, logging and slash-and-burn agriculture are among the major threats to Garamba. The Garamba Alliance builds sustainable markets by providing alternatives to illegal mining and other threats through support to sustainable agricultural enterprise, vocational education, access to finance, and biodiversity conservation. The activity coordinates with the USAID Clean Gold project to strengthen legal artisanal and small-scale mining cooperatives to improve business practices and increase the production of responsibly sourced gold. ● PROGRAM FOR THE DEVELOPMENT OF EASTERN CONGO (P-DEC): This USAID activity builds inclusive dialogue processes, conflict early warning systems, and alternatives to violence; fosters accountable, trusted, citizen-responsive institutions; and creates economic alternatives to armed violence that promote stability, inter-ethnic cooperation, and social cohesion. To help break mining-related violence dynamics and to provide alternatives to illicit mining, P-DEC assists artisanal and small-scale miners through piloting social and environmental risk-mitigation as well as market readiness to legally and responsibly produce and sell minerals. ● AFRICAN TRADE AND INVESTMENT: In partnership with Prosper Africa, the purpose of this USAID activity is to mobilize trade and investment support surrounding good governance and mining in the DRC to deliver mutual benefits between the U.S. and the DRC. Partnerships with companies respond to DRC’s goals to better integrate their economy into global supply chains and allow local companies to add more value, create better jobs, and strengthen the business enabling environment. The activity aims to increase investment facilitation and transaction support, improve advocacy for U.S. businesses and increase mining investments that promote and sustain environmental, social, and governance standards. ● HUMAN RIGHTS SUPPORT MECHANISM: This USAID activity supports the DRC’s adoption of the Voluntary Principles on Security and Human Rights specifically by strengthening the participation and leadership of civil society organizations in the national implementation of the Voluntary Principles. Congolese civil society organizations have an acute sense of the realities of mining sites and adjacent communities, and are well placed to monitor on-the-ground developments, conduct evidence-based research, and provide actionable recommendations for successful implementation of the Voluntary Principles. ● INTEGRATED GOVERNANCE ACTIVITY: This USAID activity in the DRC strengthens key governance institutions to improve the delivery of public services at the <!-- page break --> Africa Gold Advisory – 27 June 2023 community level and supports the social contract between citizens and the government. With respect to the mining sector, the activity bolsters partnerships between mining companies and local governments (Decentralized Territorial Entities, or ETDs), builds local governments’ capacity (with emphasis on financial management), for good governance of mining revenues, and increases local communities’ participation in local development planning. ● FORCED LABOR INDICTOR PROJECT (FLIP): Working in Côte d’Ivoire and Ghana, the objective of this Department of Labor project is to advance greater supply chain transparency and accountability in multiple supply chains, including gold mining, as well as support government and the private sector to expand and better coordinate ongoing labor trafficking enforcement efforts. ● REDUCING MERCURY USE AND INCREASING TRANSPARENCY IN MALI’S ARTISANAL AND SMALL-SCALE GOLD MINING SECTOR: The Department of State supports the reduction of mercury pollution and the formalization of ASGM communities in Mali. The activity educates miners on mercury-free mining techniques while creating more resilient and responsible ASGM communities. Programs assess gold ore and grade in supported communities, procure the appropriate processing systems based on the results of those assessments, and train communities in mercury-free processing techniques. Analyses include an in-depth supply chain assessment, and incentivize miners, gold buyers and banks, to create transparent and responsible supply chains. ● PROMOTING MERCURY-FREE MINING IN GHANA: This Department of State project supports the reduction of mercury pollution and the formalization of ASGM communities in Ghana. The project demonstrates effective and scalable production of mercury-free gold, educates communities on the detrimental effects of mercury, and uses business incentives to strengthen equipment supply chains. It works with registered ASGM miners to develop mercury-free business plans, providing miners with business development tools and knowledge. The project then uses those plans to attract financing and install mercury free processing equipment, thus strengthening the market share for mercury-free processing equipment. ● RESPONSIVE ENGAGEMENT AND COLLECTIVE LEARNING APPROACHES TO INFORM MERCURY SUBSTITUTION IN ASGM: This Department of State project supports Ghana as they implement the Minamata Convention and finalize their National Action Plan to reduce mercury emissions. The project improves interagency and stakeholder coordination and increases Ghana’s capacity to adopt mercury-free alternatives. It works with two licensed mine sites to showcase scalable mercury-free technologies, establishing incentives for mercury-free alternatives, and increasing stakeholder buy-in. The project engages with stakeholders to reform licensing, regulation, and oversight of the ASGM sector. The project creates an early warning and response system which strengthens communities against political, economic, cultural, health, environmental, and security threats. <!-- page break --> Africa Gold Advisory – 27 June 2023 ● GLOBAL PARTNERSHIP FOR FORMALIZATION AND PROGRESS IN ASGM: This Department of State activity facilitates a global dialogue on formalization within the ASGM sector. It convenes experts and key stakeholders from around the world, collaborating with them to develop a general framework for formalization projects. The framework details how to reduce links to conflict, corruption, and crime while considering environmental and social outcomes as communities move into the formal sector. It applies the framework to new and existing projects, while encouraging the joint implementation of projects among the key stakeholders. ● DEVELOPING POLICIES TO REDUCE MERCURY POLLUTION FROM THE ASGM SECTOR: This Department of State project supports the reduction of mercury pollution through the design and implementation of regulations for tailings, including the management of mercury, among ASGM states. Activities develop the capacity of ASGM states to understand and address ASGM tailings management while promoting knowledge-sharing and engagement among ASGM actors. It conducts a literature review, identifying global trends and best practices for tailings management and residual gold exploitation. The review includes technologies for the safe recovery and storage of mercury, and profitable residual gold recovery. This review contributes to a best practices framework for tailings management, which country administrators will use as they develop, or revise their National Action Plans. ● REDUCING MERCURY USE IN ASGM COMMUNITIES: The Department of State supports the DRC's progress towards ratification of the Minamata Convention through its project to expand the implementation of mercury-free gold production technologies and increase access to sustainable financing for ASGM communities in eastern DRC. The project assesses gold ore and grade in supported communities, procures the appropriate processing systems based on the results of those assessments, and installs mercury-free processing centers. These centers act as a community hub and have the appropriate maintenance plans and financial support in place to ensure a long-lasting impact. A number of smaller USAID programs have worked to improve knowledge about the potential for, and consequences of, ASGM in Africa through targeted research. For example, the Artisanal Mining and Property Rights project included detailed analyses of gold mining in the Central African Republic, a desk review of the ASGM sector in Burkina Faso, and an assessment on the gold and cacao sectors in Ghana. Additional projects have supported research on violence and gold in Côte D'Ivoire and mining related mercury emissions in Tanzania. In addition to the U.S.-supported programs, other leading donors and development organizations have supported the following relevant efforts: ● The World Bank, often operating through the Extractives Global Programmatic Support (EGPS) program, has provided support to ASGM communities in Burkina Faso, Burundi, Central African Republic, DRC, Mali, Niger, Nigeria, and Tanzania, among other countries. It recently supported an emergency response program to assist small-scale mining communities affected by COVID-19 and sponsors the DELVE Platform, which aims to build a global online database of artisanal and small-scale mining knowledge. Previously, the World Bank supported the Communities and Small-Scale Mining <!-- page break --> Africa Gold Advisory – 27 June 2023 (CASM) project, a major global small-scale mining initiative which operated throughout the 2000s. ● The Global Environment Facility (GEF) leads the PlanetGOLD program in support of the Minamata Convention. PlanetGOLD works with governments and gold mining communities in fifteen host countries to improve ASGM practices and reduce associated mercury pollution. In Africa, the program sponsors work in Burkina Faso, Ghana, Madagascar, Nigeria, DRC, Côte d’Ivoire, Guinea, Mali, Sierra Leone, Zambia, and Uganda. ● Multiple expert independent organizations and industry schemes also lead interventions in African ASGM, including: o IMPACT: IMPACT, formerly Partnership Africa Canada, is an NGO that specializes in artisanal and small-scale mining in Africa. It hosts various programs on ASGM, including Just Gold, a traceability and due diligence system, and interventions aimed at improving gender equality, health, and safety in mining sites. Just Gold programs operate in the DRC and Côte d'Ivoire, while the organization has broader ASGM programs in Burkina Faso, Uganda, and Zimbabwe. IMPACT’s programs are funded by donor agencies, including from Canada, the European Union, USAID, and industry groups. o The Alliance for Responsible Mining (ARM): ARM is a global initiative focused on improving artisanal and small-scale mining livelihoods through capacity building and improved market access. The organization leads several programs on ASGM, including the Fairmined Standard – a certification scheme designed to bring responsibly produced small-scale gold to market – as well as broader interventions designed to improve ASGM sustainability. Founded in Colombia with a focus on Latin America, ARM also operates in Burkina Faso, Mali, Niger, Côte d'Ivoire, Mozambique, and DRC, with previous projects in Ghana and Gabon. ARM works with various major donors as well as other implementing organizations. o Artisanal Gold Council (AGC): AGC is an organization focused on improving the ASGM sector through training, education, and capacity-building programs, as well as through guiding sector governance. AGC currently implements programs in Sierra Leone and Burkina Faso, with previous work in Guinea, Senegal, Gabon, Mali, and Ghana, among others. AGC works with donor support from the Department of State, the GEF, UNIDO, GIZ, and others. <!-- page break -->