The Illegal Trade in Chemicals


Figure 3 identifies the key stakeholders dealing with ASGM and the mercury trade. The most influential of these are informal traders and brokers of mercury and gold. They are referred to in the literature in a variety of ways. Some refer to“middlemen”who buy gold fromminers, smuggle mercury and may be involved in money laundering and other criminal activities. Others describe “brokers” who facilitate the mercury trade and help to hide mercury storage andmercury recycling activities. Others speak of “smugglers”or“illegal dealers”who buy gold, promote the use of mercury andoften accept gold in exchange for a reducedprice or a“free”supply of mercury (Fritz, Maxson and Baumgartner 2016). Only slightly less influential are the guards and security personnel who ensure that mercury reaches the ASGM sites, followed by the larger ASGM community, and the customs and local government agents. Researchers and local non-governmental organizations recognize that informal mercury suppliers and goldbuyers have a strong influence on mercury trade for ASGM by supplying, storing and even recyclingmercury – as well as tradingmercury for gold – using methods that are not transparent. Because of their importance and influence, these stakeholders also

represent a significant barrier to the common national objective of reducing mercury use in ASGM, because these informal traders facilitate the continued use of mercury by miners even whenmercury is formally prohibited. Moreover, in places where mercury is traded informally, the trade may sometimes appear in official data only at the time of import into the country, and the subsequent pathways and end uses are never recorded. This is one of themain reasons that the legalization of ASGMand the development of specific ASGM regulations are key measures required to support the transition tomercury-free ASGM, a goal that is important to many Parties to the Minamata Convention (Fritz, Maxson and Baumgartner 2016). Local government agents are often involved because the activities of informal traders reduce the potential revenues of the local governments. This potential for lost revenue further encourages governments to prioritize the fight against gold smuggling and the related informal mercury trade. Security personnel, collaborators and the larger ASGM community benefit directly from the informal trading network, but they are also critical to the support and protection of informal trade, which is often, due to the nature of the business, coordinated by an outlaw group or organized crime (see Annex 5).

Key stakeholders in uencing the use of mercury (Hg) in artisanal and small-scale gold mining (ASGM)



Legal mercury supply: Mercury sales Mercury storage

Local gold shops: Mercury sales Mercury recycling Mercury storage

Certi cation bodies: Gold certi cation Training Formalization of small-scale operations Awareness raising Investors: Financial support


Landowners and concession holders: Formalization of small-scale operations Land management Technology owners, processing site owners: Mercury sales Mercury recycling

Informal mercury and gold middlemen (e.g. brokers, buyers, sellers, credit): Mercury sales

Artisanal and Small-Scale Gold mining activities using Mercury

Mercury storage Mercury recycling

Local governments, law enforcement agencies, o cial gold buyers: Policy making Financial support Formalization of small-scale operations

ASGM communities: Mercury contamination of air, water and land

ASGM miners: Lobbying Training Formalization of small-scale operations Awareness raising

Protection and security arrangements

Awareness raising Land management

Large scale gold mine operators: Land management Awareness raising

Formal mercury supply Possible informal or undocumented Hg supply Possible in uence on use and quantity of mercury Other in uence sometimes unrelated to mercury

Source: Adapted from Fritz et al. 2016

Figure 3: Key stakeholders influencing the use of mercury in ASGM

The Illegal Trade in Chemicals


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