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    InícioEm inglêsOp-Ed: ASM risk is becoming harder to manage

    Op-Ed: ASM risk is becoming harder to manage

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    Mining companies routinely describe artisanal and small-scale mining (ASM) as a material risk. Too often, however, it is still managed with incomplete information and addressed only after it has disrupted operations, crossed concession boundaries, or created environmental and social liabilities.  

    Gold Fields flags illegal and artisanal mining across parts of its Ghana, Peru, and South Africa operations, with potential security, reputational, environmental, social, and financial impacts. AngloGold Ashanti lists ASM as a potential source of business disruption, with environmental, health, safety, security, and liability implications. Southern Copper has stated that illegal mining at its Los Chancas project in Peru needs to cease before resource verification drilling and environmental, hydrogeological, and geotechnical studies can resume. 

    The risk is also material to governments. EITI notes that ASM provides livelihoods for more than 40 million people globally, but remains largely unregulated in many resource-rich developing countries, leaving governments with limited information on production, revenues, employment, and operations.  

    Overview of an area of southeastern Peru that is experiencing significant impacts from artisanal gold mining activity in recent years. While high-resolution imagery clearly shows surface impacts, consistent monitoring remains difficult in this extremely cloudy region due to the cost and availability of cloud-free acquisitions. Source: EarthDaily analysis.

    When this language becomes common across filings, policy discussions, and transparency reporting, it signals that the issue is no longer being treated as exceptional. ASM has reached that point. It now appears in discussions about revenue leakage, deforestation, mercury emissions, concession risk, and supply-chain due diligence. 

    Not all ASM creates the same risk 

    One reason the industry struggles to manage ASM is that it is often treated as a single risk category. It ranges from individual informal miners through to organised, licensed small-scale operations. In some contexts it is legal and regulated. In others it is informal, unlicensed, environmentally damaging, or linked to illegal supply chains. The risk profile depends on where the activity is occurring, whether rights and permits exist, how material moves to market, and whether basic environmental, labour, health, and safety controls are in place. 

    ASM is shaped by many forces, including commodity prices, local livelihoods, informal labour markets, land access, enforcement capacity, and supply-chain incentives. Without a current view of where activity is occurring, how it is changing, and what it is affecting, companies and governments are left reacting to consequences rather than managing risk. 

    A view of Area A in Figure A over a two year time period. The area, which shows minimal disturbance as of February 2024 has experienced significant changes from artisanal mining activities by the end of 2025. Due to the high cloud cover, radar-based change detections form the primary methodology for this environment. Time-stamped detections over the analysis period are shown in red in the bottom image. Source: EarthDaily analysis.

    That gap affects tactical decisions, like enforcement and compliance, and strategic ones, like formalisation and taxation policy. It also affects companies, which need to distinguish isolated incidents from emerging patterns before exposure becomes operationally significant. 

    Financial impacts are very real 

    The financial impacts from undeclared production and informal mineral flows can be significant.  Swissaid estimated that at least 435 tonnes of gold, worth around $31 billion, left Africa undeclared in 2022.  

    Ghana puts the issue into sharper focus. Reuters reported that the Swissaid analysis found a 229-metric-ton gap over five years between Ghana’s declared gold exports and matching imports recorded by trade partners. The estimated value was about $11.4 billion, with much of the gold believed to have moved through Dubai. Ghana’s recent traceability reforms are aimed at bringing more artisanal gold into formal channels and reducing undeclared exports. 

    Another example is Burkina Faso, where EITI cites a national study that put illicit financial flows from five minerals at $4.93 billion between 2012 and 2021.  

    Constrained production monitoring leaves governments trying to formalise the sector, target inspections, protect revenue, and reduce harm without knowing where activity is concentrated or how it is changing. 

    Small mining footprints can still create large environmental consequences 

    A 2025 global inventory linked 5.4 million hectares of deforestation to mining between 2001 and 2020. Around 70% came from mines smaller than one square kilometre, illustrating how thousands of small disturbances can accumulate into landscape-scale change. 

    The Peruvian Amazon provides one example. MAAP, an initiative of Amazon Conservation, estimated 139,169 hectares of gold-mining deforestation across nine regions by mid-2025. The organization subsequently called for reforms to Peru’s ASM law and a cleanup of REINFO, the country’s informal mining registry. 

    The environmental footprint also extends beyond land disturbance. UNEP estimates that artisanal and small-scale gold mining accounts for 37% of global mercury emissions, making it the largest source worldwide. Once contamination moves through water, soil, food systems, or downstream communities, the issue is no longer confined to the mining area.

    In this study area in Ghana, the cumulative effects of gold mining along a waterway is mapped over 5 years from 2021 through 2025. By monitoring the patterns of mining, stakeholders can quantify the problem over time and take actions to mitigate the environmental impact. Source: EarthDaily analysis.

    In some contexts, ASM-related risk extends beyond mining 

    Artisanal mining supports livelihoods for tens of millions of people globally, and any serious discussion about ASM needs to acknowledge that upfront. In many places, ASM is a significant contributor to local economies, whether licensed, informal, tolerated, or in the process of being formalised. 

    The challenge is that ASM does not exist in a vacuum. In some jurisdictions, the same activity that provides income can also sit alongside ineffective regulation, informal taxation, smuggling routes, environmental damage, or conflict-linked mineral flows. 

    Eastern DRC is one of the clearest examples. In parts of the region, artisanal production has operated alongside armed groups, informal taxation, and cross-border smuggling. Reuters reported in 2024 that M23 rebels were generating around $300,000 a month from taxing the Rubaya coltan area. Colombia shows a different version of the problem, with illicit gold mining becoming one of the revenue sources used by illegal armed groups.  

    These cases show why the same surface disturbance can mean very different things — legal, illegal, or somewhere in between — depending on who controls it and where the material goes.

    The visibility gap behind the risk 

    Governments, companies, and supply-chain actors may know ASM is present, but often lack a reliable, current picture of where it is expanding, how quickly it is moving, and what it is interacting with. By the time impacts are visible through field reports, audits, enforcement action, or community complaints, the situation may already have changed.  

    Earlier visibility changes the response options. It can help identify where formalisation may be beneficial and suitable, where enforcement is needed, where environmental oversight should be focused, where operators face encroachment risk, and where supply-chain due diligence needs stronger evidence. 

    Regular, landscape-scale observation should therefore be part of a broader shift from episodic reporting to continuous risk intelligence. Satellite monitoring is one component of that shift, alongside field engagement, regulation, due diligence, and formalisation. 

    The next step for companies and governments alike is building a current, continuously updated picture of ASM activity into how risk and policy decisions actually get made. 

    Steve Davis is Director, Mining and Energy, EarthDaily. He is a mining transformation and strategy expert, currently leading global market engagement for EarthDaily’s mining technologies.

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