Illegal mining is a significant environmental crime that generates billions in illicit proceeds and drives deforestation, biodiversity loss, toxic pollution, and social harms across the whole world. It also intersects with financial crime, enabling money laundering, trade-based laundering, corruption, tax evasion, organised crime, and conflict financing, creating material exposure points for the financial system.

This new report from WWF and Themis examines how high-risk minerals such as gold, cobalt, coltan, and rare earth metals move through opaque, multi-jurisdictional supply chains that are difficult to monitor and vulnerable to criminal exploitation. It assesses risks connected to AML/CTF compliance, ESG and nature-related disclosure, supply chain due diligence, and reputational and regulatory obligations for financial institutions, insurers, and investors.

Drawing on global survey data and expert case studies, the report maps convergence typologies, red flags, legal and governance frameworks, and emerging standards, while outlining practical measures FIs can take to strengthen detection, due diligence, reporting, and responsible finance strategies aligned with evolving sustainability and anti-financial crime expectations.

‍Key Findings from the Report

1. Illegal mining is a major environmental crime with financial system exposure
Illegal mining generates an estimated $48B USD in criminal proceeds annually, with additional social, ecological, and fiscal losses not captured in financial estimates.

2. Convergence with financial crime is significant and multi-channel
Illegal mining intersects with money laundering, trade-based laundering, corruption, bribery, tax evasion, fraud, terrorist and conflict financing, organised crime, and human trafficking, creating complex AML/CTF exposure pathways.

3. Risk exposure spans the entire mineral supply chain
Financial exposure is not limited to extraction. It extends to transport, processing, equipment supply, trade finance, commodity trading, and manufacturing, creating indirect and obscured entry points.

4. High-risk minerals drive criminal incentives
Commodities such as gold, cobalt, coltan and rare earth metals are in demand for the energy transition and digital economy. Their high value, liquidity, and traceability challenges make them attractive to illicit networks.

5. Environmental and social impacts are severe and under-reported
Illegal mining contributes to deforestation, water contamination, biodiversity loss, toxic pollution (mercury/cyanide), land degradation, and IPLC displacement, with associated health, human rights and livelihood impacts.

6. Financial institutions are exposed but not fully prepared
Survey data indicates that exposure to illegal mining exists across multiple business lines, but internal policies, training and screening for environmental crime remain limited.

7. Governance gaps enable illicit extraction and trade
Weak law enforcement, legal grey zones, fragmented jurisdiction, and limited certification or traceability tools create openings for criminal infiltration of mineral supply chains.

8. Certification and risk management tools are emerging but fragmented
Existing frameworks (e.g., conflict minerals regulation, ASM certification, traceability platforms) cover only portions of the market and are unevenly adopted.

9. Reporting by FIs can materially support enforcement
Suspicious transaction reports (STRs/SARs) have played a role in identifying illegal mining flows in jurisdictions such as Peru, indicating actionable value for FIU collaboration.

10. FIs have opportunities to shape responsible transitions
Enhancing due diligence, AML integration, screening, SAR reporting, ESG alignment, ASM formalisation, and nature-related disclosure can reduce exposure and support sustainable supply chains.