Client : Confidential
Completed : Q1 2025
At Themis, the confidentiality of our clients and the integrity of our investigative processes are foundational to everything we do. This case study—while based on real events concluded in early 2025—has been anonymised to protect both client identity and the individuals involved in the investigation.
This case highlights the tenacity and creativity of the Themis Intelligence team in navigating opaque jurisdictions, uncovering financial crime risk, and helping clients avoid reputational damage and legal exposure.
A Middle Eastern diversified mining group engaged Themis to perform Enhanced Due Diligence (EDD) on a Bolivian mining company that had recently announced the acquisition of several mining concessions in the Bolivian Andes.
The client sought confirmation of the legitimacy and ownership of these concessions and wanted assurance that the company and its executives were not involved in financial crime before moving forward with a potential partnership.
Despite being incorporated for several years, the subject company exhibited virtually no online footprint. It appeared only on two corporate registries and lacked a website, digital presence, or public-facing communications. Likewise, its officers had almost no digital history.
With few direct sources of information, the Themis team needed to use creative, multi-source methods to identify potential red flags and triangulate the company's actual activities and associations.
Themis investigators approached the case from two angles:
Mining Concession Verification
Using Bolivia’s official mining cadastre database, our team cross-referenced the concessions allegedly held by the subject company against government records. By geolocating coordinates, areas, and registered owners, we discovered that the concessions were not held by the subject company but by a third party—an individual previously flagged to the client.
Executive Background Checks
Our team constructed a profile of the subject company's key executive by identifying related companies listed on government databases. One company was flagged as "temporarily suspended," which led to deeper investigation. Through the exclusion of similarly named entities (to avoid red herrings), our team identified the beneficial owner, who was linked via local media sources to a money laundering scheme involving illegally mined cobalt.
This revelation stemmed from the seizure of a 1-ton shipment of cobalt by Bolivian authorities. The owning company failed to provide documentation verifying the mineral’s origin — a key red flag in illicit trade.
The mining concessions supposedly owned by the subject company were, in fact, legally held by a third party previously highlighted as high risk.
That individual was named in court documents connected to an ongoing investigation into illegal cobalt mining and laundering operations.
The subject company’s executive was tied to a suspended entity linked to this network, and the minimal digital trace appeared to be a deliberate attempt to mask involvement in criminal activity—possibly through unindexing or online suppression.
Based on Themis's findings, the client was able to withdraw from the proposed engagement, thereby avoiding a high-risk partnership with an organisation tied to illicit cobalt trade and individuals under active investigation. This case demonstrates how intelligence-led due diligence - particularly in frontier markets with weak transparency - can prevent costly, high-stakes missteps and ensure compliance with internal and international standards.
Themis was engaged by a Middle Eastern diversified mining firm to investigate a Bolivian mining company that had recently made a deal to acquire a number of mining concessions in the Bolivian Andes. Our client wanted to confirm the legitimacy of the reported concessions and their ownership by the subject company, and required Enhanced Due Diligence to search for any potential financial crime concerns relating to the firm’s executives or its operations before taking them on as a partner.
Despite being incorporated several years prior, the target company had virtually no online presence, appearing only with basic details on two corporate databases and lacking a website or social media accounts. Additionally, the company’s officers had close to no online presence, meaning our analysts needed to think laterally to identify risk and address the client’s needs.
As part of our investigation into the subject company’s mining concessions, our team used a government mining cadastre database to match the concessions the client had been notified of to those registered with the government, and identify and corroborate their coordinates, areas, and ownership. In doing so, we found that the mining concessions purportedly held by the subject company were actually owned entirely by a third party flagged to use by the client. This individual was connected to a network of concessions outside of those known to the client.
Simultaneously, our team investigated an executive at our subject company, building out a list of companies in which he held key roles. In one case, a company was identified that was listed on government databases but appeared as temporarily suspended for unknown reasons, prompting further investigation.
Identification of this company involved targeted searches to discount ‘red herring’ entities. Having pinpointed the owner of the company in question, our team subsequently discovered media articles that named him and his company as subjects in an investigation into a scheme to launder the proceeds of illegal cobalt mining, after Bolivian authorities had seized a 1-ton shipment of the critical metal following a failure by the company to provide proof of provenance.
Once this case was identified, our analysts were able to delve deeper into the details of the investigation and map out a network of illicit actors linked both directly and indirectly to our subject company. Importantly, our research revealed that the concession-holding third party was named in court documents relating to the investigation – the absence of their name from search results suggesting an attempt to unindex information from the public-facing internet.
After receiving our EDD report, our client was able to halt their interactions with the subject company, avoiding exposure to and investment in a company linked to entities under investigation for organised crime.
