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GIFF: Footnotes to Nowhere

GIFF: Footnotes to Nowhere

September 28, 2016, by Mark Mattner

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The need for reliable data and localised outputs - plus an exploration of the link between mining and criminality

The GIFF project is an interesting initiative in its combination of three ever important themes: i) artisanal and small-scale mining (ASM), ii) illicit financial flows, especially in relation to mining, and iii) criminality. From this angle, it is an important project with great potential to yield tangible and useful results for our partners on the ground.

Felix Hruschka highlighted the fact that the existing regulatory systems in most mining countries are designed for industrial mining, not ASM. This status quo has long been reflected in donor approaches which tended to focus on enhancing existing systems and on improving the ability of governments to collect revenues from mining. Broadly speaking, this has also been a key focus of the German Cooperation Regional Resource Governance Program in West Africa.

In recent years, more and more attention has been paid to ASM issues. This trend can of course be linked to the apparent end of the boom in commodity prices and was in part driven by donors, but largely by the partner governments, we work with.

ASM is a sector whose challenges and problems have been well documented, but in which the solutions are much more difficult to ascertain. The resulting tendency is sometimes to jump at easy sounding projects, which in reality turn out to be very complicated. One such example is that of developing cooperatives in ASM communities, which is a potentially promising approach. Establishing cooperatives sounds like a simple step to the formalisation of the ASM sector but, as repeated across this blog series, formalisation is a process and cannot be achieved by administrative fiat. There are many other factors that need to facilitate it and that can undermine it. The GIFF Project is a useful step towards identifying and unpacking, and then addressing, some of these issues.

Lack of reliable data

We should remember that the first step to providing the best advice to our partners is collecting good data. There are facts and figures out there, but are they reliable? A couple of years ago, our Program conducted a meta-study in Liberia of all the reports that have been written about ASM. We examined thousands of pages and a clear pattern emerged. Many of the references, when checked, are empty. They are footnotes to nowhere.

This is disconcerting because it appears that policy-making and the advice provided by development partners is not always based on empirics but frequently recycles what is seen as perceived wisdom. Rigorous, data-driven research is imperative.

Incentives > Enforcement

As a Regional Program, we often talk to our partners about mineral smuggling, which is one of the most challenging aspects of our work. Criminality is particularly hard to address for development partners because it is here where we leave the realm of non-political governance work and engage with the political economy of security. In the context of development work, these are issues that are hard to grasp, and that we know relatively little about.

In this vein, before enforcement is considered, we should first understand the flows and identify the opportunities for criminal activity to take place. Prosecution is an easy conversation, but the reality is one of exceedingly weak enforcement mechanisms. It is more appropriate, realistic and useful, to think about positive incentives, opportunities, and motivations for inspiring business actors to operate formally. Incidentally, this mind-set would also help us emphasise the fact that ASM is not a mere enforcement challenge but a livelihood issue with wide-ranging consequences for poverty in rural areas.

Going forward: data, toolkits, and criminality

As the GIFF project sharpens its scope and defines its outputs, my sense is that the focus should be on three main areas. Firstly, there should be an emphasis on collecting reliable data or, at the very least, summarising existing data to highlight what is credible and what is not, what can be re-used, what needs re-thinking and what needs to be discarded.

Secondly, as the project aims to develop a toolkit for practitioners, tools need to be geared towards existing programs and activities. It is a big challenge to develop a toolkit that is integrated into local processes, but it’s a bigger risk, and a great shame, to develop a global document that gets lost and is never looked at. Outputs must be practical, and relevant to the situation on the ground.

Thirdly, the link between the ASM sector and criminality is vital and under-explored. The importance of this research, provided that it takes into account the importance of understanding incentives and livelihood systems, is immediate and pressing.


Dr. Mark Mattner heads the German Cooperation Regional Resource Governance Program in West Africa (Liberia, Sierra Leone, Côte d’Ivoire, and Guinea). In this role, he works with governments, civil society, and the mining sector to promote mining as a development tool.

The GIFF Project is a joint initiative with the Global Initiative against Transnational Organised Crime. It enables practitioners to investigate and map financial flows linked to the ASM gold sector and strengthen programme design and policy formulation.

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