Scaling Up Gold Trade in Burkina Faso with Eve Sanou
By Eve Sanou and Tegan Holmes - August 2, 2021
For most of the men and women engaged along the informal gold supply chain in Burkina Faso, there are only limited opportunities both to become formalized and to achieve more than a subsistence level of livelihood. The European Partnership for Responsible Minerals-funded, Artisanal Gold Council (AGC)-RESOLVE–Responsible Minerals Initiative (RMI) implemented project called Scalable Trade in Artisanal Gold (STAG), recognizes all of the men and women, directly and indirectly, involved along the formal and informal gold supply chain in Burkina Faso.
One of the women responsible for this move towards formalization and scaling up trade on behalf of the STAG project is Compliance Officer, Eve Sanou. In order to understand the ways in which miners, their communities, and those involved in the gold trade are marginalized from entering the formal economy, Eve has worked extensively in artisanal mining and developed a career in raising awareness on the characteristics of- and the lack of transparency in- the artisanal and small-scale gold mining (ASGM) and large scale gold mining (LSM) sectors in Burkina Faso. This has involved extensive investigative reporting and work within the mining sector over many years.
Eve Sanou, Compliance Officer, STAG | AGC 2021
Prior to joining the AGC, and STAG, Eve noticed that there was a lack of public information related to the Burkinabè mining sector in general. Yet, there seemed to be new ASGM mining operations popping up all over the country and new LSM operations pushing forward. This lack of communication and transparency in both large and small sectors led Eve to her first major foray into the world of mining in Burkina Faso in 2014.
Right away, Eve began to increase public information on mining and launched the first mining magazine of its kind in Burkina Faso titled, “Paysage Minier du Faso” which means “Mining Landscape of Faso.” This bi-monthly magazine focused on the rich mineral wealth contained within the soils of Burkina Faso, and included articles and investigative pieces on LSM and ASGM operations within the country, and interviews with various stakeholders along the supply chain, as well as opportunities for suppliers of goods and services, and advertisers and investors interested in becoming involved.
And right away, to help artisanal miners, the magazine delved into the formalization process for them, with a specific focus on the documentation and processes necessary for the granting of different types of permits needed to achieve formal status. In Burkina Faso, there are a number of systems and permits in place for formal gold trading, collecting, exporting, and mining. First, any artisanal miner or gold collector must possess identity cards specific to their job in ASGM. These cards are issued by ANEEMAS (the National Agency for the Supervision of Artisanal and Small-scale Mining Operations). The gold collectors or ‘collecteur d’or’ have to be associated with a formal gold trader and exporter, called a comptoir, for which they collect the gold. The comptoirs have to go through a costly and administratively complex process in order to obtain their trade licenses which have to be renewed every three years. Over the last few years, ANEEMAS has established a clear gold pricing scheme on the sites as well as between comptoirs and gold collectors which is expressed as a percentage of the gold price. The magazine worked to explain some of these complex permitting requirements until its final issue was published in 2018. When funding for the magazine ran out, Eve took this as a chance to pivot directly into the informal ASGM sector she had come to know so well, and she joined the comptoirs, spending some years working directly in Burkina’s gold supply chain. Ultimately this paved the way for Eve to join STAG.
The Flow of Formal and Informal Gold Purchases
Formally, gold is purchased at the sites by gold collectors on behalf of the comptoirs in town (Ouagadougou, Bobo Dioulasso, and many others). The comptoirs usually pre-finance the collectors to buy the gold on the sites. Once the gold is brought to the city, the comptoirs buy it from the collectors. In theory, it can be sold locally to ANEEMAS and jewelers, though they have not yet typically had the capital or systems to buy much. In addition, miners and collectors are supposed to pay a minimum amount of gold per month to ANEEMAS, but this frequently does not occur either. The reality is that a substantial portion is exported abroad to refineries and large international jewelry stores (in Dubai, France, Switzerland, etc.). At this level, the comptoirs respect and use formal export procedures. First, by certifying the gold at BUMIGEB (the national Mining and Geology Office) at the rate of 25 FCFA or $0.40 USD (West African Francs) per gram (about 1%) and 2,000 ($3.60 USD) FCFA per ingot, and paying the export tax at the rate of 225,000 ($405 USD) FCFA per Kilogram (about 1%), and other related costs for obtaining all the required documents (special export authorization, export title) and time and effort.
Gold produced by amalgamation with mercury (sponge gold) in Bantara, ready for collection | AGC 2021
Informally, gold is purchased on the sites by gold collectors the same way that it is purchased formally. However, these collectors do not sell anything at the national level and do not report anything on the purchase, sale, or export. These are the basis for the registers that are consulted by BNAF (the national anti-fraud brigade), therefore, this gold is often invisible and is not traced (has no traceability). These can be large quantities of gold that are fraudulently transported to Mali or Togo and ultimately often to Dubai with the complicity of the customs and border police. The proceeds of these fraudulent exports can be used to purchase goods in Dubai or China, and lead to a form of money laundering, which is very difficult for the state to control.
The challenges preventing artisanal gold miners and traders from operating formally can be numerous. These include the gold export tax of 225,000 ($405 USD) FCFA per kilogram, compared to neighboring countries such as Mali and Togo, where the tax is lower. In Togo, for example, the gold export tax is 45,000 ($80 USD) FCFA per kilogram. The difference is immediately noticeable. The Burkinabè tax can represent 50% of a trader’s margin of 2% on the gross gold value. Further disincentivizing formal trade, there are the commissions charged by the banks on the repatriation of funds from the sale of gold to international refineries at a high rate of 3% of the value of the export receipts. As well, as of yet, the prices instituted by the State through ANEEMAS’s buying program are not competitive. ANEEMAS offers rates of -10% to -13% of the world price, which typically constitutes a loss for the miners and traders. The State has been slow at finding effective ways to encourage formalization and this has led to a loss of needed public revenue.
But back to Eve. On her journey to better under the ASGM sector in Burkina Faso, Eve took a job with a ‘comptoir’ in Ouagadougou as the Director of Operations. This experience, which took place in both the informal and formal sectors of the gold trade, allowed her to increase her knowledge and capacities on how gold is sold, bought, and exported or smuggled out of the country. It also gave her the opportunity to form a deep network with different actors along the gold supply chain and to forge close links with miners and collectors in the field.
After seeing how the informal and formal gold trade works from the ground up, and how artisanal miners can be exploited for profit, but recognizing the vital importance of the sector to millions of people, Eve’s interest in transforming and legitimizing the sector grew. When STAG was announced in Burkina Faso, and team building began in May 2021, Eve found the opportunity she needed to bring her deep field knowledge to the development of the Burkinabè sector. As a part of the project team, she is able to help the artisanal miners she now has personal connections with, achieve better prices in the field, access formal finance systems, and become connected to the international market through the implementation of internationally recognized due diligence mechanisms such as the CRAFT Code.
“What is important to me is that through the STAG project, I can encourage miners to take their destiny into their own hands and complying with the CRAFT code is one of the ways to do this and open themselves to the possibilities of improving their living conditions.”
“I will be very happy to see that in two to three years I was able to reach a large number of miners on many different artisanal sites in my country and help them on the issue of formalization, through the adoption of good practices in health and safety, environment, and help them build capacity on business practices and on new methods of extraction of gold without mercury.”
Eve (front right) with a group of women miners in Burkina Faso associated with STAG | AGC 2021
As implementation of the STAG project goes into full swing, Eve’s motivation for helping the artisanal gold miners and traders she has come across is evident. The next three years will see the project flourish, and Eve will be one of the keys to this success. Eve will assist with the formalization process, risk management at the mining sites, with the establishment of clear accounting procedures for formal gold trade, and will certainly be contributing to the creation of an incentives model for competitive pricing. Eve will also do this with a cross-cutting gender-sensitive approach which will empower women to have better opportunities in the mining sector. Eve is a great example for this role.
Ultimately, Eve hopes to see Burkina Faso’s informal supply chain become formalized so that it can provide better and safer jobs for Burkinabès, and drive economic growth for their communities to help them have the opportunities needed to make a better life. This is what all of the men and women along the gold supply chain deserve, and focusing on scaling up formal gold trade is how Eve plans to make it happen.