Everyone’s Investing, Nobody’s Checking

The brochure and the bucket

Every few months, another tech summit fills a conference centre with the word “sustainable”. The lighting is soft, the lanyards are recycled, and somebody in a fleece gilet explains that the supply chain is now ethical, traceable and, as of this quarter, certified. I have no doubt most of them believe it, which is precisely what worries me.

I spent a good chunk of my working life in the RAF Police and then in senior security management, and if those years taught me anything, it’s that a signed piece of paper is the most comfortable hiding place ever invented. In my civilian security days, they called me Mr Memo, because I issued open memos that people had to sign to confirm they’d read them. Years later, directors were waving those signatures about as proof that things had been done. Read and done are not the same thing… but paper doesn’t know the difference, and neither, it turns out, does a battery.

This piece is about the gap between the brochure and the bucket. On one side sits the clean, whisper-quiet promise of electric cars and gleaming gadgets. On the other sits the river sand, the mica flakes, the coltan and the nickel that actually go into them, a startling amount of which is dug, stolen, smuggled and then made respectable somewhere along the way.

I went looking expecting the usual story: governments dragging their feet, money drying up, criminals stepping into the gap. That isn’t what I found. The money isn’t missing at all. It’s pouring in by the billion. What’s gone missing is the checking.

The world’s most boring robbery

Start with the dullest material imaginable, because that’s where the biggest theft is hiding. The green city of the future is made of concrete and glass, and concrete and glass are made of sand. According to the UN Environment Programme, the world now gets through around 50 billion tonnes of sand and gravel a year, a figure that has tripled in two decades and works out at roughly 17 kilos per person, per day. Only water is consumed in greater volume. It is also, to quote UNEP’s own polite understatement, largely ungoverned.

Where something is valuable, ungoverned and shovelled up by the lorryload, you don’t need a criminology degree to guess what happens next. “Sand mafias” is not a tabloid flourish. UNEP has accused them of stripping Morocco’s coastline, where residents of Sidi Bouknadel watched their beach vanish into the black market for construction. In India, the term has been in ordinary newspaper use for years.

And then there’s the detail no novelist would dare invent. In one Sri Lankan river, so much sand was dredged out that the flow reversed, pushing seawater inland and bringing saltwater crocodiles along for the ride. Somewhere, a sustainability report is describing that concrete as “locally sourced”. Technically, it was.

Shimmer, and the words we borrow

Mica is the glitter in the eyeshadow, the pearly sheen on the car paint and the insulation in the electronics. It’s also, in a great many cases, dug by children. India and Madagascar are the world’s two largest exporters of sheet mica, and most of it comes from illegal mines. A 2016 study estimated that 22,000 children were working in the mica mines of Jharkhand and Bihar, and the US Department of Labor puts the figure in Madagascar at around 10,000. The biggest buyers aren’t cosmetics firms, as you might assume, but the electronics and car industries. The shine on the new EV, in other words, may well have started its journey in a child’s hands.

While we’re here, a word on vocabulary, because this subject attracts lazy language like a magnet attracts filings. You’ll often see “rat-hole mining” used as a catch-all for any grim, hand-dug shaft anywhere in the developing world. It isn’t. The term belongs to a very specific, very local horror: the coal mines of Meghalaya in north-east India, where workers crawl through tunnels sometimes no more than three or four feet high to reach seams too thin for machines. India’s National Green Tribunal banned the practice in 2014. It carried on regardless, and an explosion at an illegal rat-hole mine in East Jaintia Hills has since killed 27 workers.

I mention this not to be pedantic but because the flattening matters. When every misery becomes one interchangeable stock image of a man in a hole, it stops being anybody in particular. And when it stops being anybody in particular, it stops being anybody’s fault.

The ore they dye

In my old trade, chain of custody was close to sacred. You logged the evidence, you sealed it, you signed for it, and if there was a gap anywhere in the record, a decent barrister would drive a lorry through it. So forgive me if what follows offends me on a professional level as well as a moral one.

Rubaya, in the eastern Democratic Republic of Congo, supplies around 15 per cent of the world’s tantalum, the stuff that makes the tiny capacitors in your phone work. In April 2024, the M23 rebel movement took control of the mining area and set up a taxation system, earning an estimated $800,000 a month according to UN experts. Global Witness estimates that at least 1,400 tonnes of coltan were smuggled into neighbouring Rwanda within a year of the takeover, and the UN’s experts described the resulting contamination of the region’s supply chains as the largest in a decade. Rwanda’s official coltan exports, meanwhile, rose more than two and a half times between 2021 and 2025, which critics argue is rather more than its own mines can explain. Rwanda denies any wrongdoing.

Here’s the bit that stopped me in my tracks. Congolese coltan from Rubaya is known in the trade as “white coltan”, because it carries more tantalum and less niobium than Rwanda’s own darker “black coltan”. A UN group of experts cited evidence back in 2015 that, once across the border, the white stuff was routinely darkened or mixed with the black to disguise where it came from.

We use the word “laundering” as a metaphor. Here it very nearly isn’t one. They change the colour of the evidence, and then they sign for it.

Flying documents and a farmers’ market

The romantic image of illicit mining is a lone figure with a pickaxe and a head torch. The reality, at scale, is usually a man with an excavator and a very good relationship with somebody in an office. Indonesia’s nickel boom, sold to the world as the backbone of the battery age, offers a textbook example. In the Mandiodo Block in Southeast Sulawesi, a concession that on paper belonged to the state-owned miner Antam, investigative magazine Tempo found dozens of illegal mines stealing nickel and selling it on to processors using fraudulent paperwork. Some of the companies involved were owned by politicians and officials’ families, and some enjoyed the protection of police generals. Satellite analysis by Tempo and Greenpeace Indonesia found nearly 229 hectares mined in 2022 alone, against the 40 hectares Antam’s approved work plan actually covered.

The miners have a lovely name for the paperwork. They call it “dokter”, short for dokumen terbang, or “flying documents”: legitimate quota papers borrowed from one permit and flown, as it were, over somebody else’s ore. When the case reached court, the state’s losses were put at around Rp5.7 trillion. No blockchain was harmed in the making of this fraud. Borrowed paperwork and a friendly signature did the job perfectly well.

Across in Myanmar’s Kachin State, rare earths tell a similar story with added chemistry. Global Witness counted more than 2,700 heavy rare earth mines spreading across an area the size of Singapore since 2016, all of it illegal under Myanmar law and barely existing on paper. The ore is part-processed in chemical leaching pools near the mines, trucked over the border into Yunnan, and refined in the Chinese state-owned plants that handle around 80 per cent of the world’s rare earth refining. Illegal at one end, perfectly official at the other.

And then there’s Kishi, in Nigeria’s Oyo State, where my favourite detail of the whole saga lives. In May 2024, soldiers and police raided a local market once known for farm produce, which had quietly become a hub for the illicit lithium trade. Thirty-two people were arrested, two of them Chinese nationals. Farm produce one week, battery metal the next. If you wanted a single image for this entire economy, you could do a lot worse than a vegetable stall doing a sideline in the energy transition.

Billions in, checks postponed

The received wisdom, and I nearly swallowed it whole, is that this shadow economy exists because official investment has stalled. Geopolitical gridlock, cautious investors, nobody willing to fund the mines, so the syndicates move in. It’s a tidy story. It’s also, as of 2026, very nearly the opposite of what’s happening.

Since January 2025, the US government has put around $8.6 billion into equity stakes in private critical minerals companies, which one investment research firm describes as the biggest push into strategic industries since the Second World War. Washington now owns slices of mining companies the way it once owned slices of banks after 2008: a planned 10 per cent stake in USA Rare Earth under a $1.6 billion package, 10 per cent of Trilogy Metals for $35.6 million, a slice of Lithium Americas. The US Development Finance Corporation has been handed a $5 billion equity fund and permission to own up to 40 per cent of the projects it backs. Nobody, in short, is short of money.

The producing countries are tightening their grip too. The DRC, which mines roughly 70 per cent of the world’s cobalt, banned exports in February 2025 and then replaced the ban with strict quotas, capped at 96,600 tonnes for both 2026 and 2027. Buried in the rules is a clause allowing the regulator to strip quotas from companies that process artisanal cobalt. How much of Congo’s cobalt is hand-dug is itself a fight: estimates run from 15 to 30 per cent down to under 2 per cent, depending on whom you ask. What nobody has convincingly answered is where the hand-dug ore goes when the legal exits narrow. I have my suspicions. So, I imagine, do the smugglers.

Now look at what happened to the checking. The EU’s Battery Regulation was supposed to make companies carry out supply-chain due diligence on cobalt, lithium, nickel and graphite from August 2025, with independent audits and public reporting. In July 2025, the EU postponed it to August 2027, as part of a “simplification” package designed to boost competitiveness. When the delay was proposed, only half of member states had even appointed the authority needed to approve the auditors. A coalition of 25 civil society, labour and business groups had asked for the rules to apply no later than August 2025. They were thanked for their input, presumably.

So here is the shape of the thing. Governments are spending more on critical minerals than at any point in living memory, and at the same moment the obligation to check where those minerals came from has been pushed back two years. It isn’t that nobody’s investing. Everyone’s investing. Nobody’s checking.

Garbage in, certificate out

At this point somebody in a gilet usually puts their hand up and says the word “blockchain”. Every sack tagged at the mine, every movement logged on a tamper-proof ledger, total transparency from pit to showroom. And to be fair, the pilots exist. The Re|Source consortium has trialled cobalt traceability from Congo to Europe with Tesla among the participants, and De Beers runs its diamonds through a blockchain at scale.

The trouble is the bit before the ledger. A blockchain faithfully records whatever it’s told, and it will go on faithfully recording it until the heat death of the universe. As the global union IndustriALL put it years ago, the technology doesn’t change the old principle of garbage in, garbage out. If the sack was filled from an illegal pit, darkened in a back yard or covered by a flying document, the ledger doesn’t purify it. It notarises it. Even the advocates concede that traceability alone can’t tell you whether the people at the bottom of the hole were treated decently on the day they dug.

One academic study of digital certification in Congo’s cobalt mines and Sierra Leone’s diamond fields went further, arguing that this shiny new transparency also works through concealment. That rings true to me. The more immaculate the paperwork looks, the fewer people feel the need to ask questions about it. I learned that with my memos. The signature at the bottom never proved anyone had done anything. It just proved that, if anything went wrong, it would officially be someone else’s problem.

The receipt in your pocket

This is usually where an essay like this tells you what to do. Buy the ethical phone. Check the label. Sign the petition. I’m not going to, because I don’t believe it, and I suspect you don’t either. The label is the problem. A label is just a memo with better graphic design.

Living the way I do now, off-grid in a corner of rural Spain, you develop an awkward habit of asking where things actually come from, because very little turns up out here unless somebody carries it. It’s an uncomfortable habit to bring back to the wider world. Every cable, every panel, every pane of glass becomes a small question with an answer nobody can quite give you. Not because the answer is secret, exactly, but because the system has been built so that nobody in it ever has to know the whole of it.

I don’t think the people on the summit stage are lying, mostly. I think they’ve been handed a very good certificate, and they’ve done what all of us were trained to do with a very good certificate, which is file it and stop worrying. Somewhere a river is running backwards. Somewhere a sack of pale ore is on its way to becoming dark. Somewhere a market stall is weighing out something that isn’t vegetables.

And somewhere, in a clean office with good lighting, somebody is signing to confirm they’ve read the due diligence report. They’ll have two more years before anyone asks whether they did anything about it. The paperwork, I’m sure, will be immaculate. It usually is.

Fact check and sources

Every factual claim in the piece traces to the source beside it. Where a figure is an estimate or contested, the piece says so.

Claim in the piece	Source
50bn tonnes of sand a year, tripled in two decades, about 17kg per person per day, second only to water, largely ungoverned	Reuters via Cyprus Mail, on the 2022 UNEP report
Sri Lankan river flow reversed, bringing seawater and saltwater crocodiles inland	Reuters via Cyprus Mail
Sand mafias stripping Morocco’s coastline, Sidi Bouknadel	Morocco Travel Blog, citing UNEP
Sand mafias in India	Oceanography, “Sand: A Resource That’s Washing Away”
India and Madagascar the two largest sheet mica exporters, mostly from illegal mines; 22,000 children in Jharkhand and Bihar	Stop Child Labor
Around 10,000 children in Madagascar’s mica sector (US Department of Labor)	Stop Child Labor
Electronics and car industries the biggest mica buyers	Terre des Hommes
Rat-hole mining specific to Meghalaya coal; tunnels three to four feet high; banned 2014	Drishti IAS and IAS Gyan
Explosion at an illegal rat-hole mine in East Jaintia Hills killed 27	Rau’s IAS
Rubaya about 15% of global tantalum; M23 since April 2024; about $800,000 a month; at least 1,400 tonnes smuggled in a year; Rwanda’s coltan exports up more than 2.5 times 2021 to 2025	Intellinews, on Global Witness’s report
Largest supply chain contamination in a decade; “white coltan” darkened or mixed with Rwandan “black coltan” (UN experts, 2015)	Global Witness
Rwanda denies involvement	AP via WSLS
Mandiodo: illegal mines, fraudulent documents, politicians’ companies, police generals’ protection	Tempo via Pulitzer Center
“Dokter” flying documents; 228.58 hectares mined in 2022 against 40 hectares in Antam’s work plan	Tempo via Rainforest Journalism Fund
State losses of Rp5.7 trillion; borrowed quota documents	Mongabay Indonesia
2,700+ rare earth mines in Kachin since 2016, illegal under Myanmar law, trucked to Yunnan, 80% of global refining	Mongabay, on Global Witness and Global Witness
Kishi produce market turned lithium hub; 32 arrests including two Chinese nationals	Africanews
$8.6bn of US equity stakes since January 2025, biggest push since the Second World War	The Oregon Group
USA Rare Earth 10% stake under a $1.6bn package; Trilogy Metals 10% for $35.6m	GlobeNewswire via Post Searchlight
Lithium Americas stake	Skillings Mining Review
DFC $5bn equity fund, up to 40% ownership	Mayer Brown via Mondaq
DRC about 70% of cobalt; export ban February 2025; quotas of 96,600 tonnes for 2026 and 2027	Voice of Nigeria, via Reuters
Quotas can be withdrawn from firms processing artisanal cobalt	IEA policy database
Artisanal share 15 to 30%	Skillings Mining Review
Artisanal share under 2% in 2024 (Cobalt Institute); Re\|Source pilot with Tesla; De Beers’ blockchain	TechBullion
EU battery due diligence postponed to August 2027; 25 groups asked for August 2025	EU Perspectives
Only half of member states had appointed a notifying authority	Slaughter and May
Blockchain and “garbage in, garbage out”	IndustriALL
Digital transparency working through concealment	Graduate Institute Geneva