Several shipments of cocoa beans from the Beni area were sacked by ADF forces. While the Federation can do little to prevent armed groups from attacking goods in transit, it has diversified its sourcing to regions outside of this armed groups influence.


No incidents to report


No incidents to report


August 2018, while in transit across the border into Goma, a group of officials demanded payment, in cash, for the transit of goods. Payment was refused so the officials tried denying entry into the DRC. The driver transiting the sugar simply parked the vehicle and removed the keys. After blocking traffic for several minutes, the officials gave up their attempts and released the vehicle without any payments.

ASM Gold:
  • February 2018, a DFP received a phone call from a buying agent stating that one of his colleagues, also a buying agent, had been kidnapped. After alerting the police and SAEMAPE, who began an investigation, it was discovered that the alleged kidnapping victim had been “released” by his assailants in order to retrieve money from the buying as ransom. As there was no evidence that the buying agent had been kidnapped after speaking with various neighbors and community members, the police looked into the buying agent’s personal life and discovered that he probably kidnapped himself in order to divert the buying money for personal reasons. All business was halted with the buying agent in question, and a new buying agent was hired; the police continue to investigate the situation.
  • February 2018, while transporting their cooperative beneficiary with gold in the DFP’s vehicle, the DFP’s driver swerved to avoid oncoming traffic. While doing so, the DFP’s vehicle hit and killed a child, six years of age, while walking home from school. This accident was in no way the fault of the driver or the DFP, rather the fault of a bus attempting to illegally pass traffic in the opposing lane. However, the DFP has failed to properly report this incident and failed to reply to multiple requests to see the issue resolved. Instead, the DFP gave their driver $1,200 and instructions to handle the issue independently of the organization. It is the Federation’s suspicion that the DFP is attempting to conceal this incident in an effort to protect their organizations reputation. As this was the Federation’s first engagement with this DFP, all attempts of the DFP to engage in signing a partnership agreement have been disregarded by the Federation. As the cooperative beneficiary had nothing to do with this incident, other than being in the vehicle, the Federation has continued to work with and support their activities and purchase gold from them.
  • May 2018, two incidents occurred while in transit of material. The first occurred while crossing the border from DRC into Rwanda where security officials attempted to stop the transit of goods, claiming they needed to ‘inspect’ them first. The Federation employees refused to enter a private room with the security officials as they had no authority to their request. The Federation employee immediately called a UN partner program to ensure their safety and transparency. Two UN officials arrived shortly thereafter and were able to assist the Federation employees in avoiding what was clearly an attempt to extort money. The second incident happened upon goods clearance by Rwandan Revenue Authority at Kigali airport. After walking the Federation employee through the first security screening checkpoint, the RAA official seemed to whisper something to an Rwandan National Police officer. That same RNP officer later stopped the Federation staff member and demanded to see the transit documentation accompanying the material shipment. Even after reviewing the ICGLR certificate which documented the material origin from the DRC, the RNP officer demanded to see the “other documentation” which he later stated was the Rwandan certificate of origin.  After showing all the legal paperwork from the DRC the RNP officer stated the Federation employee still needed to claim the material’s origin from Rwanda. The Federation employee refused to falsify this documentation and immediately called the US embassy for assistance. RNP later confronted the Federation employee, after covering their name tags, stating he should not have called the embassy, he was not being officially detained but he also wasn’t free to leave. The Federation employee remained in the airport overnight and later discussed the issue with the chief of police the next morning who stated, “it was a just a misunderstanding” and that all future shipments should go through him to avoid future confusion of his officers. Shipments no longer transit through this border crossing or the Kigali International Airport.
  • June 2018, a member of the Armed Forces of the DRC (FARDC) demanded that CODEMA pay an illegal fee ($10.00 USD) during travel on the Mambasa-Bunia route. CODEMA and their DFP notified the Comité Provincial de Suivi about this illegal payment in July 2018.
  • June 2018, a miner from a non-validated site entered the Kafiawema site at which point he attempted to sell 1.86 grams of hard rock gold to the buying agent. Upon inspection, the buying agent noticed that it was in fact a piece of iron weighing 1.2 grams which were covered by a thin layer of gold weighing 0.84 grams.
  • July 2018, one buying agent requested to temporarily use the backpack of a miner. Inside this backpack was a small package of gold the miner had collected. When the backpack was returned to the miner, the package of gold had gone missing. The action taken to rectify this situation is to provide the buying agents backpacks that can be used as well as verification that the backpacks are in good working order. The incident was reported to the security team on the mine site.
  • September 2018, a miner also occupying the position of Director General of the site administration was found to be tampering with the manual scales used in the purchasing of gold from his own mining team. This miner was arrested and fined for the infraction. In response SAEMAPE’s Chef de Service has conducted retraining on traceability standards.
  • October 2018, it was discovered that a miner, member of the CODEMA cooperative, was buying gold from other miners in collaboration with a gold trader outside of the DFP’s project, thus outside the ‘traceable’ supply chain. CODEMA alerted the SAEMAPE and an investigation is ongoing.
  • October 2018, although no longer sourcing from the Nyamurhale site, it was reported by our DFP partner to have children present. After further inquiry, our DFP partner determined that the COMIANGWE cooperative had been approached by another DFP focusing on schooling children. The cooperative leader instructed her members to “bring their kids to work” so that the DFP could pay for their school fees. No further engagement of this cooperative will take place until such time its leadership is replaced.
  • October through November 2018, for unknown reasons, recording of traceability data from a DFP temporarily ceased (fault). As there was gold prefinanced by the Federation to the DFPs cooperative beneficiary, the Federation demanded that all gold be delivered to it in due order. The DFP then facilitated a sale, 564 grams, to a known illicit actor with a history of money laundering and smuggling. This fault in recording was confirmed by the 3rd party private enterprise recording all traceability data offshore, described in their words as a complete data ‘blackout’. The Federation suspects this sale to an illicit actor was an attempt to conceal failures of the DFPs system. Since this incident, the Federation has enacted a companywide policy to implement its own traceability and due diligence measures with all cooperative partners to prevent any future lapse’s in data management. Direct engagement of this DFP has been kept at a minimum in anticipation of the program’s closeout.
  • October 2018, two men from the FARDC arrived at the Tokomeka mine site and attempted to extract payments to guarantee safety. These men were informed that they were at a conflict-free mine site and did not require their services. These men then stated that they would require payment on their next visit and proceeded to leave. The two men in question have not been reported to have returned to the mine site. The manager of the CODEMA cooperative is arranging a meeting with the Administrator of Mambasa Territory to address the issue.


*DFP=Donor Funded Program