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Ledger 1 : 33 — For each dollar financing nature-based solutions in 2023, about $33 financed activities harmful to nature. (UNEP)
Cases / Mining · Mali · 2023–2026

Loulo-Gounkoto gold complex: Barrick–Mali dispute, provisional administration and settlement

Nature's voice · report
The tailings storage facility on my land at Loulo is classified "Extreme (GISTM)" for consequence of failure, with flow liquefaction of tailings as the risk driver and existing controls listed as "None", according to Barrick's disclosure.
Did nature suffer? Yes. Harm is on record.
Recorded
  • A credible failure would contaminate wetlands and water in a sub-catchment of my Gara River, part of the Falémé River basin, "being the most important source of water in the area", according to Barrick. Barrick
  • At the facility's compliance point, weak-acid-dissociable cyanide exceeded the 50 mg/L limit 7 times in 2023 (up to 113.8 mg/L), 6 times in 2024 (up to 64.7 mg/L) and 10 times in 2025 (up to 134.4 mg/L on 10 July 2025), according to the cyanide audit. Eagle Environmental for the International Cyanide Management Institute
What the record lacks: 2 none on record · 1 not disclosed · 2 insufficient · 1 self-reported only · 4 disputed · 2 unclear See the gaps

Mali and Barrick, which owns 80% of the Loulo-Gounkoto gold complex, disputed taxes, dividends and the mining code from 2023; gold was seized, operations suspended in January 2025 and a provisional administrator ran the complex from June to December 2025. A settlement announced on 24 November 2025 included a payment of about FCFA 143 billion. Barrick's disclosures for the complex's tailings facility and cyanide plant record an "Extreme" consequence classification and cyanide limit exceedances.

≈ FCFA 143 bnCash payment at settlement, 28 November 2025
USD 253 million, "part of the global settlement amount" (Barrick FY2025 financial statements). Bloomberg reported, citing sources, a total of FCFA 244 billion (about USD 430 million); neither party confirmed it.

Status As of August 2026: the November 2025 settlement had been implemented; the 10-year Somilo permit renewal was still to be completed (MD&A of 4 February 2026) and Barrick's GISTM disclosure of 5 August 2026 recorded partial conformance.

What?
Mali and Barrick disputed taxes, dividends and the mining code at the Loulo-Gounkoto gold complex from 2023; gold was seized, operations suspended and a provisional administrator appointed before a November 2025 settlement, while Barrick's disclosures record an "Extreme" consequence classification for the tailings facility and cyanide limit exceedances. Barrick Mining Corp.
Where?
Loulo-Gounkoto complex, Kéniéba area, Kayes region, western Mali, adjacent to the Falémé River on the Senegal border. Eagle Environmental for the International Cyanide Management Institute
When?
Dispute from 2023; payment October 2024; employees incarcerated 25 November 2024; operations suspended 14 January 2025; provisional administration 16 June–16 December 2025; settlement announced 24 November 2025. Barrick Mining Corp.
Who?
Gained
  • Government of Mali — A payment of about FCFA 143 billion (USD 253 million) on 28 November 2025 and, per Barrick's filing, a USD 240 million liability for retained earnings payable by 2030 Barrick Mining Corp.
  • Barrick — Regained control of the complex; it contributed USD 505 million of revenue and USD 16 million of net income from 16 December 2025; permit renewal for 10 years was part of the terms Barrick Mining Corp.
Lost
  • Barrick — Paid FCFA 50 billion in October 2024 and about FCFA 143 billion in November 2025; lost access to the mine for six months Barrick Mining Corp.
  • Four Barrick employees — Incarcerated from 25 November 2024 until the settlement Barrick Mining Corp.
Harmed
Why?
Barrick said Mali demanded the mines become subject to the 2023 Mining Code in violation of stability rights; Mali's ministries alleged Barrick had not respected its commitments; Reuters reported a state claim of at least 300 billion CFA in taxes and dividends. Barrick Mining Corp.
How?
Gold exports were restricted, criminal proceedings brought, the gold stock attached, operations suspended and a provisional administrator appointed; the parties settled with a payment, withdrawal of charges and ICSID claims, and a 10-year permit renewal. Barrick Mining Corp.
6 of 6 questions answered from the record

What happened

The record, in order.

The Loulo-Gounkoto complex lies in the Kéniéba area of the Kayes region in western Mali, adjacent to the Falémé River on the Senegal border. The Malian state owns 20% and Barrick 80%. In 2023, according to Barrick's FY2025 financial statements, the Government of Mali demanded that the mines become subject to the 2023 Mining Code, which Barrick said was "in direct violation of the stability rights contained in the Conventions"; fiscal and customs proceedings began. Reuters reported in October 2024 that Mali sought "at least 300 billion CFA (US$512 million) in outstanding taxes and dividends". In October 2024 the Ministries of Mines and Finance alleged that Barrick had not respected its commitments, as summarised in Barrick's reply.

In early October 2024 Barrick paid FCFA 50 billion (USD 84 million in the filing, USD 85 million in Barrick's 24 October 2024 communiqué, which said the payment was made as part of ongoing negotiations although Barrick admitted no liability). Gold exports were restricted in November 2024. Barrick said the government initiated criminal proceedings alleging violations of exchange control regulations; four employees were incarcerated on 25 November 2024. Somilo and Gounkoto filed for ICSID arbitration on 18 December 2024. On 2 January 2025 the Senior Investigating Judges of the Pôle National Économique et Financier issued an interim attachment order against the gold stock, which was moved to a custodial bank on 11 January; operations were suspended on 14 January 2025.

On 16 June 2025 the Bamako Commercial Tribunal ordered six months of provisional administration at the government's request; the administrator took over on 23 June 2025. Zoumana Makadji, a former health minister, was named administrator. AFP reported in July 2025 that the authorities put part of the seized gold stock up for sale to pay wages. Barrick said on 16 June 2025 that the ICSID tribunal "has been constituted" and that it had requested provisional measures.

Barrick announced an agreement on 24 November 2025. According to its filing, the terms were the termination of the provisional administration, "the dropping of all charges against Barrick, its affiliates and employees and the release of the four detained employees", "the renewal of the Somilo Exploitation Permit for a 10 year period" and withdrawal of the ICSID claims. Barrick paid about FCFA 143 billion (USD 253 million) on 28 November 2025 and agreed to pay out all historical retained earnings of Somilo and Gounkoto by 31 December 2030, recognised as an "other liability to Loulo-Gounkoto NCI for $240 million". The parties sought withdrawal of the ICSID claims on 15 December 2025, the provisional administration ended on 16 December and the seized gold, with a carrying value of USD 92 million at removal, was returned on 18 December 2025. As of the filing (MD&A dated 4 February 2026) the 10-year permit renewal remained to be completed.

Barrick's GISTM disclosure for the Loulo tailings storage facility (5 August 2026) records partial conformance and a consequence classification of "Extreme (GISTM)". Barrick lost access to the mine and the facility during the provisional administration (June–December 2025). The disclosed risk driver is flow liquefaction of tailings, with existing controls listed as "None"; buttress construction was underway following a stoppage due to loss of site access. A credible failure would contaminate wetlands and water in a sub-catchment of the Gara River, part of the Falémé River basin. An ICMI Cyanide Code audit (audit 3–8 October 2025, report signed 22 June 2026) found "substantial compliance", with compliance issues in the previous three-year cycle, and recorded exceedances of the 50 mg/L WAD cyanide limit at the facility's compliance point: 7 in 2023 (up to 113.8 mg/L), 6 in 2024 (up to 64.7 mg/L) and 10 in 2025 (up to 134.4 mg/L on 10 July 2025). The auditor wrote that there was little evidence that the exceedances were reviewed with a view to identifying the causes. Digby Wells assessed the total closure plan cost at USD 51,815,308; the Malian government now requires closure funding to be lodged in a separate financial instrument with a Malian bank, and the mechanism on file is an unapproved 2021 Letter of Financial Strength.

  1. 2023Mali demands the mines become subject to the 2023 Mining Code; fiscal and customs proceedings begin
  2. 2024Oct: Barrick pays FCFA 50 billion; Nov: gold exports restricted; 25 Nov: four employees incarcerated; 18 Dec: Somilo and Gounkoto file for ICSID arbitration
  3. 20252 Jan: interim attachment order on gold stock; 14 Jan: operations suspended; 16 Jun: Bamako Commercial Tribunal orders provisional administration (administrator from 23 Jun); 24 Nov: agreement announced; 28 Nov: payment of about FCFA 143 billion; 15 Dec: withdrawal of ICSID claims sought; 16 Dec: provisional administration ends; 18 Dec: seized gold returned
  4. 20264 Feb: MD&A notes the 10-year Somilo permit renewal remains to be completed; 22 Jun: cyanide audit report signed; 5 Aug: GISTM disclosure for the Loulo tailings facility

What was said

Claims, in the words of those who made them.

“in direct violation of the stability rights contained in the Conventions”

Barrick, FY2025 financial statements, on the demand that the mines become subject to the 2023 Mining Code · 2026 · Barrick Mining Corp.

“initiated meritless criminal proceedings … alleging violations of exchange control regulations”

“unjustly imprisoned”

Barrick, on its four employees · 16 June 2025 · Barrick

“as part of ongoing negotiations… Although Barrick admits no liability”

Barrick communiqué on the October 2024 payment · 24 October 2024 · translated from French · Barrick

“This will pave the way for a constructive path forward”

“Barrick is aiming to restart operations by 1 January 2026”

“the provisional administrator is seeking the funds to restart”

An anonymous source cited by AFP, on the provisional administration · July 2025 · translated from French · Dakaractu / AFP

“there was little evidence that the exceedances were reviewed with a view to identifying the causes”

Where accounts differ

Each party's account, side by side, with its source. The record does not settle these points; it shows them.

Barrick's October 2024 payment in US dollars
Company or project
Barrick FY2025 financial statements

USD 84 million (FCFA 50 billion).

Barrick Mining Corp.
Company or project
Barrick communiqué of 24 October 2024

USD 85 million.

Barrick
Total value of the settlement
Press and investigations
Bloomberg, citing sources (reported by Reuters via Kitco)

FCFA 244 billion (about USD 430 million): 144 billion within six days of signing, 50 billion through VAT-credit offsets and 50 billion already paid the year before. Neither party confirmed the figure.

Reuters via Kitco
Company or project
Barrick FY2025 financial statements

A payment of about FCFA 143 billion (USD 253 million) on 28 November 2025 as part of the global settlement amount, and a USD 240 million liability for retained earnings; no global figure is given.

Barrick Mining Corp.
The grounds for the state's measures against the complex
Company or project
Barrick

The demand to apply the 2023 Mining Code violated stability rights; the criminal proceedings were meritless; the measures were unjustified.

Barrick Mining Corp.
Government and regulators
Mali's Ministries of Mines and Finance, as summarised in Barrick's reply

Barrick had not respected its commitments.

Barrick
Sale and return of the seized gold
Press and investigations
AFP via Dakaractu (July 2025)

The authorities put part of the seized gold stock up for sale to pay wages.

Dakaractu / AFP
Company or project
Barrick FY2025 financial statements

The attached gold stock was returned on 18 December 2025 and sold before the end of 2025.

Barrick Mining Corp.

How it looked

What was shown, beside what was recorded.

Shown

  • The government's actions to block exports and seize gold were "unjustified".
    Barrick, 16 June 2025 · Barrick
  • Barrick will soon be allowed to resume normal operations.
    Mali's Ministry of Mines, statement via Reuters, November 2025 · Mining Technology
  • Barrick had not respected its commitments.
    Mali's Ministries of Mines and Finance, as summarised in Barrick's reply of 24 October 2024 · Barrick
  • The settlement total was FCFA 244 billion (about USD 430 million): 144 billion within six days of signing, 50 billion through VAT-credit offsets and 50 billion already paid the year before.
    Bloomberg, citing sources; reported by Reuters via Kitco, 25 November 2025 · Reuters via Kitco

Recorded

Who gained

Money that reached nature, beside money that stayed elsewhere.

Reached nature or the ground

Not published
Closure plan cost, Loulo (Digby Wells third-party assessment, September 2024 update)$52m
Includes third-party cyanide decommissioning. Mali requires the funding in a separate instrument with a Malian bank; the mechanism on file is an unapproved 2021 Letter of Financial Strength.

Gained elsewhere

Not totalled
Mali's claim for outstanding taxes and dividends (Reuters)≥ $512m
Window: 2024
At least 300 billion CFA.
Barrick payment, October 2024$84m
Window: 2024
FCFA 50 billion. The filing gives USD 84 million; Barrick's communiqué gives USD 85 million.
Barrick payment, 28 November 2025$253m
Window: 2025
About FCFA 143 billion, part of the global settlement amount.
Retained earnings of Somilo and Gounkoto to be paid out by 31 December 2030$240m
Window: to 2030
Recognised as an other liability to Loulo-Gounkoto non-controlling interests.
Settlement total reported by Bloomberg, citing sources≈ $430m
Window: 2025
FCFA 244 billion; neither party confirmed it.
Carrying value of the seized doré gold at removal$92m
Window: 2025
Revenue of the complex from 16 December 2025$505m
Window: 2025
Net income of the complex from 16 December 2025$16m
Window: 2025
Currency: USD · Window: Mixed — see each line. Figures cover different periods and are not compared as a ratio. * Estimate built from cited figures.

Responses on record

  • barrick (16 June 2025; 26 November 2025): Barrick said the government's actions to block exports and seize gold were unjustified and that its employees were unjustly imprisoned, that it held firm through ICSID arbitration, and, on the settlement, that it "will pave the way for a constructive path forward". · Barrick
  • mali-gov (October 2024; November 2025): Mali's Ministry of Mines said Barrick would soon be allowed to resume normal operations. In October 2024 the Ministries of Mines and Finance alleged Barrick had not respected its commitments, as summarised in Barrick's reply. · Mining Technology

In court and with insurers

Every proceeding and every insurer decision on record.

Lawsuits and rulings

  1. 2024–2025Settled
    Criminal proceedings against Barrick's Malian companies and employees (exchange-control regulations)
    Pôle National Économique et Financier, Bamako (Senior Investigating Judges) · Criminal · Government of Mali (per Barrick); Senior Investigating Judges → Barrick's Malian subsidiaries Somilo and Gounkoto, and employees

    Barrick said the government initiated proceedings alleging violations of exchange control regulations. Four employees were incarcerated on 25 November 2024, and on 2 January 2025 the judges issued an interim attachment order on the gold stock. Under the November 2025 settlement all charges were to be dropped and the four detained employees released. No conviction is recorded. Barrick Mining Corp.

  2. 2025–2025Claimant won
    Provisional administration of the Loulo-Gounkoto complex
    Bamako Commercial Tribunal · Civil · Government of Mali → Barrick's Malian subsidiaries (Loulo-Gounkoto complex)

    On 16 June 2025 the tribunal ordered six months of provisional administration at the government's request; the administrator took over on 23 June 2025. Barrick said it would appeal. The administration ended on 16 December 2025 under the settlement. Barrick Mining Corp.

  3. 2024–2025Settled
    Somilo and Gounkoto v. Republic of Mali (ICSID arbitration)
    International Centre for Settlement of Investment Disputes · Arbitration · Somilo and Gounkoto (Barrick subsidiaries) → Republic of Mali

    Filed on 18 December 2024. Barrick said on 16 June 2025 that the tribunal had been constituted and that it had requested provisional measures. The parties sought withdrawal of the claims on 15 December 2025 under the settlement. Barrick

Insurers

No insurer decision on record.

What nature saw

Outcomes measured on the ground, and nature's note.

Nature's report opens this page. Below: further outcomes measured on the ground.

Tailings facility consequence class
Extreme
GISTM classification in Barrick's August 2026 disclosure
Cyanide limit exceedances (WAD, 50 mg/L)
7 · 6 · 10
2023 · 2024 · 2025; maximum 134.4 mg/L on 10 July 2025
Closure plan cost
USD 51.8m
No Malian-approved financial guarantee yet
Months without Barrick access to the facility
6
June–December 2025, during provisional administration

What we don't know

Undisclosed, unproven, untried: recorded as data.

Figures

  • Insufficient Settlements: Bloomberg, citing sources; about USD 430 million; not confirmed by either party.

Accounts

  • Disputed Barrick's October 2024 payment in US dollars
  • Disputed Total value of the settlement
  • Disputed The grounds for the state's measures against the complex
  • Disputed Sale and return of the seized gold

Record

  • Insufficient Insufficient: a downstream impacts assessment and emergency response plans are still to be updated for full GISTM conformance, due "by 2027" according to Barrick's disclosure.
  • None on record None on record: an approved closure financial instrument; Mali now requires closure funding in a separate instrument with a Malian bank, and the only mechanism is an unapproved 2021 Letter of Financial Strength.
  • None on record None on record: an environmental clause in the settlement; Modern Mining reported "no environmental matters".
  • Not disclosed Not disclosed: the composition of "Provisions" of USD 47 million in the provisional purchase-price allocation.
  • Unclear Unclear: whether the gold put up for sale by the provisional administration in July 2025 and the stock returned to Barrick on 18 December 2025 are the same portion of the seized gold.
  • Unclear Unclear: whether a final ICSID discontinuance order has been issued; the parties sought withdrawal on 15 December 2025.
  • Self-reported only Self-reported only: the tailings facility's consequence classification and risk controls come from Barrick's own GISTM disclosure; no independent measurement of downstream water quality is on record.

Did the harm stop?

Not established. The plant did not operate from 15 January 2025 and restarted with slurry to the tailings facility from 12 August 2025; cyanide exceedances were recorded in 2025, including 134.4 mg/L on 10 July 2025.

Who paid?

The money side was settled between Barrick and Mali (about FCFA 143 billion paid on 28 November 2025, plus a USD 240 million liability for retained earnings). For the tailings facility and Gara River catchment, no closure guarantee approved by Mali is on record.

Sources

Voices on record: ✓ Company or project— Government and regulators— Courts✓ Press and investigations— Communities and civil society— Researchers✓ Standard-setters and registries

Standard-setters and registries

  1. Cyanide Code Compliance Summary Audit Report, Barrick Loulo Gold Plant (audit October 2025)
    Eagle Environmental for the International Cyanide Management Institute · 2026-06-22

Connected cases

Related matters, and cases linked to this one through the same organisations, with the role each played in both.

Science and environment

Cyanide (in gold mining)
A highly toxic chemical used to dissolve gold from ore.
Tailings and tailings dam
Tailings are the waste left after ore is processed; a tailings dam is the embankment that stores them as wet sludge.
Wetland
Land that is saturated or covered with water for long periods, such as marshes, swamps and peat bogs.

Law and courts

Arbitration
A private dispute process in which an appointed arbitrator, instead of a court, decides the case.

Carbon and conservation finance

Offset
Using carbon credits to balance emissions released elsewhere, so that a buyer can claim lower or zero net emissions.

Bonds and banking

Guarantee
A commitment by a third party, often a development bank, to pay if the borrower does not.