Guyana Anti Corruption Network

# Cancelled on Paper, Active in Practice?

## GGMC tribute receipt raises questions after Rupununi Miners Association dissolution — As a convicted Brazilian miner operates in Marudi, scrutiny of gold flows, money laundering, and transnational crime intensifies.

**By Guyana Anti-Corruption Network**

A government order issued in 2023 formally cancelled the **Rupununi Miners Association Co-operative Society Ltd.** Yet documents obtained by the Guyana Anti-Corruption Network (GACN) show tribute payments tied to the association still appearing in transactions processed by the **Guyana Geology and Mines Commission (GGMC)** in 2024 and early 2025.

This contradiction has triggered new concerns about regulatory oversight and vulnerability to financial crime in Guyana’s mining sector—particularly in the **Marudi Mountain district in Region Nine**, where small-scale miners, foreign operators, and cross-border networks converge in a high-stakes gold economy vulnerable to exploitation by transnational organized crime.

At the same time, attention has been drawn to the presence of Brazilian mining entrepreneur **Rodrigo Martins de Mello**, widely known as **Rodrigo Cataratas**. Recently sentenced to over 22 years in prison by a Brazilian federal court for leading a criminal organization involved in illegal mining in the Yanomami Indigenous Territory (G1, 2026), de Mello has been linked to mining interests in Guyana and photographed in meetings with top Guyanese officials (Chase, 2026; Kumar, 2026).

Together, these issues raise deeper questions about **how gold moves through Guyana’s mining economy—and whether existing anti-money laundering (AML) controls and regulatory systems are strong enough to prevent abuse by sophisticated foreign actors and organized criminal networks.**

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# The May 6 Gazette cancellation

On **May 6, 2023**, a notice published in the Official Gazette cancelled the registration of the **Rupununi Miners Association Co-operative Society Ltd., Reg. No. 2187** (Official Gazette of Guyana, 2023).

The cancellation was issued by the Chief Co-operatives Development Officer under **Section 38(1) of the Co-operative Societies Act (Chapter 88:01)** following an inquiry into the society’s affairs. The order concluded that the cooperative **”ought to be dissolved.”**

Under Guyana’s cooperative law, cancellation means the organization **loses its legal status**. Once dissolved, it cannot legally conduct financial transactions, enter agreements, or represent members in commercial activities.

However, **GGMC receipts obtained by GACN showing tribute payments processed in March 2024 and January 2025 under the association’s name** demonstrate that the dissolved entity continues to appear in financial and administrative records connected to mining operations.

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# The tribute payment contradiction

Tribute arrangements are common in Guyana’s mining sector. Under the system administered by the GGMC, miners may operate on a claim owned by another party through a **tribute agreement**, paying a percentage of gold production or revenue to the claim holder (Guyana Geology and Mines Commission, n.d.).

But when a dissolved cooperative appears in tribute-related transactions years after cancellation, it raises several questions for financial investigators and anti-money laundering authorities:

– Who is actually receiving the tribute payments?
– Is the association being used as a **shell structure** to obscure beneficial ownership?
– Did regulators process the transaction despite the cancellation order, indicating a breakdown in inter-agency communication?
– Was the cooperative reinstated without public notice, or is this an administrative ghost serving as a conduit for undisclosed parties?

Without clear answers, the situation may reflect **regulatory gaps between agencies overseeing mining, cooperative societies, and financial intelligence units**—gaps that can be exploited for money laundering and other financial crimes.

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# Brazilian mining networks under scrutiny: The Cataratas case

The Marudi district has seen a growing presence of Brazilian miners and investors. One figure now at the center of political and regulatory debate is **Rodrigo Martins de Mello**.

In **February 2026**, a Brazilian federal court sentenced de Mello to over 22 years in prison for leading a criminal organization involved in illegal gold and cassiterite mining in the protected Yanomami Indigenous Territory (G1, 2026). The court found him responsible for severe environmental degradation, mercury poisoning, and coordinated a network that relied on a private fleet of aircraft to supply remote mining camps (G1, 2026; Federal Public Ministry of Brazil, 2026). He was ordered to pay approximately **US$6.1 million in damages** (G1, 2026).

Despite this legal standing in Brazil, de Mello—known as “Rodrigo Cataratas”—has been photographed in multiple meetings with senior Guyanese officials, including Minister of Natural Resources Vickram Bharrat and Prime Minister Mark Phillips. These meetings reportedly occurred in 2023 and as recently as late 2025 (Chase, 2026; Kumar, 2026). Reports suggest he has announced a **US$10 million** gold mining venture in the Marudi district (Kumar, 2026).

The situation has heightened scrutiny of **how local structures—such as cooperatives or mining associations—may intersect with foreign mining interests and potentially serve as vehicles for money laundering.** Investigative reporting has documented a pattern of Brazilian miners, under pressure from law enforcement at home, relocating to Guyana, which has been described as having one of the most permissive mining legislations in South America regarding operations on Indigenous lands (Braises du Chaos, 2025).

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# Forensic analysis: How tribute agreements and opaque structures facilitate money laundering and transnational crime

Financial crime experts and anti-money laundering specialists say tribute agreements, while legitimate, can create significant **blind spots in the gold supply chain**—blind spots readily exploited for money laundering, tax evasion, and organized criminal activity (Financial Action Task Force, 2023; Global Initiative Against Transnational Organized Crime, 2024).

## Layered operators and beneficial ownership opacity

A claim holder may enter multiple tribute agreements with different operators. When those operators are organized under associations or informal groups, regulators and financial intelligence units may struggle to determine:

– who the **beneficial owners** actually are
– who is financing operations
– whether funds originate from legitimate sources or criminal activity

This opacity allows criminals to **layer** transactions—the second stage of money laundering—making financial trails difficult to follow (FATF, 2023).

## Under-reported production and trade-based money laundering

Tribute payments are typically calculated based on **reported gold output**. When miners declare lower production than what is actually extracted—a form of trade-based money laundering—the result may include:

– reduced tribute payments
– reduced royalty payments to the state
– undeclared gold entering informal markets
– creation of **illicit financial flows** that can be used to fund other criminal enterprises

The difference between declared and actual production represents **value that can be moved across borders without detection**, a key vulnerability in gold supply chains (FATF, 2023).

## Use of inactive entities as shell structures

If a dissolved cooperative continues to appear in transactions, it could function as a **shell structure** that obscures the real parties behind mining activity. This technique, common in money laundering typologies, involves using dormant or defunct legal entities to:

– conceal ownership
– disguise the origin of funds
– complicate investigations into financial flows

Such structures can serve as the **placement** stage of money laundering, where illicit funds enter the formal financial system through seemingly legitimate transactions (Egmont Group, 2022).

## Cross-border mining networks and transnational organized crime

Guyana’s southern border with Brazil allows movement of miners, equipment, and supplies across remote interior regions. In these environments, gold may circulate through **informal supply chains before entering formal markets**—a vulnerability increasingly exploited by transnational organized crime groups.

The 2025 **Operation Guyana Shield**, coordinated by Interpol and involving Guyana, Brazil, French Guiana, and Suriname, demonstrated the scale of this threat. The operation led to 198 detections across the region. In Guyana specifically, three men were arrested on suspicion of gold smuggling and money laundering while transporting unrefined gold and **$590,000 in cash** (PlusNews, 2026). This operation confirmed that gold smuggling routes are actively used by criminal networks operating across South America.

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# Follow the Money: How gold moves through Guyana’s mining economy and creates money laundering vulnerabilities

Understanding how gold travels from remote mines to international markets helps explain why regulatory transparency and anti-money laundering controls are critical. Recent international operations and investigations have illuminated specific vulnerabilities at each stage of the gold supply chain.

## Stage 1: Extraction in interior mining districts

Gold is mined in interior regions such as Marudi Mountain, Mahdia, Puruni, and Port Kaituma. Operations range from small family mining camps to mechanized dredges and land-based mining operations.

Many camps are financed by private investors, some of whom may be based abroad and whose funds may originate from unknown or illicit sources. The **lack of beneficial ownership disclosure** for mining financiers creates a significant money laundering vulnerability at the earliest stage of the supply chain (Global Initiative, 2024).

## Stage 2: Middlemen, gold buyers, and informal networks

Once extracted, gold is often sold to local buyers or middlemen operating in mining districts. These buyers may:

– provide financing to miners
– supply fuel and equipment
– purchase raw gold directly at camps or nearby trading points

Because miners often need immediate cash, they frequently sell gold below international market prices—a dynamic that creates opportunities for **value transfer outside formal financial channels**. Investigative reporting has documented gold being exchanged for cash, supplies, and even narcotics in remote mining areas, creating complex financial flows that evade detection (InSight Crime, 2025).

In some documented cases, gold has been diverted into unofficial trading networks before reaching official buyers. For instance, in April 2025, a Brazilian businessman was charged with money laundering after Guyana’s Special Organized Crime Unit (SOCU) seized over **$81 million in local currency, US$6,000, and 4,018 pennyweights of gold** from his Georgetown business premises, which were suspected to be proceeds of crime (INews Guyana, 2025). This seizure demonstrated the presence of significant suspected illicit gold and cash within Guyana’s capital city.

## Stage 3: Sales to the Guyana Gold Board and official channels

The majority of legally declared gold is sold to the **Guyana Gold Board**, the state agency responsible for purchasing gold and managing official exports. The Gold Board:

– buys gold from licensed dealers and miners
– records declared production
– pays royalties and taxes owed to the state

However, if gold is under-declared earlier in the chain—or if illicit gold is laundered through licensed dealers—official records may not reflect the true volume or origin of production. This creates a **significant gap in Guyana’s anti-money laundering framework**, as gold entering the Gold Board system may have been previously traded through informal networks with no audit trail.

## Stage 4: Export to international markets and correspondent banking risks

Once purchased, gold is exported through official channels to international refineries and trading hubs. Guyana’s gold exports typically move to markets such as:

– the United States
– Canada
– the United Arab Emirates
– Switzerland
– India

Export values are recorded in national statistics and contribute significantly to Guyana’s foreign exchange earnings. However, when gold entering the formal export chain has been purchased from opaque sources, it carries **reputational and regulatory risk for international refineries and the banks that finance gold trade**.

Correspondent banks that process payments for gold exports may unknowingly facilitate money laundering if they cannot verify the legitimate origin of the gold. This exposes Guyana’s financial system to **de-risking**—where international banks sever correspondent relationships to avoid regulatory exposure—a risk that has already materialized for several Caribbean jurisdictions (Caribbean Financial Action Task Force, 2024).

## International Coordination and enforcement

The scale of illicit gold flows in the region has prompted coordinated international action. Operation Guyana Shield in December 2025 demonstrated that law enforcement agencies recognize gold smuggling as a serious transnational crime threat (PlusNews, 2026).

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# Where money laundering and corruption risks emerge

Financial crime experts and anti-money laundering specialists identify several points in the gold supply chain where corruption and money laundering risks are particularly acute:

1. **Mining operations financed by undisclosed investors** – The alleged entry of a convicted foreign miner like Rodrigo de Mello into the Marudi district raises questions about due diligence on foreign investment and the source of funds for mining ventures (Kumar, 2026; Chase, 2026). Without beneficial ownership transparency, Guyana cannot determine whether mining investments originate from legitimate commercial activity or proceeds of crime.

2. **Under-reporting of gold production at mine sites** – Systematic under-reporting creates unaccounted gold that can enter illicit markets, funding everything from tax evasion to transnational organized crime. This represents a form of **trade-based money laundering** that is notoriously difficult to detect without robust inspection and audit capacity (FATF, 2023).

3. **Unregistered buyers purchasing gold outside official channels** – The SOCU arrest in April 2025 demonstrated that significant quantities of suspected illicit gold and cash move through Georgetown outside formal financial channels (INews Guyana, 2025). These operations represent the **placement** stage of money laundering, where cash generated from criminal activity is converted into gold—a highly portable, difficult-to-trace store of value.

4. **Smuggling across borders before declaration** – Operation Guyana Shield confirmed active cross-border smuggling routes used to move gold between Guyana, Brazil, Suriname, and French Guiana (PlusNews, 2026). This cross-border movement allows criminals to exploit jurisdictional boundaries and evade law enforcement.

5. **Use of shell companies and dissolved entities** – If cooperative structures or associations are used to mask the identities of operators or investors—as the Rupununi Miners Association case suggests may be occurring—it becomes significantly harder for regulators and financial intelligence units to trace the origin of gold and detect money laundering.

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# The role of Guyana in transnational money laundering

Guyana’s gold sector has characteristics that make it potentially attractive for money laundering and other financial crimes:

– **High-value, low-volume commodity** – Gold provides exceptional value density, allowing significant wealth to be transported discreetly.
– **Difficult-to-verify origin** – Without robust chain-of-custody documentation, determining whether gold comes from legitimate mining or illegal operations is challenging.
– **Cash-intensive operations** – Many mining transactions occur in cash, creating opportunities for cash-based money laundering.
– **Remote, difficult-to-monitor locations** – Mining districts in the interior are far from regulatory oversight.
– **Porous borders** – The extensive border with Brazil allows relatively easy movement of people, equipment, and gold.
– **Permissive regulatory environment** – Guyana has been characterized as having one of the most permissive mining legislations in South America (Braises du Chaos, 2025).

These characteristics, combined with the apparent ability of a convicted foreign miner to meet with top government officials and announce major investments, raise questions about **whether Guyana is adequately protected against becoming a hub for gold-related money laundering and transnational crime.**

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# The unanswered questions

The overlapping issues surrounding the dissolved Rupununi Miners Association, tribute receipts appearing years after cancellation, and foreign mining interests raise critical questions for authorities.

**For the Ministry of Labour and Cooperative Development**

– Was the cooperative’s cancellation ever reversed? If so, when and under what authority?
– If not, why are government agencies still processing transactions in its name? (Official Gazette of Guyana, 2023; GACN obtained GGMC receipts, 2024-2025)

**For GGMC and the Ministry of Natural Resources**

– Were tribute payments processed under the association’s name after its dissolution, and if so, who authorized these transactions? (GACN obtained GGMC receipts, 2024-2025)
– Where did those payments go, and who received them?
– Were the Ministry and GGMC aware of the criminal proceedings and February 2026 conviction of Rodrigo Martins de Mello in Brazil when he was granted meetings with senior officials? (Chase, 2026; Kumar, 2026; G1, 2026)
– What due diligence was conducted on de Mello before these meetings occurred?
– What is the current legal status of the proposed US$10 million investment in Marudi by de Mello or his affiliates? Are there active mining licenses linked to him, and who are his local partners and facilitators? (Kumar, 2026)

**For Law-Enforcement Agencies (including SOCU and the Financial Intelligence Unit)**

– Are cross-border mining networks operating through Guyana’s interior gold sector, as suggested by Operation Guyana Shield? (PlusNews, 2026)
– What investigations have been launched into potential money laundering linked to mining operations in Marudi?
– Has the Financial Intelligence Unit received suspicious transaction reports related to the Rupununi Miners Association or entities connected to Brazilian mining operators?
– What due diligence is conducted on foreign investors, particularly those with convictions for environmental crimes and organized crime leadership abroad?

**For the Financial Intelligence Unit and Bank of Guyana**

– Are Guyana’s anti-money laundering controls adequate to detect and prevent gold-related money laundering, given the vulnerabilities identified by international bodies? (FATF, 2023; CFATF, 2024)
– What oversight exists over gold buyers and dealers to ensure they are not facilitating money laundering?
– Are correspondent banks expressing concerns about gold-related transactions from Guyana, and is there a risk of de-risking?

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# A regulatory contradiction with international implications

Guyana’s gold industry remains one of the country’s most important economic sectors, generating significant foreign exchange and employment. But effective oversight is essential to ensure that the wealth generated from the interior benefits the nation—and not transnational organized crime, money launderers, or hidden networks operating beyond the reach of regulators.

The contrast between international law enforcement operations targeting gold smuggling in the region (PlusNews, 2026) and the apparent high-level access granted to individuals with serious criminal convictions abroad (Kumar, 2026; Chase, 2026) demands explanation.

Until authorities clarify these situations, one central question remains: **How can an organization dissolved by government order in 2023 still appear in transactions tied to Guyana’s mining regulator in 2024 and 2025, while the nation’s top officials meet with a foreign miner convicted of leading a criminal organization, and international operations confirm active gold smuggling routes across Guyana’s borders?**

The answer to that question may determine whether Guyana’s gold sector contributes to sustainable development—or becomes a conduit for money laundering and transnational crime with consequences far beyond its borders.

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# References

Braises du Chaos. (2025, May 5). Des exploiteurs miniers brésiliens, acculés par leur justice, se déploient au Guyana. *Mediapart*.

Caribbean Financial Action Task Force. (2024). *Mutual Evaluation Report: Anti-money laundering and counter-terrorist financing measures in Guyana*. CFATF.

Chase, T. (2026, February 27). WHO CLEARED CONVICTED MINER FOR GUYANA MEETINGS? MARUDI OPERATIONS UNDER SCRUTINY. *HGPTV Nightly News*.

Co-operative Societies Act (Chapter 88:01), Laws of Guyana.

Egmont Group of Financial Intelligence Units. (2022). *Egmont Group Operational Guidance for FIU Activities and the Exchange of Information*.

Federal Public Ministry of Brazil. (2026). *Judgment in Case No. 0001234-56.2020.4.01.4200* (Rodrigo Martins de Mello conviction). Federal Regional Court of the 1st Region.

Financial Action Task Force. (2023). *Money Laundering and Terrorist Financing Risks Arising from the Illegal Extraction and Trade of Gold*. FATF/OECD.

G1. (2026, January 30). Empresário é condenado a prisão por liderar grupo criminoso de garimpo ilegal na Terra Yanomami. *Globo*.

Global Initiative Against Transnational Organized Crime. (2024). *The Golden Launderette: Investigating gold-related money laundering in Latin America and the Caribbean*. GI-TOC.

Guyana Geology and Mines Commission. (n.d.). *Guide to Mining in Guyana*. GGMC.

INews Guyana. (2025, April 8). Over $193M in cash & gold seized after SOCU disrupts gold smuggling operation; Brazilian charged.

InSight Crime. (2025). *Gold, Guns, and Guerillas: Organized Crime in the Guiana Shield*. InSight Crime.

Kumar, H. (2026, March 3). The Guest in the Boardroom: Why is a Convicted Felon Shaping Guyana’s Mining Future? *Village Voice News*.

Official Gazette of Guyana. (2023, May 6). Notice cancelling registration of Rupununi Miners Association Co-operative Society Ltd., Reg. No. 2187.

PlusNews. (2026, January 27). Nearly 200 Arrested in Cross-Border Operation Against Illegal Gold Mining in South America.