A permit written for pickaxes, applied to dredges
Brazil’s Permissão de Lavra Garimpeira (PLG) was created under Law 7,805 of 1989, during the Tapajós gold rush, as a simplified title for small-scale garimpeiros. Three and a half decades later, the same instrument authorizes cooperative-held areas in the Legal Amazon that are, on average, larger than the combined holdings of individual miners and individual mining firms, and in some cases larger than industrial mining concessions. The gap between what the law says a garimpo is and what a PLG now covers is the mechanism this article examines. It is documented in Brazilian government audits, in federal police operations, and in peer-reviewed land-use mapping. What is not documented, in any source reviewed for this piece, is a traced route from a specific Tapajós permit to a specific electronics component or brand. That distinction matters for anyone building a due-diligence argument on this supply chain.
What a PLG actually authorizes
Brazilian mining law provides two main titles relevant here. The Mining Concession (Concessão de Lavra) is available to industrial mining companies and requires prior mineral discovery — geological, geophysical and geochemical surveys, sample analysis, ore-processing tests — before extraction begins. The PLG is different. According to Climate Policy Initiative/PUC-Rio’s 2025 analysis of the regime, a PLG “allows the immediate exploitation of a mineral deposit without requiring any prior mineral discovery,” though the National Mining Agency (ANM) may occasionally order such studies. A PLG can be held by individual garimpeiros, individual garimpeiro firms, or garimpeiro cooperatives.
The exemption from prior discovery is the hinge. Discovery work defines where a deposit is, whether it is economically viable, and roughly how much metal it can yield. Remove that requirement and the permit certifies a place — a polygon on a map — without establishing a credible volume for that place. The Federal Public Prosecutor’s Office (MPF), as cited by CPI/PUC-Rio, states that the lack of prior discovery hampers monitoring of both socio-environmental damage and gold laundering, because it makes it difficult to identify the exact exploitation area, how extraction is carried out, and how much gold the area can produce.
CPI/PUC-Rio characterizes the framework — the Mining Code, Law 7,805/1989, and ANM rules — as “anachronistic” and “incompatible with the nature of [garimpo’s] activities,” given that most such enterprises now operate at industrial and corporate scale. The 1989 law and the Garimpeiro Statute define garimpo tautologically, as mineral extraction carried out in garimpos, without reference to rudimentary methods. The Mining Code’s older definition still evokes pickaxes and manual devices. That indeterminacy, per the MPF, creates room for industrial mining to be concealed as garimpo.
The scale shift, in hectares
The numbers from ANM data, analyzed by CPI/PUC-Rio, show how far the permit’s use has drifted from its artisanal premise:
- Between 2016 and 2023, about 82% of gold garimpo authorizations in Brazil were granted in the Legal Amazon. Of 770,464 hectares approved nationally, 630,020 hectares are in the Legal Amazon. Pará and Mato Grosso account for 35% and 64% of that regional total, respectively.
- Of the 630,020 hectares approved in the Legal Amazon in that period, 403,369 hectares were held by cooperatives, 226,601 by individual firms, and 49 by individuals. Cooperative-held PLG area averaged about 178% of the combined area of individuals and individual firms.
- In Pará, the top 10% of PLGs — 27 permits — covered 107,666 hectares, while the remaining 90% (318 permits) covered 23,122 hectares. All 27 top-decile permits went to cooperatives.
Read together, these figures describe a permit category that in practice functions as a large-area title, concentrated in a small number of cooperative entities, in the state with the Amazon’s most active garimpo front. The concentration is not proof of wrongdoing. It is the structural condition that makes volume reconciliation difficult: when one entity holds dozens of adjacent polygons, each with its own municipal environmental license, the administrative unit of oversight is far smaller than the operating unit on the ground.
What the oversight bodies found
Three Brazilian institutions have examined PLG use in the Tapajós basin, and their findings are sequential rather than isolated:
- 2022 — CGU audit. The Comptroller General of the Union uncovered a series of illegalities in an audit of PLG use, as reported by InfoAmazonia.
- 2023 — Operation Sisaque. The Federal Police, Federal Revenue Service and MPF exposed one of the Amazon’s largest gold-laundering schemes, which relied on PLGs in Tapajós.
- 2025 — TCU finding. The Federal Court of Accounts identified structural flaws that enable gold of illegal origin to be legalized.
InfoAmazonia’s own analysis, built on the VEIO platform (which cross-references mining and deforestation data with mineral production tax records, CFEM, and gold export figures), found that between 2022 and 2026, of 540 PLGs declaring gold sales in the Tapajós River basin, 263 — nearly half — showed no evidence of extraction consistent with the amounts reported. The same analysis reports that nearly 60% of gold from legalized mining in Brazil passed through a Tapajós PLG over the past four years, totaling $2.03 billion (10 billion Brazilian reais) in declared production in the basin.
These are findings about declared production versus observable extraction. They do not, by themselves, identify where non-declared gold originated. They establish that the permit-level record and the physical record diverge at scale, which is the operational definition of a laundering channel.
The purchase chain: self-declaration at the point of sale
The laundering mechanism does not require a corrupt official at the mine gate. Under Law 12,844/2013, securities distributors (DTVMs) are the only institutions authorized to buy gold from garimpos. The seller fills out a form specifying where the gold comes from — sometimes on paper — and the process is self-declaratory: garimpeiros are not required to present documents proving origin. As Instituto Escolhas has documented, the purchase is completed on the basis of good faith, and illegal gold enters the formal market carrying a declared origin that no one has verified against the ground.
Combine that with the PLG’s exemption from prior discovery and the result is a permit that certifies a place without a volume, feeding a purchase chain that accepts a declared place without verification. The permit number becomes the laundering instrument: it is real, it is registered with ANM, and it can be attached to gold dug elsewhere.
From the basin to the export ledger
The next documented step is the state-level export record. Instituto Escolhas’ analysis of 2020 data found that Brazil exported 111 tons of gold while producing 92 tons, leaving 18.638 tons unaccounted for in production records. Among registered production, 485 kg were mined without permits in Mato Grosso and Pará. In total, 19.123 tons of exported gold lacked known origin or authorization.
The state-level pattern is the more useful diagnostic. São Paulo, Brazil’s second-largest gold exporter, produced no gold in 2020, so 100% of its exports were contaminated by illegal gold in Instituto Escolhas’ accounting. Minas Gerais, the largest producer and exporter, had 37% of its exports not produced in the state. The top destinations were Canada (41 tons), Switzerland (20 tons) and the United Kingdom (11 tons).
This is a reconciliation test any importer can run before asking which riverbank the gold came from: does the exporting state’s declared export volume exceed its declared production? If it does, the surplus has an origin that the state’s own records do not explain. That check uses public data — Comex Stat export records against ANM production records — and it does not require mine-level traceability to be informative.
Where the electronics link stops being documented
Gold is a genuine input to electronics: contacts, connectors, bonding wire, plated surfaces. Brazil is a genuine gold exporter. But the documented chain in the sources reviewed here runs from PLG to DTVM to export state to importing country. The step from importing country to a specific refiner, component, or brand is not in the retrieved evidence. No source reviewed traces a Tapajós PLG to a named electronics manufacturer, component, or product, and none establishes that any named electronics brand sources gold from Brazil at all.
That gap should be stated plainly rather than bridged with inference. The correct claim is that the PLG regime creates a documented laundering risk at the point where Amazon gold enters formal markets, and that electronics supply chains are one of the formal markets gold enters. The incorrect claim — the one the evidence does not support — is that a specific permit has been traced to a specific device.
For a buyer, the practical consequence is that a due-diligence questionnaire asking “which mine?” cannot distinguish a Tapajós PLG from a legal industrial concession, because the answer rests on a self-declared form. A reconciliation-based check is more informative: request the PLG number and the declared production volume, then test both against public ANM records and satellite-observable extraction area. Permits that fail reconciliation are the actionable list, and they are public.
What the physical record shows
The environmental stakes are measurable independently of the supply-chain question. A 2024 study in Nature Communications by Ferreira Neto and colleagues, using Landsat-derived 30-meter time series and a deep-learning classifier, mapped Brazil’s mining footprint from 1985 to 2022. It found that garimpo area reached 2,630 km² in 2022, twelve times its 1985 extent, and that 91.75% (2,410 km²) of that area lay within the Amazon biome. At least 77% of 2022 extraction sites showed explicit signs of illegality. The study also notes that garimpo sites are associated with mercury use in amalgamation, deforestation, and elevated methylmercury concentrations in adjacent populations and fauna.
On the Tapajós, Fiocruz researchers have documented mercury levels in Munduruku communities above the World Health Organization’s safe threshold, as reported by InfoAmazonia. That reporting is careful to note that a definitive causal link between exposure and specific clinical conditions in named individuals has yet to be proven. The contamination pathway — mercury entering the river, converting to methylmercury, accumulating in fish — is documented; the individual diagnosis is not. The distinction is the same one that applies to the supply chain: mechanism documented, specific attribution not.
What a place-first accountability frame would require
The policy lever implied by this evidence is reconciliation, not stricter paperwork at the point of sale. Three checks, each tied to a named dataset, would close the gap the audits describe:
- Permit-level production reconciliation. For each PLG, compare declared CFEM production against satellite-observable extraction area and against the order-of-magnitude yield estimates cited in studies (InfoAmazonia references roughly 20 grams of gold per hectare explored). Permits that fail the test are the enforcement list. The data are public: ANM permit records, CFEM declarations, and MapBiomas mining layers.
- Export-state reconciliation. Compare each state’s declared gold exports (Comex Stat) against its declared production (ANM). States with persistent export surpluses are the entry points that warrant importer scrutiny. São Paulo’s 2020 position — zero production, second-largest exporter — is the clearest example in the Instituto Escolhas analysis.
- Importer-side traceability conditioned on the first two. OECD due-diligence guidance already asks companies to identify upstream actors or adopt traceability systems. The Brazilian case suggests that identifying the DTVM is insufficient, because the DTVM’s record rests on self-declaration. Conditioning imports on permit-level reconciliation would give the guidance an enforceable referent.
None of these checks requires a new law. They require using records that already exist — ANM, CFEM, Comex Stat, MapBiomas — in combination rather than in isolation. The 1989 regime was not designed to launder gold; CPI/PUC-Rio describes it as anachronistic and poorly defined, not intentionally permissive for fraud. But a permit that certifies a place without a volume, in a purchase chain that accepts a declared place without verification, produces laundering as a structural outcome. The documented response is to test the volume against the ground.
Frequently asked questions
Is a PLG illegal?
No. The PLG is a lawful title issued by ANM under Law 7,805/1989 and the Mining Code. The concern documented by the CGU, TCU, MPF and Federal Police is that the permit’s design — no prior discovery, self-declaratory sales — allows gold from elsewhere to be declared against a legal permit. Holding a PLG is not evidence of wrongdoing; failing production reconciliation is the actionable signal.
Does the evidence show Amazon gold reaching electronics manufacturers?
No. The retrieved sources document the chain from PLG to DTVM to export state to importing country. They do not trace a specific permit to a specific refiner, component, or brand. The electronics connection is a risk pathway, not a documented route, and should be presented as such.
Why focus on the Tapajós basin?
Because that is where the oversight findings concentrate. InfoAmazonia’s VEIO analysis covers 540 PLGs declaring gold sales in the basin, and the CGU audit, Operation Sisaque and the TCU finding all concern Tapajós permits. Itaituba, in western Pará, is described in that reporting as home to Brazil’s largest mining front.
What can an importer check with public data?
Two things before requesting mine-level detail: whether the exporting state’s declared exports exceed its declared production, and whether a given PLG’s declared production is consistent with observable extraction area. Both checks use public records — Comex Stat, ANM, CFEM, MapBiomas — and both are more informative than a self-declared origin form.
Sources
- Climate Policy Initiative/PUC-Rio, “Legal Gold Garimpo in the Amazon: Recommendations for Adequate Control of Socio-environmental Impacts” (Cozendey and Chiavari, June 2025).
- InfoAmazonia, “The Brazilian government keeps giving out mining licenses in the Amazon in spite of evidence of gold laundering” (May 2026), drawing on the VEIO platform.
- Instituto Escolhas, “Brazil exports illegal gold: How to tackle the problem,” summarized at Sustainable Supply Chains.
- Ferreira Neto, L.C., Diniz, C.G., Maretto, R.V., et al., “Uncontrolled Illegal Mining and Garimpo in the Brazilian Amazon,” Nature Communications 15:9847 (2024).
- Agência Nacional de Mineração, portal and open data (permit records, CFEM).
- IBAMA, autuações e embargos (enforcement records).