Additional Investigations – Bloomberg; By Simon Marks, Jinshan Hong, Michael J Kavanagh, Hayley Warren and William Clowes. Down the road from Uganda’s main international airport Entebbe, the gold refinery once controlled by the sanctioned Belgian gold entrepreneur Alain Goetz sits behind a “no access” sign.
The African Gold Refinery was sanctioned by the US in 2022 along with Goetz and a network of companies Washington said helped finance armed groups in eastern Democratic Republic of Congo, where gold has long fueled conflict that has killed and displaced millions. The sanctions froze US-linked assets and barred companies globally from dealing with him and the named businesses.
But four years later, Thaba Investments, a company that’s been registered at the same address since 2021, and involving some of the same people as AGR, is responsible for nearly half of Uganda’s gold exports — worth billions of dollars a year — using some of the same trade corridors and suppliers historically associated with Goetz’s operations, according to a Bloomberg analysis of trade data, corporate filings and customs records, as well as interviews with Western diplomats, Ugandan officials and gold merchants.
AGR itself is no longer operating and the board resolved to close the firm in April 2024. But Thaba has used some of the same intermediaries and the same logistics provider as AGR — which weren’t sanctioned — to export gold to the United Arab Emirates and beyond, the records suggest. Goetz denies any role in Thaba or knowledge of its ongoing business, and Bloomberg found no public document showing he personally controls the company or directs its post-sanctions trades. The majority shareholder of Thaba, Musthaque Murikkoli, who previously held an employment visa sponsored by AGR, told Bloomberg in an emailed response that he’s never had any business relationship with Goetz.
But three Western officials and one former senior Ugandan financial investigator familiar with Goetz’s activities said he has continued to operate through proxies appointed to Thaba’s board, keeping his name off Ugandan company filings. A 2022 report by the Extractive Industries Transparency Initiative — an international standards watchdog — said AGR was “trading as Thaba Investments.”
“There has never been any relationship, past or present, between myself and Thaba Investments,” Goetz said in a written response to questions. He said any claims to the contrary have “no credible basis.”
“AGR was a legitimate and regulated refinery, if any shortcomings may have occurred in that process, with great regrets, they were inadvertent and were never intended to facilitate conflict-linked or illicit gold flows,” Goetz said, adding that it conducted due diligence on counterparties to national and international standards.
The US government has a different view. “Mr. Goetz helped to create the conflict gold trade,” the US Office of Economic Sanctions Policy and Implementation said in 2023 in response to his failed petition to be removed from the sanctions list. His trading patterns “helped to establish the illicit routes through which gold would move from the Eastern DRC during the periods of conflict.”
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AGR accounted for about two-fifths of Uganda’s gold export value from 2018 to 2021, totaling $1.8 billion, according to customs records compiled by Big Trade Data. Thaba accounted for a similar share from 2023 through mid-2026, totaling $6.8 billion thanks to higher export volumes and increased gold prices. The company was responsible for nearly half of the country’s gold export value in the 12 months through June 2026. Bloomberg’s analysis focused on gold in unwrought, semi-manufactured or powder forms.
Thaba Emerged as African Gold Refinery Fell After Sanctions. The latest available data shows that Thaba exported about $51 million in July, the lowest since January 2024, accounting for roughly 7% of Uganda’s gold export value. The seeming resilience of the network over the years shows how difficult it has been to sever conflict-linked gold from the global market — especially once it reaches the UAE, one of the world’s biggest bullion hubs. The UAE imported about $99 billion of gold from Africa in 2025, the country reported. Swissaid, a Swiss government-backed NGO that works on transparent supply chains, including in eastern Congo, has estimated that $24 billion-$35 billion in smuggled gold enters global markets from Africa every year, much of it via the UAE.
In a written response to questions, a UAE official said the nation’s regulatory framework complies — and in some cases exceeds — Organisation for Economic Co-operation and Development guidelines on responsible sourcing, and that rules extend to refiners, recyclers and trading companies.
“Gold shipments arriving from transit hubs and conflict-affected or high-risk areas are subject to enhanced risk-based screening at the point of entry, including verification of origin documentation, source-country mining concessions, and authenticated certificates of origin,” the official said.
Ugandan company records reveal how AGR and Thaba overlap. Murikkoli, an Indian national who owns 80% of Thaba and serves as a director, had a work permit dated August 2020-August 2023 sponsored by AGR. A law firm headed by Sharon Tem, who was AGR’s company secretary until 2024 — after the refinery had been sanctioned — also serves as Thaba’s company secretary and registered Thaba with the Ugandan authorities in 2012.
Murikkoli said he was approached by an AGR director to become the firm’s chief operating officer and his permit was processed but he ultimately didn’t work there and “made the decision to pursue my own venture.”
“I firmly deny that I am, or have ever been, acting as a proxy for Goetz,” he told Bloomberg.
Tem said in an emailed response that she has had no business relationship with Goetz since 2022, that her services to Thaba are limited to statutory governance functions, and that she remained company secretary for AGR after sanctions only to oversee its liquidation. Goetz said his last interaction with Tem was in 2021, “when she issued the letter confirming the severance of my relationship with AGR.”
Murikkoli said he has had “no business relationship with Goetz, whether before or after the 2022 sanctions,” and that Goetz played no role in his acquisition of Thaba shares. He said that Thaba verifies all gold suppliers hold the required registrations, permits and mineral dealer’s licenses to prevent sourcing from conflict-affected or other high-risk areas, including Congo, Sudan, South Sudan and Rwanda. Goetz said he had no relationship with Murikkoli.
Thaba was incorporated as a business in 2012 for activities including import-export, garbage collection and arranging safaris. It amended its purpose in April 2021 to include precious metals processing, less than a year before the US imposed sanctions.
That same month, Tem acted as witness for the transfer of Thaba’s shares from its Ugandan founders to Murikkoli and two others. By May, the company’s offices were registered as Plots M103 and M106 on Sebugwawo Road in Entebbe — the same address as AGR. “The address referenced is a large shared compound near the airport,” Goetz said.
In a 2025 ruling, US District Court Judge James Boasberg wrote that Goetz “apparently caught wind that he would be sanctioned before it became public.”
Goetz denied the claim. Trade data show six AGR suppliers later sold to Thaba — and to no other Ugandan refinery. Together, they were involved in shipments representing about 40% of Thaba’s gold import value, amounting to $3 billion.
“Research suggests that his trading network has remained involved in the region’s gold trade, despite EU and US sanctions,” said Sophia Pickles, a former United Nations investigator who probed Goetz. “Many of the same gold-buying networks linked to the decades-old Goetz network appear to be alive and well.”
Thaba also uses Ferrari Group, a London-headquartered logistics provider that AGR used before sanctions, which also counts global luxury brands, watchmakers and jewelry brands as clients. Ferrari — a Netherlands-listed company whose shareholders include BlackRock Inc. — first appeared in Ugandan gold records in 2020 carrying exports for refineries including AGR. It now carries almost all of Thaba’s exports, the data show.
A representative for Ferrari Group said in an email that its activities are limited to the shipping of goods, that it does not trade gold or any other commodity, that it does not see “relevant documents produced in the country of origin” and does not provide services to entities or individuals subject to international sanctions.
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Thaba is one of only seven firms with a government-issued mineral refining license in Uganda and last year participated in a tender to supply gold to the country’s central bank.
Uganda’s own data show how sharply the gold trade has surged in recent years. Gold exports rose 112% in the year through June 2026 to $8.9 billion, or 70 metric tons, from 49 tons worth $4.2 billion a year earlier, according to the Bank of Uganda.
The dramatic surge has raised questions about origin. Uganda’s Ministry of Energy and Mineral Development reported last year that the country formally produced almost no gold in the 15 months from January 2024.
A UN group of experts report said in July last year that gold smuggled from Congo’s war-torn northeastern Ituri province “significantly inflated Uganda’s gold refining and export figures,” leaving much of the gold ineligible for trade under UN due-diligence guidelines.
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“Uganda’s gold refining sector is predominantly supplied by gold originating from eastern DRC,” the experts said in their annual report on Congo’s conflicts published in June that analyzed discrepancies in Uganda’s trade data.
Congo’s mines minister told Bloomberg last year that his country loses 60 tons of gold a year to smuggling. And at a banking conference in Kampala in February, Ugandan Deputy Central Bank Governor Augustus Nuwagaba said much of the country’s gold appeared to be coming from outside the country. “It means, actually, that gold is most probably not ours,” he said, according to CEO East Africa.
The UAE is one of the most important physical bullion hubs, along with London and Switzerland. The Gulf state has tightened oversight in recent years, adopting responsible-sourcing standards, increasing anti-money-laundering controls and securing removal from the Financial Action Task Force’s grey list in 2024. But critics say enforcement remains uneven, especially for trading companies that import most of the gold.
The UAE official didn’t address questions about Goetz, Thaba or the number of gold dealers, traders, refineries and logistics companies that have been suspended, fined or closed down for breaking rules on responsible sourcing.
The official added that authorities in the UAE have “ongoing inspections of regulated entities, and any identified gaps in compliance result in enforcement action, including suspensions and fines.” The Dubai Multi Commodities Centre didn’t respond to a request for comment.
The reforms in the UAE have not slowed the flow from Africa. Gold imports from the continent rose 76% in 2025 to about $99 billion, according to government data analyzed by Bloomberg. Imports from Uganda rose roughly 80% to $4.3 billion.
At the same time, the UAE reported exporting $47 billion gold to its top destination Switzerland, nearly four times the year prior.
Across Africa, gold often leaves conflict zones in backpacks, suitcases, motorbikes or carry-on luggage, then receives paperwork in more stable transit states. Once refined, its origin becomes far harder to establish.
M23 rebels guard a unit of surrendering Congolese police officers in Bukavu, Democratic Republic of Congo, in February 2025. Gold smuggling from eastern Congo to Rwanda has also spiked amid the occupation by Rwanda-backed M23 rebels, according to UN experts.
M23 rebels guard a unit of surrendering Congolese police officers in Bukavu, Democratic Republic of Congo, in February 2025. Gold smuggling from eastern Congo to Rwanda has also spiked amid the occupation by Rwanda-backed M23 rebels, according to UN experts. Photographer: Hugh Kinsella Cunningham/Getty Images
“The Emirati government is unable to prevent conflict gold from entering the UAE,” said Yvan Schulz, a researcher at Swissaid who studies mineral supply chains, citing trade data showing gold reaching Dubai from eastern Congo through Uganda and Rwanda, and from Sudan through Libya or Chad. Trading companies, which account for the bulk of imports, are not regulated as strictly as refiners, he said. Registered dealers of precious metals and stones in the country soared to 8,000 in 2025 from 4,500 in 2022, according to government data. “This is a major loophole.”
Sudan shows how the system works. As civil war devastated the country, roughly $5 billion of gold was smuggled each year to neighbors including Chad, South Sudan and Egypt, said Mohamed Tahir Omer, head of the state-run Sudanese Mineral Resources Company. Egypt exported $5.9 billion of gold to the UAE in 2025, or about 62 tons, according to UN Comtrade, even though it produced only a quarter of that amount in recent years. The North African nation’s single operational commercial gold mine doesn’t ship its output to the UAE. On the recipient side, the UAE reported $8.9 billion of gold imported from Egypt last year.
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How Smuggled Gold Reaches International Markets. Concerns about smuggling have drawn attention from the London Bullion Market Association, which has said it will work with other bullion centers including the UAE, India, Turkey and South Africa as part of a push to enforce responsible-sourcing standards.
“High prices attract all investors, including the nefarious ones,” Ruth Crowell, chief executive of the LBMA, told a conference in April. “We are at an extremely high point of risk for illicit gold movement, for gold laundering.”
The UAE also faces another FATF review decision later this year, and a poor assessment could return it to the agency’s grey list. But the country’s wealth and growing clout as a geopolitical dealmaker and financial hub make tougher action difficult, said Brad Brooks-Rubin, a former senior US State Department sanctions adviser.
“It wouldn’t be complicated in and of itself to have stronger gold sanctions around companies in the UAE,” he said. “The question is what are administrations willing to do to lean in and push the UAE.”
Much of the gold refined in the UAE, both responsibly sourced and illicit, is exported to Switzerland, China and India. Some of it also reaches the vaults of the world’s largest banks in London and New York, after being cast by one of the few LBMA-approved refiners who accept material from the country, after carrying out compliance checks.
The LBMA itself can’t enforce rules beyond the refiners it certifies, but is working with the UAE as part of a push to align standards across the gold market. But getting the country’s refiners onto its “Good Delivery List,” which allows gold to enter the global financial system directly, remains difficult, in part because the major banks that provide vaulting in London are wary of compliance risks, according to people familiar with the matter.
Despite the efforts, gold from conflict zones keeps going to Dubai, the data show, particularly as gold prices have soared. A store in the Dubai Gold Souk. The UAE imported about $99 billion of gold from Africa in 2025
In Kenya, authorities are trying to reform the gold sector, but there are still large gaps, said Munir Sheikh Ahmed, the chief executive officer of the Gold Souk, which opened last year.
“The re-export market was always here and it wasn’t coming properly into the country to be honest,” he said. “It would come from eastern DRC mainly, South Sudan and a little bit Ethiopia,” he said, referring to countries long embroiled in conflicts. An Ethiopian government spokesperson didn’t respond to a request for comment.
Uganda imported $1.3 billion of gold from Kenya in the year through June, surging tenfold from a year earlier and representing almost 20% of gold import value, according to customs records compiled by Big Trade Data.
Gold smuggling from eastern Congo to Rwanda has also spiked amid the occupation by Rwanda-backed M23 rebels, according to UN experts. In 2024, at least 11 tons of gold from Rwanda was exported to a UAE company called PGR Gold Trading LLC that was also sanctioned by the US in 2022, and previously owned by Goetz until at least 2020, according to an analysis of trade data by Bloomberg and Pickles, the former UN investigator.
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While Rwanda doesn’t publish gold production data, the country’s exports were on track to quadruple from 3 years ago to over $2 billion in 2025, according to the International Monetary Fund — about half the value of the country’s total exports — until the EU last March sanctioned its only refinery, for processing smuggled gold from rebel-controlled mines in Congo. The US added its own sanctions against the refiner in June. Despite the sanctions, Rwanda is still expected to ship more than $600 million worth of gold this year, according to IMF data.
Rwandan authorities expropriated the refinery, now known as Gasabo, from Goetz in 2021 over alleged tax evasion. He’s suing the government for $50 million over what he says was a hostile takeover.
The UAE’s gold imports from Chad, Ethiopia, Burkina Faso and Mali also rose, while imports from Sudan and Rwanda declined 45% and 64% to $1.1 billion and $538 million respectively. The UAE Reported African Gold Imports Rising By $43 Billion
Goetz, 61, has been involved in Central Africa’s gold trade for decades. He moved to Burundi in 1987 and began exporting gold from around the region, including from Congo, which was then known as Zaire, he told a Belgian parliamentary inquiry in 2002.
In 1997, after Zaire’s dictator Mobutu Sese Seko was overthrown, Goetz moved to Goma, on the country’s border with Rwanda, to trade gold, he told the Belgian Senate committee.
He eventually returned to Belgium to work with his family’s business, Tony Goetz NV, which processed billions of dollars of gold out of Antwerp. In 2020, Goetz and his brother were convicted of fraud and laundering money through the firm, and given 18-month suspended prison sentences. “The court judgment referenced relates to matters from 2009/2010 — over 15 years ago. The verdict was accepted and the associated fines were paid,” Goetz told Bloomberg.
Perhaps his biggest break came in 2017, when he inaugurated AGR, flanked by Ugandan President Yoweri Museveni, who has led the country since 1986. In less than a year, the refinery exported roughly $377 million of gold to one of Goetz’s family-owned companies in Dubai, according to Washington-based corporate watchdog The Sentry. AGR became a pillar of Uganda’s economy, and the subject of boasts in Museveni’s speeches.
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But six years later, Goetz’s empire began to unravel, and he’s spent the time since trying to remove himself from sanctions lists. He lost a 2024 challenge to EU sanctions, which said he continued to “exploit the armed conflict, instability and insecurity in the DRC through the illicit exploitation and trade of natural resources.”
He also sued OFAC in Washington from his home in Dubai after the US government twice denied his petitions for removal. The court ruled against him last year. He told Bloomberg he will continue to challenge the sanctions, which he believes are unjust.
On Aug. 12,2026 Goetz posted a statement to US President Donald Trump’s Truth Social website “as part of my effort to address the issues that led to the sanctions imposed against me.”
In it, he acknowledges shortcomings of the due diligence process followed by the African gold industry in the early 1990s, adding that his goal was to build legitimate businesses.
In 2014-15, when he founded AGR, the firm “made genuine efforts to maintain a responsible supply chain,” he said. “As founding CEO, I acknowledge that some of the systems at AGR should have been further strengthened. For those shortcomings, I offer my sincere and unreserved apology to all those who were affected.”
He also says he has “no interest in returning to any business connected to gold, minerals, or precious metals.”
“Should I pursue any other business activity in the future, I remain fully committed to conducting such activities in a manner consistent with international standards of ethics, compliance, and responsible corporate citizenship,” he said.
Today, state investigators in Belgium have opened inquiries into Goetz’s possible complicity in war crimes committed in eastern Congo, according to documents submitted by the US government in the case defending its sanctions. Goetz told Bloomberg he couldn’t comment on “these assertions.”
“I withdrew from all gold-related business activities including trading, refining, logistics, financing, or advisory work,” prior to the sanctions, Goetz told Bloomberg. “I have had no involvement, directly or indirect, in any such activities since that withdrawal, whether in the UAE, Uganda, Rwanda, Hong Kong, or any other jurisdiction, and this remains the case as of the date of this response.”
During his time in Uganda, Goetz was a fixture of high society, one of the rich and powerful, spending time at a luxury lodge nestled on the shores of Lake Victoria. He also started a charity that supports children and wildlife in Uganda. The foundation’s website says famed conservationist Jane Goodall gave Goetz an award for feeding 72 chimpanzees during the Covid-19 pandemic.
But in March 2025, Judge Boasberg said OFAC was justified in distrusting Goetz’s claims that he’d left his old ways behind him because of his history of “obfuscation” about his role in Africa’s gold trade. “Having muddied the water for many years,” Boasberg wrote, Goetz could not fault OFAC “for declining to say it runs clear.”
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The court record also included a 2017 diplomatic cable in which Goetz told a senior US embassy official in Kampala that an estimated 156 tons of gold had been smuggled in business-class carry-on luggage to the Middle East “in recent years.” Goetz — who told Bloomberg he couldn’t recall the conversation — also said he could not trace the origins of the gold AGR exported.
“I’m not a miner, so I don’t have much information on the source of gold,” Goetz told the official, according to the cable. “Can you tell me the source of a dollar on the streets of Uganda? It’s the same with gold, it can come from anywhere.”
