Monrovia – The recent exchange of letters between Liberia (AML) and the Liberian government, represented by the National Investment Commission (NIC) and the Ministry of Mining and Energy (MME), has led to problematic developments in the management of Liberia’s mining concessions and legal commitments.
At the heart of the issue is the Environmental and Social Impact Assessment (ESIA), a process aimed at assessing the potential environmental and social outcomes of proposed projects requested by the Department of Mines and Energy at Ivan Ho Atlantic (formerly HPX) that will be carried out within AML’s legally established concession areas.
This ESIA request, made in a letter dated March 18, 2025 and signed by Minister Wilmott M. Pe, called on AML to “permit the Ivan Ho Atlantic… to do the ESIA within the designated area as shown in the attached map”, and to do the ESIA designated from March 17-21, 2025.” Arrived after the start of the proposed ESIA schedule and is procedurally defective.
In its formal response dated March 21, 2025, ArcelorMittal Liberia raised four important objections rooted in both procedural irregularities and violations of the Mineral Development Agreement (MDA) with the Liberian government.
The first point of concern for AML was the arrival of ESIA requests after the activity was scheduled to begin. In AML’s own words, “The ESIA request made it impossible for AML to consider and respond to this important request in a timely manner on March 18, 2025, after the start of the period proposed by the Atlantic Ivan Ho to implement the ESIA.”
This indicates a clear lapse of the administrative due process. Requiring access to important post-themed mining concessions undermines operational planning as well as mutual respect between the concessionaire and regulatory authorities.
AML’s most powerful and legally grounded objections include: “There appears to be no basis under the MDA to allow such third-party access to our concession area.”
The company correctly points out that while MDA includes provisions relating to multi-user access, such provisions are “limited to certain circumstances including excessive capacity usage or infrastructure expansion, and neither of them applies to the ESIA by unrelated parties.”
In other words, AML concession areas are not open areas. This is a legal protection zone established under a binding mineral development agreement ratified by the Liberian Parliament, giving exclusive rights to locations operated by AML, including mining corridors. And the company believes it is legally unacceptable to allow Guinea mining companies to carry out any form of assessment within this zone, particularly under the guise of promoting government.
AML will further issue an alarm in the context of ESIA and link to “suggested concessions and access agreements during negotiations between the government and Ivanhoe Liberia Ltd.” Timing is troublesome and doesn’t seem like a coincidence.
This operation is disguised as a routine ESIA request and is thought to be interpreted as a thinly veiled attempt to lay the basis for access to rival concessions without first resolving or respecting existing contractual obligations to AML.
Even more worrying, AML states, “The timing and nature of the ESIA request raises concern given the continued negotiations regarding the third amendment of the MDA.”
AML correctly outlines the practical and strategic dangers of such a move. With expansion work underway and an increase in its investment portfolio, AML highlights its obligation to protect HR, equipment and infrastructure. Granting unauthorized third-party access eliminates the security protocols needed to maintain high-value industrial sites, putting decades of foreign direct investment that Liberia can afford to lose.
ArcelorMittal Liberia concludes its response with a call for clarity and constructive dialogue.
ESIA is an important tool in environmental governance, but when exploited, it becomes a dangerous tool for erosion. In this example, the Ministry of Mines and Mines’ March 18 request to allow Ivanhoe Atlantic to implement ESIAs within AML’s sensitive concession area is procedurally flawed, legally unfounded and strategically plagued, potentially undermining investors’ confidence in the Liberian extraction sector and setting the possibility of raising serious questions about a secondary issue of concession agreement.
As of April 2025, the Guinea government has not granted final approval of Société de Fer de Guinée (SMFG), a subsidiary of High Power Exploration (HPX), to export iron ore from the Nimbas Project through Liberia. The 2019 Memorandum (MOU) between the Guinea regime and the Liberian government allowed the use of Liberian Buchanan port for certain mining projects, including Nimbas, but the agreement has not been reaffirmed under current Guinea leadership, which is assuming power following the 2021 coup.
The management of interim president Mamadi Dungbouya has since prioritized resource sovereignty and domestic transformation of natural resources, linking the resource-rich Simandu mountains to the new port of Moribaya, Forekaria, towards the construction of national infrastructure such as the $15 billion Trans-Ginian Railway.
This strategic redirect has been repeatedly emphasized by top government officials.
“This mining project must be for the Gulf for Guinea,” Minister Ismael Nabe in a 2025 interview, referring to the Symandu initiative, highlighting his desire to transform mineral wealth into long-term national prosperity. – Guardian
Similarly, President Dumbya declared in 2022.
“It is becoming inevitable that ore conversion is inevitable on-site. It is necessary and must be done without delay.” – West Africa Report
And in further claims of control, government spokesman Ousmane Gaoual Diallo said Guinea will begin to exercise its right to ship up to 50% of its mined exports.
“This implementation will be carried out according to international best practices.” -Mining.com
These statements collectively illustrate the administration’s broader policy goals by avoiding dependence on foreign infrastructure and minimizing the runoff of raw raw minerals.
Liberalut: Suddenly, are you dead?
Against this background, HPX and its subsidiaries – Guinea in Liberia and SMFG in Ivan Ho, Atlantic, appear to be preparing to export Guinea iron ore through Liberia, despite the lack of updated bilateral clearance.
The Liberian government officially wrote to the Guinea authorities through the National Investment Commission (NIC) to clarify whether Guinea will allow the export of minerals through Liberia. However, there is no reply from Conakry.
There was no official reversal of the MOU for 2019, but the Guinea Mines Ministry has also not issued a new official statement reaffirming it. The last formal declaration on the issue dates back to 2019.
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“The mining project in question is near the border with Liberia and cannot make a profit if you export the coast of Guinea.” -S&P Global, Mining.com, FrontPageAffrica
That position appears to contradict the current administration’s harsh stance on maximizing domestic economic capture through the country’s routes and infrastructure. The lack of modern communication from Guinea’s Mines Ministry further promotes uncertainty over the planned operation of HPX.
Liberia is seeking adjustment amid rising pressure
Despite the ambiguous attitude from Guinea, Liberia moved cautiously. Just two weeks ago, Liberia’s Ministry of Mines and Energy reportedly approved the first step related to HPX’s planned operations, but no specific details of that approval have been made public.
Nevertheless, Liberian authorities have stressed the need for bilateral coordination and have reiterated that the use of Liberian railway and port infrastructure by Guinea mining companies must be based on appropriate agreements and explicit consent from Conakry. – Liberia News Network, allafrica.com
Without the latest cross-border contracts and a mining license granted to SMFG by a valid Mineral Development Agreement (MDA) or Guinea, industry observers note that HPX’s proposals currently lack the necessary legitimacy and face both regulatory and political cores.
HPX continues to prepare, but the prospect of exporting iron ore from Guinea’s Nimba Mountains through Liberia is surrounded by uncertainty. Without the green light from Guinea’s current regime, and without a focus on independence and resource nationalism, the cross-border route may ultimately prove incompatible with Conakry’s evolving vision for its mineral sector.
Until the Guinea government publicly revises its position or issues new approvals, Liberian corridors remain technically alive but politically dormant.
