Abstract: The estimated value of Afghanistan’s mineral and hydrocarbon deposits is more than $1 trillion, but political instability, corruption, and a robust insurgency have resulted in the Afghan Taliban and other jihadi groups penetrating nearly every aspect of the Afghanistan’s lucrative extractives industry. The Taliban exploit mining sites in at least 14 of Afghanistan’s 34 provinces and now earn as much as $200 to $300 million annually, the second-largest revenue stream after narcotics. The Taliban’s increased footprint in Afghanistan and their efforts to formalize their role in the mining sector by creating the Dabaro Comisyoon, or “Stones Commission,” have substantially enhanced their war chest. The Taliban’s involvement in Afghanistan’s mining sector will most likely continue to grow in scale and complexity for the foreseeable future. 

Afghanistan’s vast mineral deposits, a complex assortment of metals, industrial minerals, mineral fuels, precious and semi-precious gems, and hydrocarbons—including world-class deposits of iron and copper—is under threat from a horde of illegal mining syndicates, including the Afghan Taliban. The U.S. Department of Defense’s Task Force for Business and Stability Operations (TFBSO) previously estimated that Afghanistan’s known mineral deposits tops $1 trillion—$908 billion in mineral resources and more than $200 billion in hydrocarbon deposits.1 While illegal mining activities in Afghanistan have long plagued efforts to create a functioning, licit mining sector, the Taliban have now succeeded in penetrating nearly every aspect of the mining sector. Increasingly, other jihadi groups such as the Islamic State–Khorasan Province (ISIS-KP) have also entered the underground economy of illegal mining, but so far, ISIS-KP’s activities are mostly restricted to the limited areas under its control in Afghanistan’s eastern Nangarhar Province.2 The Afghanistan Anti-Corruption Network (AACN) reported in February 2017 that ISIS-KP and the Taliban earned $46 million last year from illegally extracting talc, a soft mineral used in the manufacturing of cosmetics, from Nangarhar’s Khogyani District.3 Although it was not determined how much ISIS-KP earned out of the $46 million, it demonstrated that like the Taliban, ISIS-KP is diversifying revenue streams and seeking to control territory in order to exploit its natural resources.

The Taliban have been careful not to publicize or even confirm any of their activities in the mining sector, and they often publicly deny any involvement.4 However, within the Taliban’s organizational structure, a fully functioning mining department known as the Dabaro Comisyoon (“Stones Commission”) manages the taxation of extracted minerals and ores and even issues ‘official’ Taliban sanctioned mining licenses. The Dabaro Comisyoon operates under the authority of the Taliban’s Maali Comisyoon (“Financial Commission”) and reportedly came into existence around 2009 as the Taliban began to experiment in diversifying their revenue streams.5

The United States deployed an additional 33,000 troops to Afghanistan beginning in 2009 as part of a “surge” aimed at stabilizing the Afghan government and blunting the Taliban’s momentum on the battlefield. The Taliban prepared for the surge accordingly and expanded all efforts to develop and maintain sufficient financial resources. During this time, Pakistani authorities arrested Mullah Abdul Ghani “Baradar,” the Taliban’s most senior military commander and deputy to then overall Taliban leader, Mullah Mohammad Omar, during an unprecedented security operation in February 2010.6 The leadership vacuum resulted in the rise of Mullah Akhtar Mansour, a senior member of the Taliban movement from Kandahar Province who maximized his tribal affiliation as a member of the Ishaqzai to profit from the narcotics trade.7 He would emerge as the de facto head of the Taliban movement in July 2015 following the confirmation that Mullah Omar had died of natural causes years earlier, possibly in 2013, although Mansour had largely led the Taliban movement since Abdul Ghani Berader’s arrest. Mansour, who was killed in an U.S. airstrike in May 2016, and his close confidant and business partner, Mullah Gul Agha Akhund, who also belongs to the Ishaqzai tribe and served as head of the Taliban Maali Comisyoon, expanded the Taliban’s revenue streams by exploiting the mining sector in Helmand Province among other illicit activities.8

The Maali Comisyoon oversees and manages the financial flow of many of the Taliban’s illicit revenue streams, including mining activities, kidnapping for ransom, and extorting NGOs. The shadowy leader of the Dabaro Comisyoon is reportedly a former Taliban media and propaganda figure from Ghazni Province named Ahmad Jan Ahmad.9 a Given the Taliban’s reluctance to publicize its illicit financial activities, little more is known about structure of the Dabaro Comisyoon and its purported leader.b

The Scope of Illegal Mining Activities 
In October 2016, the U.N. Analytical Support and Sanctions Monitoring Team reported that the Taliban remained directly involved in the mining sector “by controlling illegal mining sites, specifically in the south and east of the country, by extorting sums from licensed Afghan mining operations and by acting as a transport facilitator for other illegally extracted natural resources.”10 The Taliban are now involved in the illegal extraction of minerals, ores, and precious and semi-precious stones, and they reportedly own several mining and excavation businesses in southern Afghanistan.

The Taliban have been reaping significant sums from artisanal and illegal mining activities. Though a firm conclusion regarding an actual amount is impossible to ascertain, the Taliban were reported, by the Afghan government envoy to Helmand in June 2016, to earn between $50,000 and $60,000 per day ($18.5 million and $21.9 million per year) from mining and transporting marble in the province.11  In addition, they were estimated to make as much as $16 million from unlicensed ruby extraction in Kabul as early as 201412 and $6 million in 2016 from mining the gemstone lapis lazuli in Badakhshan Province.13 While those approximations pertain to only three provinces, one Afghan expert on the extractives industry assessed that out of the estimated $2 billion generated overall each year from Afghan mining operations, the Taliban currently stand to earn 10 to 15 percent, or $200 to $300 million.14 The same source contended that the Taliban’s involvement in illegal mining activities had increased significantly since 2012,15 even in areas that are under government control.16

Helmand Stones 1
Slabs of rokhaam (marble) await further processing at a warehouse in Lashkar Gah City, Helmand Province, on March 6, 2017. These stones are representative of the only two percent of Helmand’s overall marble output that can be taxed by the Afghan government and sold to local Afghan markets. The rest is exploited by the Taliban and smuggled to Pakistan. Photograph provided to the author by a source in Helmand Province.

By contrast, the Afghan government reportedly earned only $30 million from mining revenues in 2015, a paltry sum compared to the current estimated revenues of the Taliban from mining.17

The Taliban, always keen to adapt to military and political changes on the battlefield, began diversifying revenue streams in 2009 and 2010. The trend became evident in Helmand Province, especially during the lead up to the extensively planned Operation Moshtarak (“Together”), which entailed a combined force of 15,000 American, coalition, and Afghan security personnel to retake the town of Marjeh, then the key area for Taliban opium production. Up until February 2010, the Taliban had largely controlled the small agricultural hamlet of Marjeh, and between 60 and 70 percent of local farmers relied upon the illegal opium trade as their main source of income.18 Anticipating significant financial loss from losing control of Marjeh and its opium economy, the Taliban began paying closer attention to Helmand’s lucrative natural resources.

The Taliban, who had long honed the processes of taxing local farmers’ 10 percent of their harvest and 2.5 percent on their wealth, probably applied similar measures against local mining firms operating in vulnerable and rural districts. The Taliban’s budding entrance into the mining sector is not well documented. The U.N. reported in 201219 that the Taliban had earned a combined total of $400 million from a wide array of illicit enterprises, such as taxing local economies including the narcotics trade, extorting businesses and NGOs, and fundraising, but illegal mining activities went unreported until 2013. The U.N. cautiously observed in 2013 that the Taliban had begun to “specifically” target gemstone mining operations, noting that the World Bank estimated that 90 to 99 percent of Afghanistan’s gemstones were illegally smuggled out of the country.20

A second catalyst for the Taliban’s deepening involvement in illegal mining activities occurred after the United States formally ended its combat mission in Afghanistan at the end of 2014. The NATO mission in Afghanistan was renamed Resolute Support and focused on training, advising, and assisting the Afghan National Security Defense Forces (ANDSF), which, at that point, assumed responsibility for all security operations. Since the transition, the Taliban have continued to make territorial gains throughout the country. Only about 57 percent of the Afghanistan’s 407 districts were considered under Afghan government control or influence as of November 15, 2016, a six percent decrease from the 63.4 percent reported last quarter in late August 2016 and a nearly 15 percent decrease since November 2015.21 The Taliban controlled 11 of Helmand’s 14 districts by August 2016,22 hence creating a de facto shadow state and allowing the Taliban to further exploit the mining sector, the drug trade, and other illicit commodities. Local media and civil society reporting throughout 2016 identified at least 1,400 illegal mining sites located in at least 14 of Afghanistan’s 34 provincesc—710 of which are in the Kabul area alone23—that are exploited by the Taliban and other insurgents. Overall, there are some 10,000 mineral deposits reportedly located in areas outside of the government’s control.24 In June 2016, a spokesman for the Afghan Ministry of Interior acknowledged the challenges associated with illegal mining activities and claimed that the Afghan government had stopped 1,270 illegal mining operations.25 However, it was unclear when and where those illegal mining operations had been disrupted.

Dabaro Comisyoon at Work in Helmand Province 
In the volatile southern province of Helmand, which has nearly collapsed to the Taliban every year since 2014, the illegal cultivation, processing, and trafficking of narcotics has remained a critical financial resource for the Taliban. The Taliban dominate many aspects of Helmand’s thriving, multi-billion narcotics industry, which revolves around the illicit cultivation of poppy, which, in turn, is used to produce opium and refined heroin as well as the cultivation of cannabis. This is used to create hashish, a potent marijuana resin. The U.N. estimates that the Taliban earned $400 million from the narcotics industry in 2016.26 In addition to narcotics, Helmand’s mineral resources are now extensively exploited by the Taliban in areas inside and outside of government control.

While the Afghan government’s envoy to Helmand reported in June 2016 that the Taliban earn between $18.25 million and $21.9 million per year from mining and transporting marble,27 sources in Helmand reported in January 2017 that the Taliban most likely earn much more than the government is reporting. The Taliban’s taxation of marble differs depending on the color and quality of the stone. The four most common types of marble, known locally as rokhaam, are yellow, light green, dark green, and pink. Veins of yellow marble are now uncommon; light green is considered the lowest quality; dark green is the second best; and pink is considered the best quality stone.

The Taliban charge a tax for each truck used to transport the mined stones, and depending on the type of marble being transported, the tax ranges from 25,000 Pakistani rupees ($238.54) to 60,000 Pakistani rupees ($572.49) per ton. Trucks can carry between 7 and 40 tons each, depending on the type of vehicle.d The U.N. Analytical Support and Sanctions Monitoring Team reported in 2015 that between 2008 and 2014, mining operations extracted 124,000 to 155,000 tons of marble from Helmand each year.28

Sources in Helmand also estimated that around 50 trucks are used to smuggle hundreds of tons of marble from Helmand into Pakistan every day, while only two percent of Helmand’s extracted marble end up in Lashkar Gah, the provincial capital, where the marble is further processed and sold.29 Of the meager two percent of marble that remains in Afghanistan, the government is only able to tax 3,500 afghanis ($33.40) per ton.30

In addition to taxing the transport of minerals, the Taliban in Helmand now also charge mining operators for a license to excavate. From the Taliban’s perspective, this was a key achievement of the Dabaro Comisyoon, helping it to dramatically increase revenues. Some mining operators also pay the government for a license, but many only carry the license issued by the Taliban. The U.N. estimates that there are at least 35 illegal marble mining sites in Helmand, many of which are located in desolate, Taliban-controlled areas of Dishu District.31

Taliban officials from the Dabaro Comisyoon and Maali Comisyoon—who maintain a presence in Khan Neshin District as well as in nearby Baram Chah, a well-known haven for insurgents—smugglers, and traffickers collect the payments and taxes from the mining operations.32 It is even alleged that some of the excavation companies are owned by senior Taliban commanders, including various family members of Amir Khan Motaqi, a senior Taliban commander in charge of the ‘Cultural’ Commission.33 The Taliban shadow governor for Helmand, Mullah Manan, a member of the Ishaqzai tribe, and Dabaro Comisyoon official Mullah Mohammad Essa, a Noorzai Pashtun originally from Spin Boldak, Kandahar Province, reportedly run the Taliban’s illegal mining operations in Helmand.34

The contemporary manifestation of the Dabaro Comisyoon is a far cry from the Taliban’s past attempts at exploiting local mining operations, many of which were ad hoc or temporary efforts to tax the smuggling of precious stones and eventually industrial ores such as chromite. The Dabaro Comisyoon, which functions under the authority of the powerful Maali Comisyoon (the Taliban Financial Commission), is tasked with streamlining the Taliban’s financial intake from mining operations through taxation and the issuance of excavation licenses and through trafficking operations. The Dabaro Comisyoon is reportedly also tasked with managing the revenues earned from taxing mining companies and those tasked with transporting the stones throughout the country (and not only in Helmand Province). It also maintains relations with Pakistani businessmen who help facilitate the black-market sale of Afghanistan’s illegally excavated natural resources.35

Illegal Mining Close to Kabul 
Illegal and unregulated mining activities are not only pertinent to isolated rural communities long outside the government’s control. The village of Nili, located in Parwan Province—approximately 25 miles from Kabul City and 12 miles from the sprawling U.S. base at Bagram Airfield—is reportedly a hub for the illegal mining of nephrite jade, a decorative stone used in ornaments and jewelry. Taliban insurgents reportedly have controlled mining operations in Nili for most of 2016.36 The jade is trafficked through the mountains by mules until it reaches Sarobi District, Kabul Province, where it is then transferred to trucks and transported farther east to markets in Pakistan.

Sarobi itself is also illegally exploited for its precious stones, mostly rubies. Taliban insurgents have controlled a mountainous area near the village of Jegdaleke in Sarobi District since at least 2012, when reports first emerged indicating that the Taliban had coerced locals to illegally mine the mountains for rubies. One such high-quality ruby extracted there allegedly sold for $600,000 to a buyer in Dubai, UAE.37 Despite an Afghan security operation codenamed “Iron Triangle” that successfully routed insurgents from several enclaves of Sarobi in 2015, the illegal extraction and smuggling of rubies from Sarobi continued unabated in the summer of 2016.38 Most of the precious stones illegally extracted from mines in Kabul are smuggled to Peshawar, Pakistan; the rubies are typically sorted for quality and sold in the gem stalls of Peshawar’s Namak Mandi market.39 

Areas located immediately west and southwest of Kabul City paint a similar picture. In 2015, officials in Wardak Province reported that the Taliban effectively tax a lucrative mining site where limestone, an industrial mineral, is extracted.40 Similarly, the massive coal deposits in Bamyan Province, part of the rugged central highlands and ancestral home of ethnic Hazaras—an historic enemy of the Taliban—have also been exploited by the Taliban despite a large portion of the coal mines being closed in 2013. The Taliban have allegedly taxed every truck of coal extracted from the Kahmard coal site, earning approximately $3,000 per day (approximately $1.1 million per year) in 2015.41

Conclusion
Although the Taliban enjoy a diverse array of income generation, reaping hundreds of millions of dollars from the illicit drug trade, kidnapping for ransom, and extortion rackets, they have formalized its exploitation of Afghanistan’s natural resources by creating the Dabaro Comisyoon. Since its inception, and under the leadership of Akhtar Mansour and his confidant Gul Agha Akhund from 2010 to 2016, the Dabaro Comisyoon has emerged as one of the most effective, efficient, and enduring business enterprises associated with the Afghan Taliban.

The Taliban’s momentum in penetrating the mining sector has continued uninterrupted over the past several years and will most likely continue to grow in scale and complexity in the near term, especially in areas under total Taliban control. The Taliban are actively engaging in illegally mining activities in at least 14 of Afghanistan’s 34 provinces, including Kabul. Estimates that the Taliban now earn upward of $200 to $300 million annually from the illegal excavation of various metals, industrial minerals, mineral fuels, and precious and semi-precious gem stones are certainly plausible; however, firm conclusions remain difficult to prove.

The licit prospects of Afghanistan’s vast natural resources are fleeting, a sentiment that is slowly seeping from civil society organizations, extractives experts, and Afghan government officials alike. A former senior Afghan official with detailed knowledge of the extractives industry recently told the author, “Afghanistan is a very mineral-rich country, but mining by itself can never result in sustainable development unless there are strong political, legal, and financial frameworks in place to manage this potential—something that needs patience and perseverance in pursuing the right policy. Unfortunately, neither Afghan politicians nor the international donor community seems to have this patience. The mining sector [in Afghanistan], at this point, is bleak.”42

Despite international involvement to stabilize Afghanistan over the past 15 years, the Afghan government remains vulnerable and continues to suffer from inadequate security, a lack of modern infrastructure, corruption, and belligerent neighbors that undermine Afghanistan’s economic potential and directly threatens its physical security. Afghanistan’s projected mineral wealth is unlikely to be realized over the next generation, although small-scale artisanal and illegal mining activities will most likely continue to expand in size and scope. The Taliban will inevitably remain at the forefront of Afghanistan’s many illegal mining activities, especially in Helmand Province, which has galvanized into the center of gravity for the Taliban’s illicit revenue streams.     CTC

Matthew C. DuPée is a senior analyst for the U.S. Defense Department. He previously served as a research associate at the Naval Postgraduate School’s Remote Sensing Center and for the Program for Culture & Conflict Studies. His research focuses on organized crime, insurgency, illegal mineral extraction, and the narcotics industry in Southwest Asia. He holds a master’s degree in Regional Security Studies (South Asia) from the Naval Postgraduate School.

The views and opinions expressed in this article are those of the author and do not necessarily reflect the official policy or position of any agency of the U.S. government. 

Substantive Notes
[a] Ahmad Jan Ahmad shares a name similar to a former Taliban Minister of Mines, Maulavi Jan Ahmad, who held the position for a short time during the Taliban government era (1996-2001). It should be noted that these are two separate individuals.

[b] The Taliban rely upon shadow administrations, commissions, and commanders active in rural communities to manage and tax local mining operations and charge taxes for each ton of stone transported from the mining site. The finances are most likely managed by provincial-level Taliban officials, who relay portions of the coffer to the Dabaro and Maali Comisyoons.

[c] The provinces include Badakhshan, Bamyan, Ghazni, Helmand, Kabul, Khost, Kunar, Logar, Nangarhar, Paktia, Paktika, Panjshir, Parwan, and Wardak.

[d] As of January 2017, the Taliban charged the following taxes for marble extracted in Helmand—Light Green: 25,000 Pakistani rupees (PRs) ($238.54) per ton; Dark Green: 30,000 to 40,000 PRs ($286.25 – $381.66) per ton; and Pink: 50,000 to 60,000 PRs per ton ($477.08 – $572.49).

[e] The Jegdalek area of Sarobi is world-renowned for its gem stones and marble deposits. In fact, a portion of the Taj Mahal—the world famous ivory-white marble mausoleum in India—was built using marble extracted from Jegdalek.

Citations
[1] The $1 trillion estimate is derived from Stephen G. Peters, Trude V.V. King, Thomas J. Mack, and Michael P. Chornack, “Summaries of Important Areas for Mineral Investment and Production Opportunities of Nonfuel Minerals in Afghanistan,” U.S. Geological Survey, September 29, 2011. For estimated financial breakdown, see “SIGAR 16-11 Audit Report: Afghanistan’s Oil, Gas, and Minerals Industries: $488 Million in U.S. Efforts Show Limited Progress Overall, and Challenges Prevent Further Investment and Growth,” Special Inspector General for Afghanistan Reconstruction (SIGAR), January 2016.

[2] Fawad Nasiri, “Terrorists Indirectly Receive Parts of Mine’s Revenue in Nangarhar: MoMP,” Ariana News, January 1, 2017.

[3] Farhad Naibkhel, “Bootie of Natural Riches; Insurgents Earns $46m From Illegal Mining to Continue War in Afghanistan: Survey,” Afghanistan Times, February 1, 2017.

[4] For instance, see Taliban spokesman Zabihullah Mujahid’s comments in “Taliban Start Digging Ghazni Mines, Claims Governor, Pajhwok Afghan News, February 10, 2016, and Farid Tanha, “Nephrite Jade’s Illegal Extraction Continues in Parwan,” Pajhwok Afghan News, July 10, 2016.

[5] Author interview, resident of Lashkar Gah, Helmand Province, who has direct knowledge of the shadow mining sector in Helmand Province, January 2017. The interviewee spoke on condition of anonymity. Supplemental information about the timing of the Commission’s reported creation was obtained from author interview, Pakistani national who maintains close contact with Afghan Taliban officials, March 2017.

[6] Mark Mazzetti and Dexter Filkins, “Secret Joint Raid Captures Taliban’s Top Commander,” New York Times, February 15, 2010.

[7] “Security Council 1988 Committee Amends 105 Entries on Its Sanctions List,” United Nations Security Council, November 29, 2011.

[8] Sami Yousafzai, “Up Close With the Taliban’s Next King,” Daily Beast, July 31, 2015.

[9] Author interview, Pakistani national who maintains close contact with Afghan Taliban officials, January 2017.

[10] “Seventh report of the Analytical Support and Sanctions Monitoring Team submitted pursuant to resolution 2255 (2015) concerning the Taliban and other associated individuals and entities constituting a threat to the peace, stability and security of Afghanistan,” UN Analytical Support and Sanctions Monitoring Team, October 5, 2016.

[11] Sune Engel Rasmussen, “Afghan Government Money Reaching Taliban Through Marble Trade,” Guardian, June 3, 2016. 

[12] “Report of the Analytical Support and Sanctions Monitoring Team on specific cases of cooperation between organized crime syndicates and individuals, groups, undertakings and entities eligible for listing under paragraph 1 of Security Council resolution 2160 (2014),” UN Analytical Support and Sanctions Monitoring Team, February 2, 2015.

[13] “War in the Treasury of the People: Afghanistan, Lapis Lazuli, and the Battle for Mineral Wealth,” Global Witness, May 30, 2016.

[14] Author interview, Afghan extractives analyst who spoke on condition of anonymity, December 2016.

[15] For previous analysis about illegal mining in Afghanistan up until 2012, see Matthew C. DuPée, “Afghanistan’s Conflict Minerals: The Crime-State-Insurgent Nexus, CTC Sentinel 5:2 (2012).

[16] Author interview, Afghan extractives analyst who spoke on condition of anonymity, December 2016.

[17] Etlaf Najafizada, “The Taliban is Capturing Afghanistan’s $1 Trillion in Mining Wealth, Bloomberg News, October 20, 2015; ibid.

[18] Rod Nordland, “U.S. Turns a Blind Eye to Opium in Afghan Town,” New York Times, March 10, 2010.

[19] Michelle Nichols, “Taliban raked in $400 million from diverse sources: U.N.,” Reuters, September 11, 2012.

[20] “Letter dated 10 November 2013 from the Chair of the Security Council Committee established pursuant to resolution 1988 (2011) addressed to the President of the Security Council,” UN Analytical Support and Sanctions Monitoring Team, November 11, 2013.

[21] “Quarterly Report to the United States Congress, Special Inspector General for Afghanistan Reconstruction (SIGAR),” January 30, 2017.

[22] Ankit Panda, “The Battle for Helmand: Afghanistan’s Largest Province May Fall Entirely to the Taliban,” Diplomat, August 11, 2016.

[23] “SIGAR 16-11 Audit Report.”

[24] Najafizada.

[25] Mohammad Halim Karimi, “Taliban’s Income from Illegal Mining to be Blocked: Official,” Pajhwok Afghan News, 8 June 8, 2016.

[26] “Letter dated 4 October 2016 from the Chair of the Security Council Committee established pursuant to resolution 1988 (2011) addressed to the President of the Security Council,” United Nations Security Council, October 5, 2016.

[27] Rasmussen.

[28] “Report of the Analytical Support and Sanctions Monitoring Team on specific cases of cooperation.”

[29] Author interview, resident of Lashkar Gah, Helmand Province, who has direct knowledge of the shadow mining sector in Helmand Province, January 2017.

[30] Ibid.

[31] “Report of the Analytical Support and Sanctions Monitoring Team on specific cases of cooperation.”

[32] Author interview, Pakistani national who maintains close contact with Afghan Taliban officials, January 2017.

[33] Ibid.

[34] Author interview, resident of Lashkar Gah, Helmand Province, who has direct knowledge of the shadow mining sector in Helmand Province, March 2017.

[35] Author interview, Pakistani national who maintains close contact with Afghan Taliban officials, January 2017.

[36] Tanha.

[37] “Afghanistan’s Fabulous Ruby Mines Plundered by Thieves,” BBC News, May 22, 2012.

[38] “Illegal Mining of Precious Stones Ongoing In 8 Provinces,” Tolo News, July 19, 2016.

[39] “Jagdalak Rubies End Up in Peshawar,” Pajhwok Afghan News Special Mines Page, accessed January 14, 2017.

[40] Zafar Bamyani and Qarib Rahman Shahab, “Taliban Profiting from ‘Closed’ Mines in Bamiyan and Wardak,” Gandhara, July 16, 2015.

[41] Ibid.

[42] Author interview, former senior Afghan Government official with intimate knowledge of the extractives industry, December 2016.

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