# The ITSCI Laundromat > [!note] 📄 Non-governmental report > Published by [[Global Witness]], an independent investigative NGO. [[Global Witness]], *The ITSCI Laundromat: How a due diligence scheme appears to launder conflict minerals*, **26 April 2022**. The most consequential single investigation in the cluster since [[A Rough Trade]], because it attacked not a warlord or a company but **the verification layer everyone else was relying on**. ## What it found - At **Nzibira**, South Kivu, in Q1 2021: validated mines produced **less than 20%** of the roughly 83 tonnes of cassiterite tagged there. - At **Lubuhu**: roughly **fifteen times** as much cassiterite was tagged as the two validated local mines produced. - Similar patterns at seven further tagging centres across North and South Kivu. - In **Rwanda**: a source described as an architect of the scheme estimated **only about 10%** of the minerals Rwanda exported had actually been mined there. - **The conflict of interest:** [[ITSCI]] is run by the International Tin Association, which represents major 3T buyers. **The auditor is the trade body of the audited.** - Downstream, the material reached smelters supplying Apple, Intel, Samsung, Nokia, Motorola and Tesla. Method: fieldwork in more than ten mining areas, 90-plus interviews, and comparison of tagged tonnages against validated-mine production records. ## ITSCI's rebuttal, which deserves to be taken seriously Its June 2022 response makes arguments that are the report's genuine pressure points, not evasions: 1. The tonnage discrepancies **compare different sets of mines under different validation criteria** — tagged output legitimately includes mines validated under other regimes, so the ratios are not like-for-like. 2. Global Witness relied on 90 interviews; ITSCI has 120 permanent field staff. 3. The report's hedged language — "appears," "seemingly" — signals its own confidence level. 4. **ITSCI is a due-diligence framework, not a certification scheme.** Its function is to identify and escalate risk, not to guarantee its absence. Treating every identified incident as a system failure mistakes the system working for the system broken. That fourth point is legally accurate and rhetorically devastating in both directions: if true, then **a decade of downstream "conflict-free" claims rested on a document that never promised what buyers treated it as promising.** ## What it produced, and what it didn't The [[Responsible Minerals Initiative]] allowed ITSCI's recognition to lapse in late 2022. ITSCI paused its own reapplication in 2023; RMI paused consideration in 2024. And then nothing replaced it. The Great Lakes still needs tagging at the mine, and the only scheme operating at scale is the discredited one. **The June 2026 follow-up** — *Who buys Rwanda's smuggled coltan?* — measured the consequence. Seven Rwandan exporters accounting for about 85% of the country's coltan exports; over 2,000 tonnes of smuggled material entering supply chains; more than 1,400 tonnes in [[M23]]'s first year holding the [[Rubaya Coltan Mine]]; traders paying $4/kg to M23 and $3/kg on crossing into Rwanda. **Eight smelters, mostly in China, processed the material. All eight passed RMAP audits in 2024–25.** Apple responded by notifying suppliers that smelters must suspend 3T and gold purchases from the DRC and Rwanda entirely — which is the de facto embargo the critics of [[Dodd-Frank Section 1502]] warned about, arriving fourteen years later by corporate decision rather than statute. ## See also [[ITSCI]] · [[Global Witness]] · [[Responsible Minerals Initiative]] · [[Rubaya Coltan Mine]] · [[Rwanda]] · [[Conflict Minerals Ecosystem]]