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Ten years of UK memoranda on Mongolian mines end in a working group and an unfunded list

Mongolia’s mining sector was put before London on 21 October at a Mongolian-British Chamber of Commerce conference during LME Week. The state’s list of mines seeking investment holds 67 projects asking for ₮3.5 trillion, about $970 million, two thirds of it one Australian-owned coal deposit. Britain’s record since the first mining memorandum of 2016 is a working group, a metro memorandum and a listing programme without an issuer.

A wooden geological core box with most cells empty, one dark coal core, one short quartz fragment and an amber tag lying on an empty cell.

The chamber’s own page frames the week of 18 to 23 October as London Metal Exchange Week and lists the UK-Mongolia Mining Investment Conference on 21 October under one of seven themes, from capital markets and international listings to corporate governance and state-owned enterprise reform. By the morning of 22 October no agenda, venue, speaker list or outcome had appeared on that page or on the Mongolian embassy’s site in London.

Britain and Mongolia signed their first mining memorandum in November 2016, on the sidelines of a London mining conference, with Erdenes Mongol’s chief executive Tumentsogt Tsevegmid saying it covered financing as well as technology and training. A critical-minerals memorandum followed during David Cameron’s visit of April 2024, a critical-minerals roadmap in June 2025, according to AKIpress, and on 25 February 2026 industry ministers Chris McDonald and Damdinnyam Gongor agreed in London to set up a joint working group under the 2024 memorandum.

The joint press statement of 30 March, after the second annual political dialogue in Ulaanbaatar, describes that group as established and commits both sides to increase cooperation through it. By 22 October gov.uk, the Mongolian industry ministry’s site and the Mongolian embassy’s news pages carried no readout of a meeting, no work plan and no participant list. The same statement repeats a line from the February 2025 dialogue: Britain is ready to continue discussions on UK Export Finance (UKEF) support for Ulaanbaatar’s first metro.

That metro line is the one place where British state financing has a signature on paper. The Office of the Governor of Ulaanbaatar and UKEF signed a memorandum of cooperation on 9 July 2025, with the agency’s usual condition of at least 20% British content, according to the Mongolian embassy in London. UKEF’s Impact Report for 2025 to 2026 names no Mongolian transaction, and the Department for Business and Trade’s factsheet of 24 September puts total UK-Mongolia trade at £180 million in the four quarters to March 2026, with Mongolia ranked 136th among Britain’s trading partners and the stock of British direct investment in Mongolia at minus £1 million at the end of 2024.

That last figure records where the investing entity is registered. Rio Tinto, headquartered in London, holds 66% of Oyu Tolgoi through subsidiaries registered outside Britain, so the country’s largest foreign investment sits outside the British statistics. The money Ulaanbaatar argues about is that mine’s dividend: on 20 October the finance minister defended before the budget committee a plan to spend ₮2 trillion of it on power plants, as CAW reported.

Britain’s presence in Mongolian mining comes in two forms, owner and broker. Among London-listed companies Rio Tinto is the owner, the one with a Mongolian mine in production and its risk on its own books. The other London-listed name with Mongolian licences that Capital Markets Mongolia, the organiser of September’s Mongolia Investment Forum in London, cites in its newsletter, Petro Matad on AIM, is an oil producer with one field that reported $2.14 million of cash and received no oil sales revenue in the first half of 2026.

Everything else Britain has put on paper for Mongolia’s mining sector in 2026 is brokerage: London sells access, services and a venue, and the capital comes from elsewhere.

The clearest example of brokerage is the webinar the Department for Business and Trade’s Business Academy ran on 20 August, “Discover opportunities in Mongolia: spotlight on mining and critical minerals”. Its page promised to “unveil 15 high-potential mining projects ready for international collaboration” to British suppliers of equipment, technology and services, with the director of Mongolia’s National Geology Survey, Munkhbileg Namsrai, and two ministry officials as speakers. The 15 are not named on the page, and no list has appeared on the embassy’s or the ministry’s sites since.

Ikh Noyon, a placer gold licence in Darkhan-Uul province, seeks ₮500 million, about $140,000, for a two-year mine with an output of 25 kilograms of gold.

The second example is a meeting. On 17 September the Mongolian Stock Exchange met Palladium Group, which it described as the implementer of the British government’s MOBILIST programme, to discuss a market-maker system, exchange-traded funds and sustainable finance. The two sides, in the exchange’s words, agreed to seek technical assistance and continue cooperation.

MOBILIST is a Foreign, Commonwealth and Development Office programme, co-funded by Norway and Switzerland, that takes anchor stakes in listed products in frontier markets, most recently $10 million in the Manila water utility Maynilad’s IPO in November 2025. Its product platform is a £8.96 million contract with Palladium International, the group’s British company, first signed in May 2020.

A tender notice of 15 September 2025 extended that contract to 31 March 2027 because a planned re-procurement “was paused following the shift of UK ODA budget to 0.3%” of national income and the programme “is now undergoing a strategic options assessment”. So the Mongolian exchange is asking for help from a programme whose sponsor, by its last public notice, was still deciding what it will be.

What the Mongolian state publishes for investors is a different list, longer and poorer than the promised 15 high-potential projects. The Mineral Resources and Petroleum Authority’s Information on Projects Seeking Investment for 2026, posted on 29 June and updated on 6 September, was compiled from the regulator’s own returns: of 1,771 mining licences held by 1,234 companies at the end of 2025, 732 companies reported no activity on 1,314 licensed areas, and 459 of them gave a lack of investment as the reason. Sixty-one of those companies sent in 67 project sheets, with figures as of 1 January 2026.

The 67 ask for 3.5 trillion tugrik between them, 13 for exploration, 48 to start mining and 6 for processing plants. By mineral the list is 25 gold projects, 8 limestone, 8 fluorspar, 5 each in coal, copper and iron, 2 in gypsum and single sheets for nine other minerals, from graphite to lithium.

Coal takes ₮2.5 trillion of the ₮3.5 trillion, and one sheet carries ₮2.4 trillion of that: Ovoot in Khuvsgul province, 230 million tonnes of reserves, a planned 5 million tonnes a year over 37 years, 560 kilometres from Erdenet. Its owner, Khurgatai Khairkhan LLC, is the wholly owned Mongolian subsidiary of ASX-listed Aspire Mining. Strip Ovoot out and the remaining 66 projects seek ₮1.1 trillion, about $306 million by CAW’s arithmetic at the Bank of Mongolia’s rate of 20 October, 3,597 tugrik to the dollar.

Most of the sheets are small. Ikh Noyon, a placer gold licence in Darkhan-Uul province, seeks ₮500 million, about $140,000, for a two-year mine with an output of 25 kilograms of gold. Bumbat in Tuv province asks for ₮100 billion against a reserve of 82 kilograms of gold and prints an internal rate of return of 10%.

Mongolyn Alt’s Tsagaan Suvarga copper project in Dundgovi is the largest non-coal line by money already spent: ₮190 billion invested, a ₮36.4 billion loan sought, 6,000 tonnes a year of cathode copper planned. The forms of investment the sheets name are joint venture, loan, equipment supply and outright sale, and each sheet ends with a contact name, a position and a mobile number.

At the Mongolia Investment Forum on 15 September, by the organiser’s recap of 30 September, around 150 people met at Mansion House, 125 of them from 84 international institutions, among them Jefferies, UBS, Morgan Stanley Investment Management and Pictet. What was launched there was a market programme, “Mongolian Capital Market 2.0”, a joint programme of the Mongolian Stock Exchange, the Central Securities Depository and LSEG, with one pillar for trading, surveillance and settlement technology and one for dual listings, which CAW reported on 18 September.

Five weeks on, the programme has no published document, budget, timeline or named first issuer. The nearest candidates are banks and funds. Golomt Bank’s chief executive told the forum the bank was preparing a dual listing, and IFR reported in July that Golomt plans a London IPO in 2027 after raising $450 million in a three-year bond at 7.95% and tapping it for $50 million.

The government signed a memorandum with Franklin Templeton on 8 July to study a National Investment Fund and dual-listing IPOs of state companies. ICFG, the precedent the forum’s programme cited, is a Mongolian-rooted consumer-finance group admitted to the London Main Market in February 2025 at about £130 million.

The sovereign dollar borrowing of 2026 bypassed London. Mongolia’s $500 million bond at 5.95% due 2032, closed on 9 March with HSBC, Morgan Stanley and Standard Chartered as lead managers, was listed in Singapore. In June and July the Development Bank of Mongolia raised $750 million in notes, by the account of its counsel Cleary Gottlieb, which names no listing venue.

At the EBRD, whose London headquarters hosted the February presentation of “Mongolia’s priority mining projects” at MiningWeek & MinePro’s London Strategic Edition on 24 February, the project page for Mongolia shows three signings or approvals in 2026, in food, consumer lending and property, and none in mining.

The Minerals Law amendments of 16 October, which CAW reported that day, carry no clause on listing abroad. The British embassy and the chamber have organised a week of events, and the Mongolian side has a catalogue whose average ticket, Ovoot excluded, is ₮17 billion, about $4.6 million.

Five documents would change the picture, and none is public on 22 October: the names of the 15 projects the Department for Business and Trade showed in August, a readout of the critical-minerals working group, the Capital Market 2.0 roadmap with a budget and dates, a MOBILIST mandate for Mongolia, and a signed paper from this week’s conference naming a company, a sum and a right.

Until one of them appears, Mongolia’s offer to London is 67 idle licences whose 61 holders asked their regulator to find them investors, and what London has put in writing for Mongolia is a venue, a working group and a memorandum on a metro.