Amulsar: Offshore Companies, a $150 Million State Guarantee, and Environmental Risks

The operation of the Amulsar gold mine has already begun, but questions regarding the terms of investment, the financial obligations assumed by the state, and environmental safety remain without full answers. An investigation by Hetq reveals aspects of the mine’s ownership structure and financing that the government is obliged to present to the public in detail.

Prime Minister Nikol Pashinyan attended the opening ceremony of the Amulsar mine on October 10. The government presents the project as an economic achievement, expecting investments worth hundreds of millions of dollars, tax revenues, and new jobs. However, it is still unclear how well-founded these expectations are, what risks the state has assumed, and who will be held responsible for potential damage.

In the “8th Floor” podcast published on October 20 by Hetq, editor-in-chief Edik Baghdasaryan and economic journalist Seda Hergnyan discussed Amulsar’s ownership structure, financing, and environmental hazards. The information they presented shows that many questions remain regarding the project’s financial terms.

A $150 Million Guarantee at the State’s Expense

The initial version of the Amulsar project’s financing plan envisaged attracting around $250 million. According to the project announced in 2023, $100 million was to be provided by the Eurasian Development Bank, while the remaining funds were to be raised from other sources.

However, that plan was not implemented as intended. In November 2024, the Eurasian Development Bank told CivilNet that Lydian Armenia had withdrawn its loan application. Following this, on February 27, 2025, the Armenian government adopted a decision to provide a state guarantee for a loan of up to $150 million.

The initial decision named five Armenian banks, but Ameriabank was subsequently brought in instead of them. According to CivilNet, the $150 million loan was provided by that bank.

This change raises an important question: why was the original financing plan not implemented, why did the previously named banks withdraw, and under what terms was the loan secured by a state guarantee provided?

The Hetq journalists note that the full loan terms—the interest rates, repayment schedule, and extent of the state’s potential obligations—have not been adequately presented to the public. Without this information, it is impossible to assess how beneficial the deal is for Armenia and what financial consequences could arise if the mine fails to generate the expected revenues.

The State’s 12.5% Stake Does Not Yet Guarantee Revenue

In December 2024, Lydian Armenia transferred 12.5% of the company’s shares to the Armenian government. The remaining 87.5% has belonged to United since 2025.

The government presents its participation in the company as an opportunity to benefit from the mine’s revenues and exercise control over the company’s operations. However, owning a stake does not mean that the state will regularly receive dividends.

For dividends to be paid, the company must make a profit and decide to distribute it. If the profits are reinvested or the company does not declare profits available for distribution, the state may receive no direct income from its stake for a long time.

The Hetq journalists also raise questions about the terms under which the stake was transferred to Armenia, what rights the state has in management matters, and what mechanisms will be used to protect its interests.

This is particularly important because the state is simultaneously a shareholder in the project and the provider of a loan guarantee.

The Ownership Trail Leads to Offshore Zones

According to Hetq’s publication, the chain of companies associated with Amulsar’s other owner extends to the Seychelles and the British Virgin Islands, as well as the United Arab Emirates.

According to Edik Baghdasaryan, a structure consisting of five companies was formed in April 2025, within which various companies were registered in these jurisdictions. The journalist notes that the full picture of the connections between them and the division of their financial roles remains unclear.

The podcast also discusses the activities of businessman Justin Dibb. Baghdasaryan recalls that Dibb’s name appeared in materials from the international investigative journalism project Paradise Papers, in the context of a network of offshore companies. He also addresses reports of problems and legal disputes that arose in African countries in connection with Dibb’s activities.

The existence of offshore companies is not, in itself, proof of illegality. However, when it concerns a mine financed through a state-guaranteed loan and operating with state shareholding, transparency in the ownership structure becomes a matter of public oversight. It must be clear who the ultimate beneficiary is, where the investments are being raised, what obligations the companies have, and what guarantees have been provided to lenders.

Environmental Risks Do Not Disappear with the Mine’s Opening Ceremony

Environmental disputes surrounding Amulsar began back in 2018, when activists and local residents blocked the roads leading to the mine, halting construction.

In 2019, the companies ELARD and TRC examined the project’s environmental impact at the government’s request. More than $450,000 in public funds was allocated for that study. The expert materials identified omissions and inaccuracies in the environmental impact assessment documents, including problems related to water resource modelling, acid drainage calculations, and biodiversity assessment.

On October 12, 2026, a number of non-governmental organizations and citizens issued a statement demanding that the operation of the Amulsar mine be halted and that the decisions underlying its permits be reviewed. They also cited Armenia’s obligations under the Bern Convention and the need for a new environmental assessment.

Water resources are at the center of environmentalists’ concerns. The potential consequences of the mine’s operation concern the Arpa and Vorotan river basins, groundwater, Jermuk’s mineral springs, and the water system of Lake Sevan. The existence and extent of the risks must be assessed through professional studies and independent oversight, rather than solely through assurances from the operating company.

Government representative Gnel Sanosyan, for his part, has stated that the company and state bodies are monitoring environmental indicators. However, what matters to the public is not only what measurements are being taken, but also who verifies the results, what data are published, and what measures will be taken if deviations from established standards are detected.

$130 Million in Revenue—At What Cost?

In connection with the launch of the mine’s operations, government representatives announced that, at current gold prices, Amulsar could generate $120–130 million annually in taxes and royalties. According to Gnel Sanosyan’s estimate, around 1,200–1,300 people could work at the mine, while thousands of additional jobs could be created in the supply and services sectors.

These are forecasts, not revenues that have already been received. To assess whether they are realistic, it is necessary to know what production volumes are planned, what expenses are expected, what debts must be repaid, and how much revenue will remain for the state budget.

The Hetq journalists also point to the danger of Armenia’s economy becoming dependent on mining. Mineral exports may produce short-term economic results, but they do not replace the development of the processing industry and the creation of high-value-added production.

The economy of Vayots Dzor is a separate concern. Jermuk and the surrounding areas are developing tourism, guesthouses, vineyards, and small farms. The mine’s long-term impact on these sectors must also be taken into account. If revenues generated by mining are accompanied by losses in tourism or agriculture, the project’s overall economic outcome may differ significantly from the figures presented by the government.