Critical minerals: the ownership blind spot in America’s mines

America wants secure supplies of minerals for batteries, power grids and defence manufacturing. Federal agencies have maps of mining sites and records of permits. Following the companies behind those operations to their owners is harder. Two Government Accountability Office reports, listed as publicly released on 16 October 2026, put numbers on the gap. ¹²

GAO examined 43 US-incorporated companies linked to 59 critical-mineral mining plans on Bureau of Land Management land. It resolved ownership relationships for 32 and identified at least 14 subsidiaries of foreign groups. Eleven structures remained unresolved. Chinese investors held minority stakes in two foreign parents, creating indirect financial interests in US mining operations. The operating decision rights attached to those stakes remain an open question. ¹

On 4 November 2026, the BLM announced a screening map that brings together mineral deposits, claims and infrastructure, including a layer of refineries and smelters. It helps connect geology with industrial facilities. GAO’s ownership work follows another route, through corporate structures and shareholders. Mineral security depends on connecting those routes. ¹²¹

This investigation follows both money and material. A mine in the United States can belong to a foreign group, sell concentrate overseas and finance its development through those international relationships. The rights, contracts and processing facilities determine the risks and the economic value of that arrangement. The documents reviewed here are current through 5 November 2026; the mine-plan inventory dates from February, while the ownership audit continued through October.

The name on the mining claim may be only the first company in the chain

A mining claim under the American system should not be confused with full ownership of a tract of land or all subsurface rights. For many minerals classified as locatable on eligible federal lands, a claim gives the holder exclusive rights to explore for and extract a discovered valuable mineral deposit subject to the relevant rules. The land itself can remain federally owned. The legal claimant may also be separate from the operator, the business actually carrying out the mining under a contract. ¹⁴

The distinction matters because the eligibility tests differ. In general, an entity holding a claim must be incorporated in a US state or territory. A foreign business can meet this condition by using a US-incorporated subsidiary. An operator is not subject to the same specific citizenship requirement under the legal framework GAO examined. A state registration address therefore identifies the company’s legal location, rather than every person entitled to influence its decisions. ¹

Method and limitations

632 approved hardrock plans as of February 2026, including 66 whose primary commodity was a critical mineral. The 59 plans on BLM land map to 43 distinct claimants or operators. The 632/66 bar is proportional; subsequent steps describe successive scopes. A company may appear in several plans.

As of February 2026, GAO counted 632 approved hardrock mining plans on federal lands. Only 66 listed a critical mineral as their primary product. Fifty-nine of those plans were on BLM-managed land and involved 43 distinct companies as claimants or operators. One company can appear in several plans, which means the number of plans cannot be silently substituted for the number of firms. Nor do the 66 plans cover all mining in the United States. Private land, different federal mineral regimes and critical minerals recovered as by-products of other mining operations fall outside parts of the count. ¹

The BLM’s Mineral & Land Records System, known as MLRS, holds information about claims, companies and mine operating plans. But it is not a comprehensive register of overseas shareholders or ultimate controlling interests. GAO had to build its ownership analysis from corporate websites, US state business registers, SEC filings, information held by the Defense Logistics Agency and the subscription-based S&P Capital IQ database. Eleven of the 43 corporate ownership structures remained unresolved even after that work. ¹⁵¹¹

The eleven unresolved cases are a documentary gap. Their ownership may be domestic, foreign or mixed. Even a known parent company leaves further questions about indirect shareholders, special voting rights and contracts that can shape industrial decisions.

Fourteen identified subsidiaries and eleven unresolved structures

Dividing the 14 identified foreign-parent subsidiaries by the 32 resolved cases gives 43.75%, an l0g calculation that describes this particular group. A production share, reserve share or nationwide mining share would require a different inventory and appropriate weights. The eleven unresolved cases also leave part of the reviewed population without a complete classification. ¹

Method and limitations

Each dot represents a company: 14 identified subsidiaries of foreign groups, 18 other resolved structures and 11 unresolved cases. Ownership research was conducted during the audit, completed in October 2026. The calculated ratio 14/32 = 43.75% describes resolved cases; it carries no production or reserves weighting. The other 18 cases may include minority foreign investors.

The identified parent companies were based in Canada, Australia, the United Kingdom, Poland, Curaçao and Ireland. International capital is hardly surprising in mining. Developing a project may require years of exploration, permitting, construction and financing before a saleable product is available. Geological risk and future commodity prices remain uncertain throughout the process. GAO’s interviewees emphasised that foreign investment can support local jobs, tax revenues and the construction of mines that would otherwise be difficult to finance. ¹

This is the strongest counterweight to the national-security concern. A rule discouraging every overseas shareholder could delay domestic supply and deepen reliance on imported minerals. The relevant question concerns the rights attached to ownership, particularly rights that might direct a mine’s production, its customers, its financing or the use of sensitive information. A Canadian pension fund and an overseas state-owned producer can both appear as foreign investors while creating very different risks.

The opposite error is to assume that the registered parent company’s jurisdiction is the end of the inquiry. Public companies can have dispersed investors; private companies can be nested within holding structures; investors can exercise influence through financing, board seats and supply contracts. The official company registry is a starting point for examining those arrangements.

Chinese minority stakes and the rights attached to them

GAO describes two cases while keeping the companies anonymous. A parent located in the United Kingdom was at least 11% owned by a Chinese state-owned company, according to Capital IQ data reviewed by the auditors. A Canadian parent was approximately 12% owned by a Chinese entity, and a director of the Canadian company also held a board position at the Chinese investor. These are documented financial and governance connections. Their effects on operating control require additional evidence. ¹

Method and limitations

The GAO describes a Chinese state-owned company holding at least 11% of a UK parent and a Chinese company holding about 12% of a Canadian parent. The arcs depict those stakes: a lower bound and an approximate figure, respectively. The report anonymises the groups and leaves their detailed contractual rights undisclosed.

An 11% investor might gain access to board information, approval rights or influence over major transactions. Whether that happens depends on the capital structure, voting arrangements, board nominations and contractual protections. A minority stake can have meaningful influence where the other holdings are widely dispersed. It can also provide limited leverage in a company controlled by another shareholder. No public evidence reviewed here enables a reliable quantification of the Chinese investors’ operating influence in these two cases.

The practical questions concern who appoints managers, approves borrowing, sells concentrate or can veto an asset disposal. Shareholder agreements, board powers, loan covenants and offtake commitments can each matter. GAO published limited information about these rights for its two cases.

Because the cases are anonymised, matching public shareholdings to those percentages would produce candidates rather than an established identity. We have kept both examples anonymous. The underlying shareholder agreements and restricted Capital IQ records were outside our access.

A visible ownership chain: the Robinson mine in Nevada

One independently documented example makes the corporate layers easier to see. The Robinson copper and gold mine, near Ely, Nevada, is reported by KGHM International, part of the Polish-listed KGHM Polska Miedź group. KGHM’s 2025 management report records 49,300 tonnes of payable copper production at Robinson. KGHM defines payable metal as the volume produced less losses during further processing into refined metal. The measure distinguishes recoverable metal from rock extracted and from refined-product deliveries to manufacturers. ⁸

Method and limitations

Poland’s State Treasury holds 31.79% of KGHM equity in the February 2026 snapshot. The 2025 accounts identify it as the ultimate controlling entity for accounting purposes. Arrows combine several wholly owned subsidiaries: Future 1, KGHM International, Robinson Holdings (USA), then Robinson Nevada Mining. Robinson produced 49,300 tonnes of payable copper in 2025. This independent case study remains separate from the GAO’s anonymised examples.

KGHM’s February 2026 shareholding disclosure reports that the Polish State Treasury held 31.79% of shares and voting rights. Its 2025 consolidated accounts add a decisive fact: they identify the Treasury as the group’s ultimate controlling entity. Reported accounting control and the equity percentage describe different aspects of the structure. Other shareholders own the remaining capital. ⁹¹⁴

The 2025 organisational chart links KGHM through Future 1, KGHM International, Robinson Holdings (USA) and Robinson Nevada Mining, with 100% holdings at each of these steps. A Nevada operation therefore sits within an international chain of legal entities. Mining rights, financing and sales must be examined at their respective levels. The accounts disclose the structure; tracing each shipment would require commercial records. ¹⁴

Robinson is a standalone public illustration, documented through KGHM’s disclosures. GAO also mentions an unnamed copper mine with a Polish parent. The published material leaves its identity, its correspondence with Robinson and Robinson’s membership of the reviewed sample unresolved.

American ore still travels abroad

Ownership is only one side of mineral sovereignty. The other is the physical destination of production. According to GAO’s analysis of US Census trade declarations, the country exported more than 2 billion kilograms of selected hardrock critical minerals in 2025, worth more than $11 billion. This selection excludes scrap and waste. It includes customs categories judged close to mining output, such as ores and concentrates. Neither figure represents all critical minerals, and neither can be allocated to the federal-land operations in the ownership review. ¹

Method and limitations

Country shares measure cumulative export volumes in 2019-2025. Other destinations, at 29%, are the calculated residual of five rounded shares; the GAO describes about 28%. The thresholds of 2 billion kilograms and $11 billion concern 2025 alone, excluding waste and scrap. Aggregate customs data do not identify the federal-land mine of origin.

Over 2019-2025 combined, Canada received roughly 23% of the selected export volume; China 18%; Mexico 15%; South Korea 9%; and Japan 6%. Subtracting these rounded shares leaves 29% for other destinations, while GAO describes the latter as approximately 28%. The difference reflects the limits of rounded categories. Canada received large zinc flows, Mexico a substantial volume of copper, while the mix going to China included lead, boron, titanium, rare earth elements and copper. The mineral breakdown within each destination is a different denominator from the country’s share of total American exports. ¹

The trade series measures national flows without assigning them to the 59 BLM plans. GAO also describes gaps in federal-land output records. The 1872 location regime operates without a federal production royalty, while location fees, annual maintenance fees and applicable taxes remain. The resulting administration separates mineral-rights records from the output accounts a royalty system could generate. ¹¹³

Sending concentrate overseas may be commercially efficient. The most suitable smelter may be across a border, or a customer may have financed production through a long-term offtake agreement. But concentrated refining capacity can also become a source of vulnerability when trade controls, geopolitical shocks or logistics interrupt material returning as a finished product. Determining which interpretation fits a mine requires shipment-level records, refinery capacity and contracts, not a map alone.

The chokepoint after extraction

Extracted rock must be prepared. Depending on the mineral and process, it may be concentrated before chemical separation, smelting or refining and subsequent manufacturing. Each stage needs its own equipment, expertise and environmental controls. BLM officials and industry experts interviewed by GAO identified limited domestic processing capacity as a major constraint. Adding extraction capacity leaves those downstream facilities to be financed and built. ¹

Method and limitations

USGS, Mineral Commodity Summaries 2026, figure 2. Each bar measures the share of apparent consumption covered by net imports, from 0 to 100%. Product scopes differ: gallium, natural graphite, rare-earth compounds and metals, and refined copper. The sequence depicts industrial stages; the rates use the USGS product categories and measure reliance on all suppliers.

For 2025, the USGS estimated net import reliance at 100% for gallium and natural graphite, 67% for rare-earth compounds and metals, and 57% for refined copper. These measures relate net imports to apparent consumption using the USGS methodology. Supplier concentration uses another denominator: China, including Hong Kong, supplied 71% of US imports of rare-earth compounds and metals over 2021-2024. The measures illuminate complementary risks across different periods and product scopes. ³

Consider two plausible supply chains. In the first, an American mine extracts ore, sells concentrate to a foreign processor and must rely on imported refined material for downstream production. An interruption overseas can still affect the US buyer. In the second, a US processor obtains feedstock from several countries and supplies domestic manufacturers. That chain may be comparatively robust even without fully domestic ore. Both examples are conceptual, not reconstructions of specific mine transactions.

A useful industrial strategy therefore asks at least three separate questions: where the ore originates, where it is processed and who has contractual priority over the refined output. Capital ownership can affect these decisions. So can loan agreements and sales contracts even where the mine is legally American-owned. The publicly available GAO dataset does not connect those contractual rights to each of its mine plans.

The geography is concentrated; the statistics are incomplete

The 66 federal critical-mineral mine plans are concentrated in the western United States. GAO places 21 in Nevada, 11 in Arizona and nine in California. Nevada has eight plans listing barite as their principal mineral and six listing lithium. Copper accounts for eight Arizona plans; boron for five California plans. The remaining 25 appear across other states. These are counts of approved operating plans, not tonnes of output, the value of mineral reserves or the number of producing businesses. ¹

The classification system matters when politicians promise to open a certain number of critical-mineral mines. Some strategically important materials are produced as by-products of mining another metal. Some projects are on privately owned land. Others fall under separate federal mineral rules. And the US critical-minerals list itself changes: it contained 60 minerals after the November 2025 update, including copper. Comparing an old count based on a different official list with the 2026 plan count may imply growth where there has only been a change in definition. ¹¹⁰

A stronger operational measure would track each project’s path from permitting to construction, first production and reliable deliveries to processing plants. GAO notes that major mining projects can cost billions of dollars and, according to officials it interviewed, may take as long as two decades to reach full operation. This long development cycle explains both the importance of international financing and the risks of reacting to a headline with an immediate investment ban. ¹

Investment screening draws on scattered information

The US has an investment-security institution designed to examine foreign transactions: CFIUS, an interagency committee chaired by the Treasury. It can scrutinise covered foreign investments in US businesses and certain real estate, require measures to mitigate national-security risks and, where necessary, refer a case for presidential action. Most notifications are voluntary, with mandatory filing rules in some categories. The committee also has authority to identify and examine certain unnotified transactions. Foreign-parent acquisitions that affect a US mining subsidiary may fall within its jurisdiction depending on the facts. ¹⁷

That is where GAO finds a structural mismatch. The BLM and Forest Service need not collect foreign-parent information as part of the routine hardrock mine records. CFIUS may have jurisdiction over a relevant transaction and access separate sources. Those two facts can coexist with an incomplete or outdated administrative ownership map. GAO also found that mining regulators do not necessarily record later changes of ownership at foreign parent-company level. ¹

The second October audit went back to the basic eligibility check. In a targeted, nongeneralizable sample of 15 claimants that appeared to be corporations, GAO established US incorporation for eight and left seven cases unverified. BLM also lacked the information needed to settle their status. The audit leaves those seven legal situations unresolved. Its recommendation asks BLM to collect and document claimant eligibility; it remained listed as open on 5 November 2026. ²

Another federal transparency channel has narrowed. A final FinCEN rule effective 14 August 2026 made permanent the exemption for US-created entities from the beneficial ownership reporting system it administers. The exemption had first been introduced in March 2025. Applicable securities and sectoral disclosure requirements remain in place, but this particular federal filing channel offers no general substitute for tracing US mining subsidiaries. ⁶

GAO also provides a useful comparison with agricultural land. The Agricultural Foreign Investment Disclosure Act includes foreign ownership reporting obligations, under specified conditions, that reach some domestically incorporated entities with at least 10% foreign investment. Whether a similar model makes sense for mines would require careful consideration of reporting thresholds, legal privacy protections, compliance costs, national-security usefulness and data quality. The difference between sectors illustrates a policy choice, not a ready-made solution. ¹

A more useful definition of mineral security

A better ownership declaration would answer an essential question: who holds which rights over which asset? Supply-chain analysis then needs the physical production and sales destinations alongside it. The public documents reviewed here leave those datasets partly disconnected for the federal operations examined.

Connecting the information could improve screening, reveal concentrations of influence and identify commercial dependencies. Refineries, diversified feedstock and reliable industrial deliveries would still require investment. Foreign capital can help fund them. The useful test combines decision rights, physical capacity and sales commitments.

The next useful investigative steps are specific. The 59 BLM mine-plan references could be matched to named claimants and operators in MLRS; their corporate structures could then be checked against current state registers and securities filings. Researchers should examine voting rights and offtake commitments where public documents permit. Federal agencies could be asked whether they can compile mine-output and processing-destination data in an aggregated form that protects legitimate trade secrets. None of those exercises should be described as completed merely because the relevant databases exist.

Mineral security runs all the way to the industrial customer. A permit locates an activity, a corporate chart describes power and a contract directs production. GAO’s audit exposes gaps between those three accounts. More extraction can increase supply; turning it into resilience requires knowing who decides, where the material goes and in which form it becomes available.

Further reading

Sales commitments can help finance industrial capacity. Our investigation into GM, VAC and a US magnet factory examines those contracts. The analysis of JPMorgan and industrial power follows strategic investment before projects reach full operation.

Method and limitations

The documentary review closes on 5 November 2026. GAO conducted its ownership audit from February 2025 to October 2026, using a mine-plan population inventoried in February 2026. Export data cover 2019-2025; the USGS net-import-reliance measures describe 2025. We cross-checked public audits, regulatory documents and KGHM disclosures, with company claims attributed to their issuer. Private agreements, GAO’s complete named dataset and its restricted underlying data remain outside our access. Figures distinguish observations, l0g calculations and conceptual mechanisms. Robinson is a separate illustration from the anonymised audit cases. The opening artwork is conceptual; the infographics use documented data.

Editorial licence: CC BY 4.0.

Sources and references

1. S01 · US Government Accountability Office (GAO) · 2026-10-06 · Accessed: 5 November 2026Critical Minerals: Limited Available Information on the Full Extent of Foreign Investment in Mining on Federal Lands, GAO-27-108094
   Passages and scope

   Report dated 6 October, publicly released in the GAO catalogue on 16 October 2026. Pages 5-15, figures 4-6 and methodology: 632 plans, 66 critical, 59 BLM, 43 companies, 32 resolved relationships and at least 14 foreign-parent subsidiaries. Ownership audit February 2025-October 2026; plan inventory February 2026. National exports cover selected products, excluding scrap and waste, without tracing federal-land origin.

2. S02 · US GAO · 2026-10-06 · Accessed: 5 November 2026Critical Minerals: BLM Should Ensure Individuals and Businesses Meet Citizenship Requirements for Hardrock Mining Claims, GAO-27-108196
   Passages and scope

   Targeted, nongeneralizable sample of 15 claimants. Seven US incorporation cases remain unverified, leaving legal status unresolved. The recommendation to collect and document eligibility information remained open when consulted.

3. S03 · US Geological Survey · 2026-02-06 · Accessed: 5 November 2026Mineral Commodity Summaries 2026, version 1.3
   Passages and scope

   Version 1.3 revised on 27 May 2026, first posted 6 February. Figure 2 measures 2025 net import reliance by product. Copper, gallium, natural graphite and rare-earth profiles; the rare-earth supplier window is 2021-2024 and China includes Hong Kong.

4. S04 · Bureau of Land Management · undated page, consulted 2026-11-05 · Accessed: 5 November 2026Staking a Claim
   Passages and scope

   Claimant eligibility guidance. A US-incorporated claimant can have a foreign parent. The legal claimant and actual operator perform different functions.

5. S05 · Bureau of Land Management · undated page, consulted 2026-11-05 · Accessed: 5 November 2026Mineral & Land Records System (MLRS)
   Passages and scope

   Description of the land and mineral records system. It provides legal starting points; this investigation did not conduct an exhaustive named extraction of registry records.

6. S06 · FinCEN / US Treasury · 2026-08-11 · Accessed: 5 November 2026Beneficial Ownership Information Reporting – final rule
   Passages and scope

   Final rule announced 11 August and effective 14 August 2026, making permanent the US-created-entity exemption first introduced in March 2025. Scope is this FinCEN system; other disclosure regimes may still apply.

7. S07 · US Treasury · 2026-08-07 · Accessed: 5 November 2026Treasury Releases CFIUS Annual Report for 2025
   Passages and scope

   Treasury release of 7 August 2026 on the 2025 CFIUS annual report. National-security transaction review has jurisdiction and filing rules distinct from mining records. Aggregate all-sector caseload is not used as a count of mines.

8. S08 · KGHM Polska Miedź · 2026-03 · Accessed: 5 November 2026Management Board report on activities in 2025
   Passages and scope

   Issuer publication for FY2025. KGHM International production tables report 49.3 thousand tonnes of payable copper at Robinson. No link is established to GAO’s anonymised corporate examples.

9. S09 · KGHM Polska Miedź · 2026-02 (ownership snapshot) · Accessed: 5 November 2026Share graph – ownership structure February 2026
   Passages and scope

   Ownership snapshot for February 2026: Polish State Treasury, 31.79% of shares and voting rights. This equity percentage complements the ultimate-control disclosure in the consolidated accounts.

10. S10 · US Geological Survey · 2025-11-14 · Accessed: 5 November 2026USGS final 2025 list of critical minerals
    Passages and scope

    News item dated 14 November 2025 on the final list of 60 critical minerals published in November. Copper was added; historical comparisons need consistent classifications.

11. S11 · Bureau of Land Management · undated, consulted 2026-11-05 · Accessed: 5 November 2026MLRS Reports
    Passages and scope

    Public MLRS report portal and its administrative scope. A searchable portal is a research tool rather than a completed reconstruction of ultimate ownership.

12. S12 · Bureau of Land Management · 2026-11-04 · Accessed: 5 November 2026New BLM Tool Helps Industry Identify Known Critical Minerals Resources
    Passages and scope

    Announcement dated 4 November 2026. The screening tool combines deposits, claims and infrastructure, including processing facilities. The release describes support for project screening and preparation.

13. S13 · US Government Accountability Office · 2021-07-21 · Accessed: 5 November 2026Federal Land Management: Key Differences and Stakeholder Views of the Federal Systems Used to Manage Hardrock Mining
    Passages and scope

    Report dated 21 July 2021, publicly released 26 July. Background on federal mineral regimes, checked against the 2026 audits for the location system.

14. S14 · KGHM Polska Miedź · 2026-03-25 · Accessed: 5 November 2026Consolidated Financial Statements for 2025
    Passages and scope

    FY2025 consolidated accounts published 25 March 2026. Organisational chart, pp.14-15: Future 1, KGHM International, Robinson Holdings (USA), Robinson Nevada Mining. Note 12.1, p.150 identifies the Polish State Treasury as ultimate controlling entity. Individual mine shipments are not traced to final customers.