Law enforcement agencies have spent years investigating corruption and criminal activity within Mongolia’s coal industry, uncovering schemes that stretch from the manipulation of contracts to the illegal movement of coal across state borders. Courts have already heard a number of cases involving abuse of power, bribery, money laundering and unjust enrichment. Officials say the wrongdoing has touched nearly every aspect of the coal trade, including sales agreements, transport networks and financial transactions. But while many cases have been prosecuted, others appear to have quietly disappeared, leaving the public with unanswered questions and growing concerns over accountability.
One of the most prominent unresolved cases involves Founder of Ajnai Group LLC and former Parliamentarian D.Bat-Erdene, alongside R.Seddorj, who represented Umnugovi Province in parliament. The case was transferred to the Prosecutor’s Office, where it stalled. Investigators had previously announced that D.Bat-Erdene admitted his guilt and paid compensation amounting to more than 11 billion MNT in damages uncovered during the probe. Despite this admission and repayment, the matter has remained in limbo, with no resolution made public.
Another case that has slipped into obscurity is linked to former Lawmaker J.Munkhbat. Investigators alleged that ex-legislator A.Adiyasuren paid a 100,000 USD bribe to an official of the National Road Transport Center in order to secure a coveted “C” permit for international cargo transportation. Once spotlighted as a textbook example of corruption in the coal transport sector, this case too has faded from the headlines without explanation.
These unresolved cases stand in stark contrast to the broader picture painted by ongoing investigations. Law enforcement officials have documented widespread abuses in coal sales and purchase contracts, where tender processes were allegedly manipulated to favor select companies in exchange for kickbacks. Transportation has also been rife with misconduct: authorities say coal was illegally imported across state borders under the guise of legitimate trade, often aided by falsified documentation. The fraudulent issuance of “C” permits, designed to regulate international cargo transportation, has been a central feature in several prosecutions.
Corruption has extended further into infrastructure and procurement. Railway construction projects tied to coal transport corridors were allegedly awarded through rigged tenders, with bribes exchanged to secure lucrative contracts. Investigations into public procurement have similarly revealed that well-connected businesses received preferential treatment, while competitors were excluded. Financial crimes, including money laundering and unjust enrichment, also feature prominently in indictments. Investigators claim profits from coal contracts were funneled through shell companies, offshore accounts and real estate holdings to disguise their origins.
Despite the breadth of the crackdown, the disappearance of major cases such as those involving D.Bat-Erdene and J.Munkhbat has drawn scrutiny. Analysts warn that when prosecutions stall without explanation, it undermines public confidence in the justice system and raises doubts about whether corruption is being tackled consistently. For a nation where coal remains both an economic lifeline and a flashpoint for political influence, the quiet vanishing of such cases suggests that the deeper problem is not simply corruption itself, but the uneven pursuit of justice.
Supreme Court to review exclusion of D.Ariunbold and S.Ganselem
In addition, the long-running investigation into former Erdenes Tavan Tolgoi JSC CEO D.Ariunbold and former Governor of Govi-Altai Province S.Ganselem remains unresolved, with the Supreme Court still to decide the case despite the seriousness of the allegations.
D.Ariunbold, who headed the state-owned coal company between September 2016 and April 2018, was detained in 2023 as part of the sweeping “Coal” corruption probe that has implicated several public officials, including Member of Parliament Sh.Radnaased. Prosecutors accused him of abusing his office to conclude coal purchase and sale contracts with three Chinese companies, namely Urat Middle Banner Tianyimengyu Logistic Co. Ltd, Inner Mongolia Rong He Energy and Bo Yu An Shi Di. According to investigators, the companies agreed to pay him a bribe of 1 USD for every ton of coking coal sold under contracts covering between 260,000 and 360,000 tons. The total alleged bribe amounted to 360,000 USD.
The case, opened in 2017 under file No. 1741000150174, also involved S.Ganselem. During his tenure as governor of Govi-Altai Province, he granted a 15-year lease on land located in the protected zone of the old runway at Altai airport to a company founded by D.Ariunbold. The project was formally described as a wholesale trade center, but prosecutors argued that S.Ganselem’s decision, taken without inclusion in the provincial land management plan, amounted to giving D.Ariunbold improper advantages.
The initial trial, presided over by Judge of the Govi-Altai Soum Intermediate Court B.Odbayar and attended by supervisory prosecutors Ch.Batzorig and B.Oyuntsetseg, ended inconclusively. D.Ariunbold, represented by lawyers D.Batsukh and B.Baatarsaikhan, was acquitted after the court ruled that the charges of bribery and abuse of office did not constitute criminal conduct. S.Ganselem was found guilty of abuse of power as a politically influential person and sentenced to five years in prison along with a fine of 15 million MNT.
That conviction was later overturned. The Govi-Altai Provincial Criminal and Civil Appeal Court, presided over by Chief Judge Sh.Battogtokh with Judges Ts.Oyun-Erdene and B.Namkhaidorj, acquitted S.Ganselem, applying the same reasoning that led to D.Ariunbold’s acquittal.
Prosecutors, refusing to accept the decisions of both the first-instance and appellate courts, filed an objection with the Supreme Court. Yet the case has stalled once again: the scheduled hearing was postponed because the presiding judge had not yet fully reviewed the case files. Until the Supreme Court resumes, the matter remains unresolved, reinforcing public doubts about the judiciary’s ability to bring politically sensitive corruption cases to a clear conclusion.
Head of Transport Agency fined only
The Supreme Court has also closed the final chapter in one of the most prominent pandemic-era corruption cases linked to the coal transport sector. By refusing to hear the appeal of five defendants, the Court has allowed the verdicts and fines imposed by the lower courts to become legally binding. The ruling applies to Head of the Traffic Management Department of the State Transport Agency K.Aidos, specialists G.Mendbayar and S.Onon and company officials B.Davaa and L.Baldorj.
The case stemmed from events in December 2021, when the government had introduced a system of “bubbles” to allow coal exports to continue under pandemic restrictions by isolating truck drivers and giving them permission to cross the border. According to investigators, K.Aidos and G.Mendbayar manipulated the lists of approved drivers from five enterprises, inflating the rosters far beyond the government’s intended limits. Instead of authorizing 17 to 46 names, they expanded the lists to between 52 and 87, then introduced these names to border officials for clearance. In doing so, they allegedly provided privileges not only to enterprise managers but also to Chinese citizens.
The investigation further revealed that bribery was a central element of the scheme. G.Mendbayar accepted a payment of 5 million MNT from a Chinese business entity, while S.Onon received an iPhone 13 from coal company manager B.Davaa in exchange for expanding the number of approved drivers from 67 to 103 and granting special licenses for trucks. L.Baldorj played the role of financial intermediary, transferring the bribe from G.Mendbayar to S.Onon’s account.
The case was repeatedly delayed in the Soum Intermediate Court of Khanbogd soum, Umnugovi Province, before a ruling was finally delivered on January 17, 2023. K.Aidos was convicted of abusing his position to give unlawful advantages and sentenced to two years of disqualification from public service along with a fine of 15 million MNT. G.Mendbayar was convicted of abuse of power and bribery, disqualified from holding public office for seven years and fined 26 million MNT. S.Onon was sentenced to the same disqualification period and fined 21 million MNT. B.Davaa, who offered the bribes, was fined 16 million MNT, and L.Baldorj was fined six million MNT and barred from public service for between two and four years.
The Umnugovi Provincial Criminal and Civil Appeal Court later upheld the sentences in full, rejecting the appeals lodged by the defendants. Their final attempt to overturn the convictions was cut short when the Supreme Court refused to hear the case, ensuring that the lower court’s ruling is now final and binding.
Unlike other major corruption cases tied to the coal sector that have stalled or disappeared from public scrutiny, this case has reached conclusion. Yet critics argue that the absence of prison terms, despite evidence of bribery and abuse of authority, shows how lightly Mongolia’s justice system often treats corruption even when convictions are secured. For now, the 2021 coal transport bribery case stands as one of the rare instances in which officials and company representatives faced legal consequences, albeit limited, for their actions.
