In any event the obvious solution to the problem, if it were such, would be to remove the MMCZ’s monopoly over mineral marketing, which may be of dubious constitutionality in any event. The claim that the SDN list imposes sanctions against Zimbabwe has some cogency in relation to the Zimbabwe Mining Development Corporation. This 100% state owned entity does not merely develop mining in Zimbabwe, as the name of the Act30 implies, but conducts its own mining activities. A complete list of ZMDC mines and the extent of its ownership in these mines is difficult to determine. The ZMDC website has not been updated since 2015 and the last annual report appearing there is from 2012. Nonetheless, ZMDC has, or previously had mines, in the following areas: Gold – Bar-20 Mine, Kimberworth Investments (Pvt) Ltd trading as Sabi Gold Mine; Jena Gold Mines and Elvington Gold Mine, (all 100% ZMDC owned); Emeralds – Sandawana Mines (Pvt) Ltd (90%); Tin – Kamtivi Tin Mines (40%); Copper – Copper Queen, Lomagundi Smelting and Mining (Alaska Mine), Sanyati Copper Mines and Mhangura Copper Mine (all 100%?); Zimbabwe Germany Graphite Mines (Pvt) Limited (50%); Platinum – ZMDC has been linked in reports31 to joint ventures in platinum mining on the Great Dyke with Global Platinum Resources, Todal Mining and Sino-Zim Global. ZMDC’s share in these proposed joint ventures appears to be less than 50%; Diamonds – Marange Resources (Pvt) Ltd (100%), Mbada Diamonds (Pvt) Ltd (50% - with Grandwell Holdings), Diamond Mining Corporation (Pvt) Ltd (50%); Anjin Investments (Pvt) Ltd (10%). However, most of these ZMDC mines are dormant or have been shut down. In 2016 most diamond mining in Marange (including Mbada and Marange Resources) was consolidated under the Government’s Zimbabwe Consolidated Diamond Company (Pvt) Ltd leading to protracted litigation and then unbundling/demergers in the post-Mugabe era. Of all 23 wholly owned government mines nationally, only three are running. Government’s attempts to sell off its mines under the Mnangagwa administration has failed to date, mainly due to the indebtedness of the companies.32 In order to demonstrate a loss of revenue to the state on account of sanctions against the ZMDC, it is necessary to show either that mining operations were affected by the inability to obtain capital equipment and inputs due to sanctions or that this could only be obtained at a significantly higher price from countries that had not imposed sanctions on these entities and/or the inability to sell outputs to sanctioning counties meant that the product could not be sold at all, or only at significantly reduced prices elsewhere. There do not appear to be any studies which have undertaken analysis of this nature. ZANU PF’s 2013 election manifesto stated that sanctions had cost the country US$42 billion in lost revenue of which US$3,4 billion was held to be reduced GDP.33 In 2017 government awarded a $150 000 tender to a group of academics for research to be conducted to show how the supposed $42 billion loss had arisen.34 The subsequent report, has never been published.35 There appears to have been only one genuine attempt to analyze the effect of the measures, undertaken by a South African based NGO, IDASA, in 2010.36 The study found that “the primary blame for the downward spiral of the national 30 Chapter 21:08. Including its own annual report for 2012, the last published report on its website, which does not appear to have been updated in any respect since 2015. 32 Why Zim’s Big Mine Sale is Failing? Newsday 02.04.19. 33 ZANU PF 2013 Election Manifesto Table 1 p50. How the figures are arrived at is not stated. 34 UZ Wins Bid For 'Sanctions' Impact Study Daily News 26.01.17. 35 Ahead of the “anti-sanctions day march Foreign Affairs and International Trade Minister, Dr Sibusiso Moyo, presented a paper to Cabinet, indicating Zimbabwe lost US$98 billion due to sanctions of which US21 billion was reduced GDP. This may be the report by the UZ academics, apparently to be published after cabinet approval – see ‘Zim loses US$98 billion due to sanctions’ The Sunday Mail 11.09.19. 36 The date does not appear on the paper and is deduced. The paper is available here: https://www.academia.edu/ 1861567/Restrictive_Measures_and_Zimbabwe_Political_Implications_Economic_Impact_and_a_Way_Forward. 31 10