How a private entity is trying to assign the status of subsoil use regulator
Content:
- Introduction: Crisis of trust and the need for truth
- Chapter I. Historical Foundation: How Legitimacy Was Built (2004-2011)
- Chapter II. Technology of Deception: The «Three OERNs» Phenomenon and the Passing-off Scheme
- Chapter III. «Codex MIRR: An instrument of rupture with the State
- Chapter IV. The international dimension: How CRIRSCO was misled
- Chapter V. The Commercial Ecosystem: Who Profits from Chaos?
- Chapter VI. Legal qualifications and responses
- Chapter VII. Implications for the Industry: Why Can't We Be Silent?
- Conclusion and call to action
Introduction: Crisis of trust and the need for truth
In 2024-2025, the Russian professional community of subsoil users is facing an unprecedented challenge that goes far beyond the usual corporate disputes or competitive struggle. We have witnessed a large-scale, carefully planned and cynically implemented operation to replace the industry's fundamental institutions. At the center of this storm was a private organization, incorporated only in 2021 - the Interregional Public Organization «Society of Experts in Subsoil Use» (IPO «OERN»), led by a group of individuals (I.L. Svintitsky, I.V. Epstein, G.N. Malukhin) who, manipulating the similarity of names and historical memory, are trying to usurp the functions of the National Reporting Organization (NRO). The purpose of this article is to provide every visitor to our website, whether a geologist, investor, mining company representative, or government official, with a completely transparent, fact-checked picture of what is going on. We do not resort to emotion where documents speak. We do not use speculation where there is notarized evidence. In this material we will consistently, step by step, uncover the mechanics of creating a «twin organization», analyze the legal nullity of the so-called «MIRR Code» and show what colossal risks this activity carries for the economic security of subsoil use in Russia.Chapter I. Historical Foundation: How Legitimacy Was Built (2004-2011)
In order to understand the nature of the forgery being committed today, it is necessary to go back to the origins and clearly record how exactly the architecture of the Russian public reporting system was built. It is the historical truth that is the inconvenient factor that opponents try to erase or rewrite on their resources.1.1 State order for transparency
In the early 2000s, the Russian economy was experiencing a period of rapid growth and integration into global markets. The largest domestic companies in the mineral sector - Gazprom Neft, LUKOIL, Severstal, ALROSA, and UMMC-Holding - were entering international stock exchanges (IPOs), attracting syndicated loans, and needed a tool to translate data on our subsoil reserves into a language understandable to global investors. The Soviet school of geology was great, but the Western market demanded different standards of information disclosure. There was an urgent need to create a bridge organization that would combine the rigid state control (GKZ) with the flexibility of market codes. The answer to this challenge was the creation on November 25, 2004 of the Association of organizations in the field of subsoil use «National Association for Subsoil Expertise» («NAEN»). It is important to emphasize: this was not an initiative of private individuals who wanted to make money in consulting. It was a consolidated order of the industry and the state. The founders were subsoil users themselves, and organizational support was provided by the Federal Agency for Subsoil Use (Rosnedra). The first Chairman of the NAEN Supervisory Board was the following Yuri Alexandrovich Podturkin, who simultaneously headed the State Commission for Mineral Reserves (SCR). This overlapping of posts was a guarantee that the new structure would act in the interests of the state and not break up the unified space of subsoil evaluation.1.2 The Birth of HERN: The Function, Not the Firm
As the system developed, there was a need to create a professional workshop of experts - individuals qualified to sign reports. Thus, in 2007 the «Society of Experts of Russia on Subsoil Use» (OERN) was formed within the NAEN structure.1.3 International Triumph 2011
The culmination of this work was Russia's admission to the elite club of global standards - the CRIRSCO Committee (Committee for Mineral Reserves International Reporting Standards). This happened on November 1, 2011. In the official press release of CRIRSCO and in the Charter of the organization (Terms of Reference) the formula of Russia's representation was fixed:- National Reporting Organization (NRO): NAEN (National Committee).
- Professional Organization (RPO): OERN (as a component organization, which is a component of NAEN).
Chapter II. Technology of Deception: The «Three OERNs» Phenomenon and the Passing-off Scheme
The professional community needs to realize: what is happening now legally qualifies as a «pass-off» - a type of unfair competition in which one party passes off its services as those of another, better-known party, parasitizing on someone else's reputation. The organizers of the scheme (Svintitsky-Malukhin group) deliberately created confusion by manipulating three different entities hiding under one acronym.2.1 Separation of entities: Who is who?
For the sake of clarity, we must make a clear demarcation, confirmed by the data of the Unified State Register of Legal Entities.| Essence | Period | Legal status | Attitudes towards NAEN | Status in CRIRSCO |
|---|---|---|---|---|
| OERN (Historical) | 2007 - present. | Structural subdivision of NAEN (not a legal entity) | Integrated part | Recognized as an RPO within the NRO (NAEN) |
| MPO «OEN» (Liquidated) | 2014 - 2019 | Separate legal entity (OGRN 1147799004330) | An attempt to divide NAEN-OERN. | No Status. Liquidated 28.06.2019 |
| IPO «OERN» (Simulator) | 2021 - present. | Private legal entity (OGRN 1217700020229) | No succession | Self-declared status, attempted seizure |
2.2 Fabrication of history on the oern.expert website
Analysis of the official website of the imitator organization (oern.expert) demonstrates the classic techniques of trust attribute fraud.
- Lies about age: The «About Us» section states, «Date of creation - March 16, 2007.» This is a direct falsification. The legal entity with their TIN was created in 2021. By attributing 14 years of someone else's history to themselves, they are trying to create the illusion of institutional weight. Link to the disinformation page: https://oern.expert/about.
- Brand theft: The logos of IPO «OERN» (stylized image of instruments under the map of Russia) to the extent of confusion copy the logo of the historical OERN, the rights to which belong to NAEN. This is done so that the user does not notice the substitution.
- Illegal naming: According to the Unified State Register of Legal Entities, the full name of the organization is «Interregional Public Organization «Society of Experts in Subsoil Use»». The word «Russia» is not in the name. However, on the website and in the documents they refer to themselves as «Society of Experts Russia on subsoil use». The use of the name of the state without the permission of the Ministry of Justice is a violation of Article 1473 of the Civil Code of the Russian Federation and Article 170.1 of the Criminal Code of the Russian Federation, deliberately creating a false impression of the state status.
2.3 Use of other people's «credentials»
In order to legitimize its status to users, «OERN» places on its website scanned copies of Letters of Recognition from foreign organizations JORC (Australia), SAMREC (South Africa) and SME (USA). However, if one scrutinizes these documents, one can see that they are dated 2012-2018. At that time, the IPO «OERN» (2021) did not physically exist. These letters were addressed to the historical OERN within NAEN. The use of these documents by the new entity is fraudulent and misleading to consumers of services. Link to the fraudulent documents section: https://oern.expert/code.
Chapter III. «Codex MIRR: An instrument of rupture with the State
The centerpiece of the attack on the national system was an attempt to supplant the legitimate «NAEN Code» with a surrogate document called the «MIRR Code» (Mining Investment Reporting Russia). This is not just a name change, it is a sabotage against the unity of measurement of the mineral resource base of the country.3.1 Plagiarism and renaming as a method of «innovation»
UNAES conducted a linguistic and computer-technical examination of the text of the «MIRR Code». The results are unambiguous: the document is not an independent development.- Alignment of the structure with the NAEN Code: ~95% (view report).
- Direct textual match according to the Anti-Plagiarism system: 83,53% (view report).
3.2 Chronology of Digital Forgery
Thanks to the Wayback Machine web archiving service, we can trace exactly how the substitution of concepts took place at oern.expert.
- August 17, 2022: The first ping of the «National Codex» page in the archive (page archive). The page contains only the 2013 edition of the NAEN Code (2013 NAEN Code PDF archive).
- Through the spring of 2025: The «NAEN Code» is posted and mentioned on the website. The organization is still pretending to work in the legal field, posting documents of IPO «OERN» and does not yet claim the name of OERN and the statuses of NRO and RPO, although at the same time it is already actively engaged in international disinformation activities CRIRSCO ("CRIRSCO").page archive as of 26.03.2025).
- July 2025: On the GeoWebinar platform there are announcements of «public hearings» with manipulative wording: «Draft of the new edition of the Code (formerly NAEN Code)». Users are led to believe that the old Code is dead (link to GeoWebinar announcement).
- September 6, 2025: Physical file replacement. A «Russian Code (MIRR)» appears on the website with the false claim: «The MIRR Code replaces the earlier NAEN Code». No one gave a private organization the right to override a national standard. The physical replacement of the files occurred without changing the Internet address (URL). A page that had been linked to as the «NAEN Code» for years was quietly reverted to the «MIRR Code.» This is technical evidence of intentional traffic and reputation hijacking: users who clicked on old bookmarks in search of a legitimate document were forcibly redirected to the surrogate.
- October 7, 2025: I.L. Swintitsky at the Techno in the Subsurface conference publicly calls for a «signature transfer» to the new code, finalizing an act of self-rule.
3.3 ROCMIRR ideology: Refusal of harmonization
The most dangerous thing in the «MIRR Code» is its methodological basis. The ideologist of the project I.V. Epstein in the program article «CRIRSCO and ROCMIRR» directly declares «refusal of double standards (harmonization of SCZ categories with CRIRSCO)». Document reference: CRIRSCO and ROCMIRR (PDF).
What does this mean in practice? The NAEN Code was designed so that investor reporting would not conflict with the State Balance of Reserves data. «The MIRR Code breaks that link. This creates the threat of »double accounting«: a company may report some reserves to investors (according to the MIRR) and other reserves to the state (according to the State Reserves Balance Sheet).
Chapter IV. The international dimension: How CRIRSCO was misled
To succeed in their adventure, Svintitsky's group needed international recognition. Since the legal way was closed (Russia already has an NRO - NAEN), they went the way of disinformation of the international CRIRSCO committee.4.1 Digital Forensics: Chronology of substitution in the CRIRSCO Registry
The Internet remembers everything. Thanks to independent web archiving services (Wayback Machine), we can reconstruct the chronology of exactly how the substitution of the National Organization (NAEN) for a private entity (IPO «OERN») took place on the site of the international committee. Analyzing the historical imagery of crirsco.com reveals not only the «technical errors» but also the personnel mechanics of the takeover. We see how the historical representatives of NAEN (G.N. Malukhin, O.V. Ilyin) were gradually, step by step, replaced by the beneficiaries of the new private scheme.| Image date (Archive) | Representation of Russia (Entry) | NAEN Comment | Proof link |
|---|---|---|---|
| 06.03.2014 | NAEN - National Committee Reps: Oleg Ilyin (NAEN) + Grigoriy Malukhin (NAEN) | Historical Truth. Russia is represented by the NAEN Association. Two representatives are indicated: O. Ilyin and G. Malukhin. Both of them are rigidly tied to NAEN. | Archive 2014 |
| 17.06.2018 | NAEN - National Committee Reps: Oleg Ilyin (NAEN) + Grigoriy Malukhin (NAEN) | Status unchanged. Up until mid-2018, the tandem «Ilyin - Malukhin» officially represents NAEN. There are no references to third-party legal entities. | Archive June 2018 |
| 19.07.2018 | OERN (Russia) Reps: Oleg Ilyin (NAEN) + Igor Svintitski (NAEN) | Point of tampering and rotation. 1. The header suddenly changes the name of the organization to OERN. 2. G. Malukhin passes his seat to I.L. Swintitsky. 3. Important: both representatives (Ilyin and Swintitsky) are still listed from NAEN. This proves that Swintitsky went in on the Association's mandate committee and the change of the title to «OERN» was a disguise. | Archive July 2018 |
| 21.01.2021 | NAEN (on map) | «Flicker» status. After 3 years, NAEN reappears on the CRIRSCO membership map. This confirms that there was no legal basis in the committee for the final removal of the Association. | Archived Jan. 2021 |
| 19.10.2021 | OERN (Members list) Reps: Oleg Ilyin + Igor Svintitski | Fixing the switch. The page has moved to a new address. Both representatives (Ilyin and Swintitsky) are now displayed under the heading OERN. Affiliation (NAEN) disappears from the visible field, completing the visual break with the Association. | Archived Oct. 2021 |
| 10.05.2022 | NAEN (on map) | NAEN continues to appear as a national representative on the map even in 2022, suggesting an internal data inconsistency on the CRIRSCO website. | Archive May 2022 |
| 07.12.2022 | OERN (on map) | Visual Capture Finalization. The map has been updated, NAEN has been erased, only OERN is displayed. | Archived Dec. 2022 |
| 10.10.2025 | OERN, Russia Reps: Igor Epshtein + Igor Svintitski | A complete lineup change. O.V. Ilyin (the last representative of the historical OERN) leaves the list. His place is taken by Igor Epstein. From that point on, there was a complete replacement of the delegation by the individuals of the IPO «OERN». | Archived Oct. 2025 |
Analytical conclusions:
- «Trojan Horse» 2018. I.L. Swintitsky's entrance to the committee (July 2018) came about because he was announced as Rep. NAEN (in place of G. Malukhin). It was this legitimate status that was used for the subsequent seizure of control.
- Technical Fix (2021). The page move in October 2021 was the moment when the mention of NAEN next to the names of representatives was finally removed from the interface, fixing the visual link to OERN.
- CRIRSCO's Institutional Blindness. A key factor in the success of the scheme is the lack of distinction on the part of the international committee. For CRIRSCO's English-speaking leadership, the historic NAEN (OERN) and the new private entity (IPO «OERN») were merged into one acronym. Using the lack of Russian-speaking experts in the leadership, the organizers of the scheme convinced Chairman Garth Kirkham that they were one and the same organization. The Committee still does not see the substitution of the entity.
- Finalization in 2025. The replacement of O.V. Ilyin by I.V. Epstein (October 2025) put a personnel point in the process. If in 2018 the committee had people affiliated with NAEN, now the representation is fully controlled by private individuals affiliated with IPO «OERN» and the commercial project ROCMIRR.
4.2 Garth Kirkham's letter and the Final Notice«
Using the lack of Russian-speaking experts in CRIRSCO's leadership and confusion over acronyms, the imposters convinced Committee Chair Garth Kirkham that the NRO was the same organization that joined the Committee in 2011. In a letter dated July 18, 2025, Kirkham erroneously confirmed the status of the OERN (which is not actually the IPO «OERN») as the «current NRO.» In response, the NAEN AO sent CRIRSCO a Final Notice dated 08/09/2025 (read the full text of the letter). The document demands immediate correction of the register, introduction of a «Litigation Hold» regime (prohibition to delete evidence, logs and correspondence) and an independent audit of the representation. We warned international partners that recognizing impostors violates CRIRSCO's own bylaws (Due Process principle) and threatens to exclude the committee from IFRS procedures.Chapter V. The Commercial Ecosystem: Who Profits from Chaos?
Behind the lofty words about «standards» there is a banal commercial interest. The analysis of links shows that a strict monetization system has been built around IOE «OERN», the beneficiaries of which are specific individuals.5.1 Scheme Architects (ROCMIRR Committee)
| Figurant | Role and actions | Commercial interest | Disciplinary Status (as of 11/14/2025) |
|---|---|---|---|
| Igor Lvovich Svintitsky | Chairman of IPO «OERN», organizer of the scheme. Publicly announced the substitution of the Code on 07.10.2025. | Owner CyberGeo LLC« (GeoWebinar platform) and LLC «MINGEO». Generates income from fee-based courses and conferences. | REVOKED |
| Igor Vladimirovich Epstein | Ideologue. Author of the concept of breaking with the SCS. Self-appointed delegate to CRIRSCO. | Promoting his consulting services, selling educational programs. | REVOKED |
| Grigory Malukhin | Founding member of the IPO «OERN» (2021). | Using one's past status in NAEN/GCP to legitimize the «new-age». | SUSPENDED |
| Alexander Davidovich Pisarnitsky | Head of the «Eurasian Union» (EEU). | Organization of the flow of «certification» through ESOEN. Currently convicted under article «fraud». | SUSPENDED |
5.2 The Geowebinar sales funnel«
The scheme works like a classic marketing funnel:- Involvement: Through the geowebinar.com platform (owned by Swintitsky), free webinars are held where the fear is stoked: «The old code has been canceled, you won't be able to work without MIRR.».
- Selling Training: Users are imposed paid courses of «Geovebinar University» (beneficiary - Svintitsky) and partner training of ESOEN with imitation of access to state expertise (Pisarnitsky A.D. - member of ROCMIRR and director of ESOEN convicted under the article fraud on October 29, 2025):
-
- Scheme: For 65,000 rubles (plus membership fees) listeners are promised inclusion in a certain «Register of experts» with the wording that they will be «taken into account by the FBU «GKZ» when appointing experts for state expertise.
Fig. 2. Documentation of the sale of «access» to the state expert examination for 65,000 rubles.- Violation of the law: According to Resolution of the Government of the Russian Federation No. 335 and Order of the Ministry of Natural Resources and Environment No. 216, the procedure for certification and involvement of experts in the state expert review is strictly regulated and does not provide for mediation by private NGOs. Creation of a paid «filter» for access to the state function is illegal and contains signs of misleading for the purpose of taking money.
- Pseudo-certification and monetization of access to the profession: Placement in the «competent person registry» on the website oern.expert/competent (not recognized by NAEN and CRIRSCO) is implemented according to the model of a closed commercial ecosystem. In order to be included in the list, financial burdens are imposed on the specialist: payment of admission and membership fees, as well as mandatory training. There is a fundamental conflict of interest in this scheme: IPO «OERN» solely sets the requirements for «recognized» training and sells these educational services itself (through affiliated structures, such as ESOEN and «Geovebinar University»). Thus, the declared «national certification system» is actually a private profit-making mechanism, where the funds of the professional community are redirected to the accounts of commercial organizations.
- Forums: Legitimization takes place through paid forums «MINGEO», the operator of which is LLC «Mining and Geological Forum MINGEO» (Krasnoyarsk, 8 Parkovaya St.), also owned by Svintitsky.
According to weighted average estimates, the damage to OERN and NAEN alone from misrepresentation and imposition of services by this group has already exceeded RUB 63.5 million, without considering the harm to companies and experts.5.3 Imitation of social activities
The fundamental problem of the established structure is that the IPO «OERN» does not solve the real tasks of the expert community. Instead of promoting the profession, protecting the rights of geologists and providing methodological support, the organization has been turned into a closed commercial circuit. It exclusively serves the private financial interests of a narrow circle of beneficiaries who monetize access to the profession through imposed services, while ordinary experts become a mere source of contributions.Chapter VI. Legal qualifications and responses
NAEN has moved from exhortation to tough legal action. The actions of the ROCMIRR group are not characterized as ethical violations, but as criminal acts. Technological simulation of state powers (AIS «Register») The operation of the private information system AIS «Register of Experts» (experts.eues.ru), which goes beyond maintaining lists of NCO members, was recorded. According to the technical documentation, the system's functionality copies the contour of the state administration: automatic formation of «orders on the creation of expert commissions», imitation of sending documents to departmental EDMSs and approval procedures typical for FBU «GKZ». Such IT-architecture misleads users, creating a complete illusion of working in the official state contour.6.1 Statement to the Investigative Committee of the Russian Federation
An application to initiate criminal proceedings was sent to the Chairman of the Investigative Committee of the Russian Federation A.I. Bastrykin.6.2 Appeal to the FAS of Russia
An application has been filed with the Federal Antimonopoly Service for violation of Article 14.33 of the Code of Administrative Offenses of the Russian Federation and the Law «On Protection of Competition». We demand to recognize the actions of IPO «OERN» as an act of unfair competition, block their resources and oblige them to publish a refutation of false information about «continuity».6.3 Decisions of the Disciplinary Committee: Measures of responsibility and status of experts (Minutes No. 01-DC/2025)
On November 14, 2025, the Disciplinary Committee of the «NAEN», following the review of materials on violations of the Code of Professional Ethics and actions aimed at destabilizing the national reporting system, adopted the following decisions.CATEGORY A: WITHDRAWAL OF STATUS (REVOKED)
With regard to persons whose actions are qualified as organization of a scheme to mislead market participants and international partners, a decision was made to terminate the Competent Person status indefinitely.- Igor Lvovich Svintitsky - status revoked. Grounds: organizing activities aimed at usurping the functions of the National Reporting Organization (NRO) and deliberately misleading the CRIRSCO committee.
- Igor Vladimirovich Epstein - status revoked. Grounds: development and promotion of documents contrary to the principles of harmonization with the state expertise, as well as provision of inaccurate information to international organizations.
CATEGORY B: SUSPENSION OF STATUS (SUSPENDED)
In respect of a group of persons whose participation in the activities of the IPO «OERN» and the «ROCMIRR» committee is considered as contributing to the violation of standards, a decision was made to suspend the status for a period of up to 01.12.2025. These persons are given the opportunity to officially cease participation in the activities of illegitimate structures. In the absence of appropriate applications within the established period of time, the status will be canceled automatically from 02.12.2025. List of persons with suspended status:- Grigory Malukhin
- Oleg Vyacheslavovich Ilyin
- Alexander Borisovich Lazarev
- Mikhail Ilyich Leskov
- Pyotr Ivanovich Kushnaryov
- Alexander Sergeevich Tarasov
- Gennady Mashkovtsev
- Alexander Sergeevich Yakubchuk
- Alexander Davidovich Pisarnitsky
A.B. Lazarev: Use of administrative resources and conflict of interest
It is important to note the role of A.B. Lazarev, who, while holding the position of Chief Geologist of FBU «GKZ», joined the private committee «ROKMIRR» and promoted their agenda and the MIRR Code in the departmental journal of FBU «GKZ» «Geology and Subsoil Use» (No. 01/May 2025). This is considered as a gross conflict of interest, undermining confidence in the state expertise.
- Documented dual affiliation: While holding the state position of the Head of the Department and Chief Geologist for TPI FBU «GKZ», A.B. Lazarev simultaneously holds senior positions in the private structure «Eurasian Union of Experts on Subsoil Use» (EUEN). The official website of ESEN directly confirms his status as a Deputy Chairman of the Management Board (Lazarev's profile page as Deputy Chairman of the Management Board) и Chairman of the Audit Commission (Lazarev's profile page as Chairman of the Audit Commission).
- Legitimization of private activity through statehood: On the above pages Lazarev is positioned exactly as an official of FBU GKZ, which creates a false illusion among market participants that commercial products of ESEN (paid registers, training) have state approval and departmental sanction.
- Direct participation in a private committee: Despite his civil servant status, Lazarev joined the private ROCMIRR committee, publicly enshrining his responsibility for implementing a Codex MIRR standard that competes with the government's.
- Utilization of the departmental podium: He promoted a private agenda through the official printed body of FBU «GKZ». The journal «Geology and Subsoil Use» (No. 01/May 2025), where Lazarev is a member of the editorial board, featured a column «ESOEN News» advertising the CRIRSCO/MIRR bundle.
- Methodological sabotage: He was the architect of the technical substantiation of the «MIRR Code», promoting the rejection of harmonization with the state categories of reserves (the principle of «remove the second scale»), which leads to the breakdown of the unified space of subsoil evaluation.
- Legal Qualification: In the absence of official orders from the SCZ management to participate in the activities of IOE «OERN» and ESOEN, the actions of the official are considered as self-rule and exceeding the limits of authority.
Chapter VII. Implications for the Industry: Why Can't We Be Silent?
We appeal to every user of the site, to every industry professional. The situation with IPO «OERN» is not a dispute between two business entities for the market of services. It is an attempt to undermine the foundation of trust in the Russian mining industry and the Russian expert community, creating systemic risks of a national scale. The introduction of a surrogate standard («MIRR Code») by a private entity and the creation of a parallel regulatory reality carries the following critical threats:1. Direct threat to national sovereignty and mineral and raw material security
The actions of the ROCMIRR group go beyond ethical violations and affect legally protected values, jeopardizing the country's economic security:- Loss of unity of strategic information management. A private document, the «MIRR Code,» which is being promoted as a replacement for a national standard, breaks a critical linkage «public reporting ↔ State Examination (SAE)». This leads to discrepancies between the State Balance of Reserves and the public disclosures of companies. A «double accounting» effect arises, creating a window of opportunity to manipulate the volumes and categories of reserves to the detriment of the state's interests.
- Substitution of public law powers. The publication of private «registers» and «rules» on the oern.expert website creates an illusion of officialism. The private structure actually usurps the functions of a regulator influencing the circulation of strategic information on subsoil, without any state mandate.
- Risk to the tax base and licensing. Splitting standards leads to non-comparability of data. The MIRR logic (comparing data only after it has been internalized) allows reports to be issued without reliance on state expertise. This complicates the administration of mineral extraction tax (MET), production planning and control over compliance with the terms of license agreements.
- Loss of methodological sovereignty. «The MIRR Code declares the refusal of harmonization with the state standards of the Russian Federation in favor of exclusive application of Western methodologies. This approach creates a critical vulnerability: replacing national criteria with borrowed ones devalues the unique competencies of the domestic expert community. This threatens the long-term degradation of the mining industry's human resources potential, with Russian specialists relegated to the role of auxiliary personnel serving the interests of foreign auditors.
2. International isolation and financial and economic risks
The attempt to create a «second center» to represent Russia in the international arena hits the capitalization of each subsoil user:- The «two-center» effect in CRIRSCO. The positioning of IPO «OERN» as a «national» entity dilutes Russia's state mandate. The presence of two conflicting «representations» (NAEN and the self-proclaimed IPO «OERN») creates the risk of a complete suspension of Russia's membership in CRIRSCO and a revision of the country's status in the system of international standards.
- Delisting risk and capital appreciation. International exchange regulators (ESMA in the European Union, CSA in Canada) officially recognize only the «NAEN Code». A report signed under the unrecognized «MIRR Code» is legally void for listing in Toronto, Hong Kong or London. Companies that risk using such a report will face delisting, shareholder lawsuits for misleading disclosure, and higher credit costs due to regulatory uncertainty.
3. institutional trap for experts (Competent Persons)
The biggest blow is to the professional community of geologists, who become hostage to the scheme:- Turning certificates into legally worthless papers. Geologists who have paid courses and membership fees to the IOO «OERN» have actually purchased illegitimate documents («wrappers»). The Competent Person status is valid only if confirmed by NRO (National Reporting Organization), which is NAEN. The private registers of the NRO do not create legal consequences.
- Loss of international recognition. If the status of the national system (NRO) is undermined, automatic recognition of Russian competent persons abroad will cease (Reciprocity principle). Signatures of Russian experts will cease to be accepted by foreign banks and stock exchanges, which means professional disqualification on the international market.
Conclusion and call to action
The truth is on our side. History, documents, state registration and international agreements confirm it: The only National Reporting Organization (NRO) in Russia is the NAEN Association. The only legitimate standard is the NAEN Code. All activities of IPO «OERN», «ROCMIRR» committee and related structures on creation of parallel reality are illegal.What should you do?
- Check: Competent Person status is valid only if it is confirmed in the official register on the website naen.ru or oern.ru. Registries on oern.expert and other portals are not legally binding.
- Ignore it: Do not give in to provocations and demands to switch to the «MIRR Code». This document has signs of counterfeit and is not recognized legitimate regulator. The current presence of traces of misinformation in public sources (including the official CRIRSCO website) is the result of misleading the international committee and is temporary. After the legal procedures are completed and the correct NAEN status is restored in the registers, the use of a surrogate standard («MIRR Code») will create pending risks for you: from non-recognition of reports to claims from exchanges and regulators.
- Report: If CyberGeo LLC services are imposed on you or if you are demanded to join IPO «OERN» under the threat of problems with expertise, report it to NAEN. We document every fact for submission to law enforcement agencies.
The article was prepared by the Information and Analytical Department of the UN AO «NAEN» on the basis of materials submitted to the Investigative Committee of the Russian Federation and the Federal Antimonopoly Service of Russia. Date of data update: 09.12.2025. -