Since 11 April 2023, the blanks for Mongolia's national passports have been produced by a purpose-built state company, Toriin Unet Tsaas Hevlel (State Securities Printing). The state holds 51 percent of it. A private company, Migason LLC, holds the other 49 percent — a stake recorded at ₮15,483.2 million. When the state's own auditors examined it in the second quarter of 2024, they recorded that no handover act existed for Migason's contribution and that the origin of that ₮15.5 billion was unclear. The company was, by then, already operating ₮23,068.8 million in assets.
That finding is not an opposition claim or a media report. It is in the internal audit report of the General Authority for State Registration (UBEG), dated 8 July 2024 and published on UBEG's own site, burtgel.gov.mn. This investigation sets out what the documents establish, what has only been reported, and what remains unproven.
By Government Resolution No. 69 of 8 February 2023, Toriin Unet Tsaas Hevlel was established to produce and personalise national electronic passport blanks, with UBEG responsible for professional oversight. Its charter capital was set at ₮31,598.4 million: ₮16,115.2 million (51 percent) from UBEG and ₮15,483.2 million (49 percent) from Migason LLC. It was entered in the state legal-entity register on 11 April 2023.
UBEG's internal audit of the second quarter of 2024 found neither side's founding contribution properly settled. No decision of the State Property Policy and Regulation Agency had been issued for the transfer of UBEG's own 51 percent asset contribution. On the private side, there was no handover act for Migason's 49 percent contribution, and the audit states that the origin of that contribution was unclear. While the paperwork stood open, the company's board chair and executive director had signed a lease over the assets in use, creating a ₮2,618.0 million rent liability, and UBEG had prepaid raw-material purchases for passport production from its current account.
The state's side was regularised during 2024: on 16 May 2024 the State Property Agency, by Resolution No. 234, moved UBEG-registered assets valued at ₮16,115.1 million into the company's charter capital against the state's 51 percent, and on 19 July 2024 UBEG's head, by Order A/123, transferred the passport personalisation plant's equipment. A supply contract for passport blanks was drafted on 20 February 2024. What no document in the public record yet shows is the corresponding paper for Migason's side: the handover and valuation acts for ₮15,483.2 million, or how Migason was chosen.
The Minister of Foreign Affairs, Batmönkhiin Battsetseg, has held that office continuously since 29 January 2021. Her career before politics was printing. She was general director of Munkhiin Useg from 1996 to 2005 and chair of the Munkhiin Useg Group board from 2007 to 2015, then Deputy Minister of Foreign Affairs from 2016 to 2020.
She has never hidden the business. Her asset declarations to the Anti-Corruption Agency (IAAC), as recorded by UIH.mn from her 2024 filing, list majority stakes across a vertically integrated print group: 52 percent of Munkhiin Useg LLC (19,081 shares); 52 percent of Mongolian Securities Printing LLC (29,738 shares); 52 percent of Ecopack Mongolia LLC (27,303 shares), working in packaging; 50 percent of Eco Paper LLC (500 shares); 45 percent of Az Khur LLC (850,109 shares); and 100 percent of Batar International LLC. She also declares smaller parcels in Bayalgiin Khuv JSC, Jenco Tour Bureau and Mongol 999 National Consolidation JSC. Her declared income across the series is ₮392,572,000 in 2023, ₮620,327,000 in 2024 and ₮460,798,000 in 2025; the 2025 summary lists real estate of ₮150,000,000 and savings of ₮253,667,000 — and, in tension with the 2024 filing, her shares at a value of ₮0, a point Decode has put to her.
The accountability question in her file is therefore not concealment; the stakes are declared, openly, year after year. It is where the state's secure-printing business flows, and who stands at the other end of it.
The minister's documented 52 percent is in Mongolian Securities Printing LLC — a private company. The passport printer of 2023 is Toriin Unet Tsaas Hevlel — a different, state-majority company with a near-identical name. The two are routinely confused, and the confusion has shielded the second company: readers who check the minister's declarations find her private printer, declared and accounted for, and stop there. Her stake in the state printer is zero. Its private 49 percent belongs, on the documented record, to Migason LLC. What connects the minister to Migason is not a share certificate. It is a reported personnel link, at a lower tier of evidence than everything above.
DNN.mn, in an investigation published on 20 April 2026, reported that the sole shareholder of Migason LLC is N. Tserendolgor. DNN.mn further reported that Tserendolgor is a former legal adviser to the minister's companies Munkhiin Useg and Ecopack Mongolia, and an executive director of VSM LLC, a company founded by the minister's son, Ganbatyn Sodjamts. A later editorial on Zaluu.com, an openly partisan commentary outlet, repeated the 51/49 structure and alleged that people close to the minister run the company, that tens of billions of tögrög were taken without tender or oversight, and that the IAAC does not investigate her. Zaluu.com's figures are not itemised, and no checked primary source establishes that Tserendolgor owns Migason, that the minister influenced Government Resolution No. 69 or the choice of Migason — the resolution is a government act executed by UBEG, which sits outside her ministry — or that any sum was misappropriated. No court or IAAC finding on the company exists. Decode Mongolia has not verified this claim; it is published as reported.
What the documents do establish is the shape of the money: a ₮31,598.4 million charter capital whose private half arrived, on the state's own audit, without a traceable origin; ₮23,068.8 million in assets in use by mid-2024; and a state supply relationship for passport blanks whose contract value and tender record are not in the public documents so far released. Passport-printing money has flowed abroad before: in 2016 the Hungarian Banknote Printing Company signed a contract of about US$10 million to manufacture Mongolian electronic passports (Hungarian Government, 26 January 2016). That contract predates both the state printer and Battsetseg's ministership, and no checked source links her to it. Who has received dividends or payments from the 49 percent since 2023 is a question the company's financial statements would answer; they have not been produced.
Since July 2024, Battsetseg has also sat as a Member of Parliament for District 1, the Khangai region. Hunnu.mn's review of her parliamentary activity reports service on the Budget Standing Committee (July 2024 to July 2025), the Petitions Standing Committee (July 2025 to April 2026) and, from April 2026, the Environment, Food and Agriculture Standing Committee. It is in the chamber, not the ministry, that her printing holdings meet a written rule. UIH.mn, the parliamentary monitoring record, documents her declared printing stakes and states the consequence under Rule 14.10 of the Law on Parliamentary Session Procedure: where a member or their family earns income from an activity connected to a matter under discussion, the member must notify the chair and abstain from the vote. UIH.mn concludes she carries a conflict of interest in the printing sector and bears that duty. No checked source records whether she has ever filed such a notification or abstained on a printing, passport or registration matter. The register that would show it exists; the entries, if any, have not been produced.
Under her ministry, Mongolia co-led — with Norway, Ghana and Albania — the UN Resolution on Political Finance Transparency adopted at the 11th Conference of States Parties to the UN Convention against Corruption in Doha in December 2025, and on 2 March 2026 she visited International IDEA headquarters in Stockholm to discuss political-finance transparency cooperation (International IDEA, 3 March 2026). That record sets the standard her own file will be read against: a minister who has carried the transparency standard into the UN system, whose declarations are open, and whose open declarations lead to a state company whose founding private contribution her own government's auditors could not trace.
For the record: no criminal case, IAAC action, foreign sanctions listing, Interpol notice or foreign court record naming Battsetseg was found in the sources checked for this investigation, and no checked source reports a procurement scandal or audit finding inside the Ministry of Foreign Affairs itself touching her or her companies. These are negative search results, stated as such — not a clearance, and not an accusation.
Under Decode Mongolia's reply law, the subject of an investigation is contacted before publication, given every claim in writing, and invited to answer; the answer runs beside the piece. Decode has written to Minister Battsetseg — with parallel letters to UBEG, the State Property Policy and Regulation Agency, Migason LLC and N. Tserendolgor — putting seven claims: the founding of the company under Resolution No. 69 and the documented 51/49 structure; the audit's findings on the undocumented contribution and the ₮23,068.8 million in assets in use; DNN.mn's reported identification of Migason's sole shareholder and her reported ties to the minister's companies and her son's company, with a request to confirm or deny any relationship and any part in the company's establishment; her declared printing portfolio and whether those companies have held state contracts during her tenure; her Rule 14.10 duty and whether she has notified or abstained; her income series and the ₮0 share entry in 2025, with a request to explain the 2024 peak and confirm her current holdings; and an open invitation to identify any proceeding Decode has not found. The letter gives 10 working days to reply. Any answer will be published with this piece; if a document she provides proves a claim false, the claim will be relabelled proven false, with the proof linked.
Five documents, all of which exist or should exist, would settle every open claim in this piece: the full text of Government Resolution No. 69 with its annexes and the company charter, showing the founding terms and whether any selection process for the private partner was prescribed; Migason LLC's full register extract, proving or breaking the reported sole-shareholder claim; the handover and valuation acts for the contribution and any follow-up audit, showing whether the "unclear origin" finding was ever cured; the UBEG passport-blank supply contracts with values and tender records, proving or breaking the claim that money moved without tender; and the minister's full primary IAAC declarations for 2021 to 2025, settling the ₮0 share entry, the 2024 income peak and her holdings today. The story will be updated, in the open, with whatever they show.