DRC Mineral Sourcing Due Diligence: A Practical Checklist for International Buyers

Procurement teams buying gold, copper, cobalt, lithium, coltan or cassiterite with a Democratic Republic of the Congo (DRC) origin face the same core question regardless of mineral: can every claim made about the material and the people selling it be checked in writing? Offers often arrive with attractive specifications and urgent timelines but little documentation. A structured checklist slows the process down to the speed of evidence.

This guide sets out the checks Afrimet Global Resources considers before a DRC sourcing enquiry progresses, drawing on public frameworks such as the OECD Due Diligence Guidance, the ICGLR Regional Certification Mechanism and FATF anti-money-laundering standards. It does not describe any available lot, and it is not legal, sanctions, customs or regulatory advice. Where a requirement depends on the mineral, the destination or the buyer’s own policies, we say so rather than stating a single rule.

Start with the legal entity, not the individual making contact. Obtain the company’s registration documents, registered address, directors and ultimate beneficial owners, and confirm them against official registries where possible. The bank account named for payment should be held in the same legal name as the contracting seller.

Then establish authority. An intermediary, agent or broker should be able to show a written mandate from the party holding title to the material, and the buyer should be able to confirm that mandate directly with the title holder. Production statistics, photographs or a certificate of origin do not prove that the person offering a cargo is entitled to sell it.

Ask for the mine site or sites of origin and the mining title under which the material was produced. In the DRC, mining and exploration rights are recorded by the Cadastre Minier (CAMI) under the Mining Code (Law No. 18/001 of 2018, which amended Law No. 007/2002). An exploration licence is not a mining licence, and neither on its own authorises a third party to export. Buyers should request the relevant title, the export or trading authorisation held by the exporting entity, and evidence of royalty and tax payment, and verify them with the issuing authority or a qualified local adviser.

For tin, tantalum, tungsten and gold, the ICGLR Regional Certification Mechanism applies, and in the DRC the Centre d’Expertise, d’Evaluation et de Certification (CEEC) acts as the focal point for ICGLR certificates. Copper, cobalt and lithium follow different national processes, so the document set will differ by mineral; the buyer should list the expected documents per mineral rather than reuse one template.

The OECD Guidance asks companies to identify and assess risk across the supply chain, including where minerals originate in or transit through conflict-affected and high-risk areas, as parts of eastern DRC are widely regarded. In practice, this means a reconciled record of who held the material at each stage — mine, trading counter, processor, warehouse, exporter — with weights, dates and lot or bag identifiers that match from one document to the next.

Ask how blending, repacking or weight changes were recorded and who witnessed them. Where an upstream traceability or audit programme applies, request its documentation. For gold, the LBMA Responsible Gold Guidance sets expectations that many refiners apply to their suppliers; for tin, tantalum and tungsten smelters, the Responsible Minerals Assurance Process is widely referenced. Confirm which standard your own receiving refinery or smelter requires.

A seller’s assay certificate is a starting point, not settlement evidence. Specify in writing who samples, where, using which method, and which independent laboratory analyses the sample. Agree an umpire laboratory and the tolerance that triggers an umpire assay before shipment. For concentrates, agree whether results are stated on a dry or wet basis and how moisture is determined. For refined gold, verify hallmarks and serial numbers against refinery records rather than relying on photographs.

Sample-to-lot matching matters: the sample assayed must be shown to represent the lot actually loaded, with sealed sample retention for the agreed period.

Screen the seller, its owners, directors, agents, banks and logistics providers against the sanctions lists that apply to your organisation — typically including the UN Security Council lists (the 1533 Committee covers the DRC), the US OFAC lists, EU and UK lists, and any others relevant to your jurisdiction. Identify politically exposed persons and apply enhanced due diligence where they appear. The FATF Recommendations provide the international baseline for customer due diligence; South African parties are additionally subject to obligations administered by the Financial Intelligence Centre.

Treat cash payments, unexplained third-party payees, pressure to skip verification and commissions to undisclosed parties as red flags that justify pausing the transaction.

The export file should be complete before the material leaves the country. Depending on the mineral and route, it may include the export authorisation, certificate of origin, ICGLR certificate where applicable, assay and weight certificates, packing list, commercial invoice, proof of royalty and tax payment, and transport documents such as a bill of lading or air waybill. Every document should reference the same lot, weight and parties. Afrimet does not issue or reproduce government documents, and buyers should verify any certificate with its issuing body.

Agree the Incoterms® rule, the named place and the point at which risk transfers, and make sure the insurance cover matches it. Clarify who arranges and pays for inland transport, border clearance, warehousing, security escorts, inspection and freight. Inland DRC cargo commonly moves by road or rail towards ports via neighbouring corridors, so transit documentation and the custody record must continue across borders. Where South African coordination is involved, confirm which entity handles each stage and under which contract.

Destination rules can add obligations. EU importers of tin, tantalum, tungsten and gold above set volume thresholds must meet due-diligence duties under Regulation (EU) 2017/821, which is based on the OECD Guidance. Other destinations apply their own import controls, reporting requirements or refinery onboarding standards. Confirm with your own compliance team what evidence your customs authority, bank and refinery will require, and build that list into the purchase contract.

The following list can be adapted into an internal approval form. Each item should be supported by a document that the buyer has checked, not merely received.

If your procurement team is preparing a DRC sourcing requirement, you can send the mineral, product form, specification, destination and your documentation expectations to our trade desk. Any discussion remains subject to verification and does not imply availability, price or delivery.