Every question about our practice, answered.

The Strategic Asset Reserve is the SPA's core investment mechanism. The DRC designated an initial list of critical-mineral assets, gold assets, and unlicensed exploration areas. Under Article VII, US persons hold the right of first offer on these assets before aligned or non-aligned persons can compete.

The process runs on strict clocks. Three months to submit a proposal once the DRC notifies the Joint Steering Committee of the opportunity. A three-month negotiation window, renewable once. A maximum of nine months from notification before aligned persons, including qualifying Congolese persons, gain the right to submit.

These clocks are running now. If your organization has any interest in DRC mineral assets, your SAR positioning is time-sensitive.

A Qualifying Strategic Project is a DRC project not majority-owned by the DRC or its state-owned enterprises that meets every criterion in Annex 1 of the SPA. A project becomes a QSP on notification to the Joint Steering Committee, by either Party or by the US Ambassador. Meeting the criteria is necessary. Notification is the operative step.

Annex 1 sets conditions across ownership, offtake, and project type. All must be met.

Ownership. Either at least 51 percent equity held by a US person or persons, or at least 40 percent held by US or aligned persons together with effective control over project governance, meaning a board majority or veto rights over strategic decisions, or guaranteed critical-mineral offtake rights.

The equity cap most investors miss. Separately from the ownership condition, no more than 40 percent of project equity may be held by anyone outside the US-person or aligned-person definition. That ceiling drops to 30 percent five years after entry into force, 20 percent at ten years, and 10 percent at twenty. If your DRC project has non-aligned co-investors, your position against that ratchet is a structuring question you need answered now, not at renewal.

One discretionary path. Annex 1 allows the Parties to permit a higher non-aligned ownership percentage for projects evaluated in a given year. It is a narrow door and it is not automatic, but it exists, and most investors do not know it does.

Offtake. The project must meet the JSC's offtake guidelines, or demonstrate to the JSC how its offtake advances the Agreement's objectives, and must be designed so that exported critical-mineral offtake moves on the Lobito Corridor rail infrastructure where geographically feasible. A project that clears the ownership test and fails the offtake test is not a QSP.

SAR is about securing new assets. QSP is about structuring an existing or target investment to qualify for SPA protections and fiscal incentives. They are complementary, not interchangeable.

Yes, and the definition matters more than most investors assume.

The SPA extends benefits to aligned persons. An aligned person is a non-US person that is not a national of a covered nation, not an entity organized under the laws of a covered nation, not an entity owned one third or more, directly or indirectly, by covered-nation nationals or entities, and not an entity in which covered-nation nationals hold the chief executive position or can appoint or remove one third of the board or otherwise direct its vote. Covered nations are defined by 10 U.S.C. 4872(f)(2): principally China, Russia, Iran, North Korea, Cuba, and Venezuela.

The practical consequence: a European, Canadian, Australian, or Japanese company can fail the aligned-person test on a shareholding or a board composition it has not examined in this light. The threshold is one third, not a majority. Aligned persons gain access to the SAR investment process, QSP fiscal incentives, and Lobito Corridor treatment. Non-aligned persons do not.

We serve clients from any jurisdiction with legitimate DRC exposure, and eligibility screening is usually the first thing we run.

Yes, and this is one of the most misunderstood provisions in the entire framework.

Congolese nationals and Congolese-registered companies are not excluded from the SPA. Article VII expressly contemplates DRC persons who meet the aligned-person definition in Annex 2 entering the SAR process. A Congolese entity that is not one-third-or-more owned or controlled by covered-nation interests can qualify as an aligned person and participate alongside US and other aligned investors.

We offer an Aligned Person Eligibility Assessment for Congolese operators who need to understand their positioning, what ownership structuring the definition may require, and which SAR assets or Designated Strategic Projects are most relevant. We also provide SPA analysis for Kinshasa-based law firms whose clients are asking SPA questions the firm is not yet equipped to answer in-house.

Three things.

Exclusive SPA specialization. We work only on the US-DRC Strategic Partnership and its direct implications. Not generic Africa advisory. Not emerging-markets consulting. Not extractive-sector consulting broadly. Every framework we have built serves one purpose: making your DRC engagement under the SPA succeed.

Depth over breadth. We produce analysis that is verified, not estimated. Every claim carries a confidence rating. When we do not know something with sufficient certainty, we say so, in the deliverable, in writing.

Timing. The Joint Steering Committee is operational. The SAR list is live. The twelve-month reform clock is running. The window for first-mover positioning is measured in months.

No. We maintain strict independence from all governments, political parties, commercial interests, and advocacy organizations. We advise clients on navigating the DRC's political landscape. We do not serve it.

We hold working relationships with DRC government officials, ministry staff, and state-enterprise leadership. These relationships are sources of context, not mandates. Our advice serves client interests exclusively.

Paris is the primary base, with regular travel to Kinshasa for client engagements, source relationships, and stakeholder meetings.

Paris is deliberate. The decision chain on a major DRC transaction does not sit in one capital. Kinshasa sets the terms. The financing, the diplomatic positioning, and the corporate approvals run through Paris, Brussels, Washington, and London. Being Europe-based with a working Kinshasa presence puts us on both ends of that chain rather than one.

With a phone call, not a proposal. We run a thirty-minute diagnostic conversation to understand your situation, your timeline, and whether our work is the right fit for what you need. If it is, we scope a proposal from that conversation. If it is not, we tell you directly.

We do not send generic capability decks to cold inquiries. Every proposal is scoped against a specific need.

Professional advisory fees only, as project fees or monthly retainers. We do not take equity stakes, success fees, profit participation, or any form of performance-linked compensation. That structure exists so that our analysis serves your interests and nothing else.

No. We provide analysis and advisory, not deal origination, project development, or investment facilitation. We help you assess opportunities you have identified, understand the political and regulatory dynamics around them, navigate stakeholder complexity, and manage risk. The assessment is analytical. The decisions remain yours.

Yes, depending on capacity. Our primary focus is the US-DRC Strategic Partnership, but DRC advisory needs do not always map neatly onto a single framework. A political-risk question, an operator background check, a conflict-zone assessment that sits outside the strict SPA perimeter: we consider it against what we are already running.

We are a capped-capacity practice by design. If we are at or near capacity, we tell you directly and either refer you or propose a timeline when we can engage properly. We do not overcommit.

Yes, for all client engagements. Confidentiality is standard. We also maintain strict information barriers between clients operating in overlapping sectors or geographies.

Yes. We hold three collaboration models for firms that need DRC and SPA expertise on a client engagement.

• Subcontractor. We deliver under your brand.
• Acknowledged partner. Co-delivery with dual credit.
• Referral. You introduce the client, we serve them directly, with credit to your firm.

Flexible on structure. Inflexible on quality.