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.

One subject, covered in depth: the US-DRC Strategic Partnership and the reform, reserves and corridor questions inside it. The work is organised as five asset classes rather than as an undifferentiated feed.

Explainers answer a structural question once and are maintained as the answer changes. They are open to everyone. Analysis is a dated judgement on a live development. Dossiers are living files on a single subject, such as the Lobito Corridor, updated as the file moves. Registers are structured, searchable records: the SAR Registry, the CAMI Registry, the Regulatory Reform Tracker, the SPA Glossary and the DRC Sovereign and Institutional Rating. Briefings are private sessions, described below.

The distinction matters because the asset classes carry different obligations. An Explainer is expected to be current. A Dossier is expected to be complete. A Register is expected to state the date of the sources it reflects.

The Friday Brief, weekly. Analysis when a development warrants it rather than on a schedule, because a manufactured cadence produces filler.

Registers are updated when their underlying sources move, and each states the date of the sources it reflects and its next scheduled review. Dossiers are versioned, with the version and date at the head of the file.

Every substantive claim carries an explicit confidence indication: HIGH, MED-HIGH, MEDIUM or LOW. The rating describes the state of the evidence, not our enthusiasm for the conclusion.

HIGH means the claim rests on a primary document or a corroborated official record. MEDIUM means credible reporting we have not been able to close against a primary source. LOW means a signal worth recording that we would not act on. Where a claim is contested or unestablished, it is published as contested, not quietly upgraded.

Vintage is the date of the sources a piece reflects, which is not the date you read it. Congolese official data carries real reporting delays, so a register consulted in October may faithfully reflect a cadastre extract from July.

Stating vintage is how a reader knows what a finding can and cannot bear. No register substitutes for direct consultation of the competent official registers.

Identified public sources: treaty and annex text, official journals and gazettes, cadastre and company registry extracts, court and arbitration filings, disclosure documents, multilateral and UN panel reporting, and named press. Claims are checked against the primary document rather than against secondary coverage of it.

Confidential information provided by an advisory client never appears in published work. See the independence section below.

Short quotation with attribution and a link is welcome. Bulk extraction is not.

The registers are a protected database. Extracting a substantial part of a register, or building a derived database from one, requires written authorisation. Reasonable internal use by a licensed subscriber, including consultation, search and occasional extraction of non-substantial items for your own work, is permitted. The provisions are set out in full in the Terms of Service.

A small named desk across Washington, Paris and Kinshasa. Every piece carries a named analyst, a location and a stated confidence. Analyst profiles are published, and each lists the pieces that analyst signed.

Some pieces carry the desk collectively rather than an individual. That happens where a finding rests on sourcing several analysts contributed to, or where naming one analyst would narrow the protection we extend to a source. Desk pieces meet the same evidentiary standard.

Private Monday evening sessions, off the record, held for a vetted group. They are invitation-only and are not a public events programme.

Enterprise subscribers receive priority consideration. If a session is relevant to your mandate, raise it on a call.

The full Explainer library and the US-DRC Partnership hub are open to everyone, permanently, with no account. They are the structural grounding on the partnership and we would rather they be read than gated.

A subscription begins at the Friday Brief, which every paying tier receives in full. What separates the tiers above that is depth: Analysis in full, the Dossiers, the Registers and the archive sit at Professional, because that is the layer you work from when an asset is exposed rather than the layer you read to stay current.

Analysis pieces show an opening extract before the paywall, so you can judge a piece before you buy it.

Essential, €50 a month or €500 a year. The Friday Brief in full, the SPA Glossary in full, the opening extract of every Analysis piece, email delivery each Friday, a saved reading list and a single seat. Enough to stay current on the partnership.

Professional, €200 a month or €2,000 a year. Everything in Essential plus all Analysis in full, all Dossiers, the SAR Registry, CAMI Registry, Reform Tracker and the DRC Sovereign and Institutional Rating, per-entity profiles inside every register, and the full searchable archive. The reference layer you work from when an asset is exposed.

Enterprise, custom. Everything in Professional plus seats across your organisation, a named analyst you can reach directly, licensed data export from the registers, priority consideration for the Briefings, invoicing on your procurement terms and onboarding. Priced by headcount and arranged in a conversation, never a public checkout.

Full detail sits on the Subscribe page.

In your account, at any time, on monthly or annual billing alike. Access continues to the end of the period you have paid for and does not renew. There is nothing to phone about and no retention script.

Consumer subscribers in the EU also have a fourteen-day right of withdrawal, subject to the digital-content conditions set out in the Terms of Service.

Seats are personal and named. Essential and Professional are single-seat, and credentials are not to be shared.

If several people in your organisation need access, that is an Enterprise arrangement, and it is usually cheaper than the workaround. Tell us how many seats and we will quote.

No trial and no purchase by the article. The open Explainer library and the opening extract on every paid piece exist so that you can assess the work without one.

If you need to see a specific kind of output before committing an institutional budget, ask on a call and we will point you at the closest published example.

Yes, through Enterprise. Multi-seat access for a team, a department or a library is arranged directly, including invoicing on your procurement terms rather than by card.

Because the wall runs in both directions, and both directions are written into our terms rather than left to trust.

Confidential information provided by an advisory client never appears in published work. Published analysis is prepared exclusively from identified public sources.

Conversely, an advisory engagement confers no right of review, no priority of access, and no right to delay or withdraw any publication or rating. A client cannot see a piece before publication, cannot soften it, and cannot stop it. If that is a condition of the mandate, we are the wrong firm.

No. They do not constitute credit ratings within the meaning of Regulation (EC) No 1060/2009. We are neither registered nor certified as a credit rating agency and do not carry on that activity.

They measure neither probability of default nor the credit quality of any issuer, debt, security or instrument, and must not be used for regulatory, prudential or valuation purposes. A rating is a reasoned analytical opinion at a stated date, against a published methodology.

No. We receive no remuneration from rated entities, and no publication, rating or publication schedule is subject to any consideration.

The publication is funded by subscribers. The advisory practice is funded by clients under signed scopes of work. Neither buys an editorial outcome.

Write to [email protected], identifying the content and the passages you contest. We acknowledge receipt and respond within the applicable legal time limits.

Where a correction is established, it is published visibly and dated. We do not quietly amend. A right of reply is available on the same terms, and it does not require a lawyer to invoke.

No. It is analysis and information. It is not investment, legal or tax advice and it is not a recommendation to enter into any transaction. We are not a law firm.

Reading it creates no advisory or client relationship and no duty on us to alert you individually. An advisory engagement begins only under a signed scope of work following a diagnostic call.

A subscription gets you the analysis: what is happening, on what evidence, at what confidence. An engagement gets you the answer to your question, on your asset, on your timeline, including the parts we would never publish.

Most institutional readers start with a subscription and commission when a specific exposure needs closing. If you are unsure which you need, start with the call. If a subscription would serve you better than a mandate, we will say so.

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.