Operator, counterparty, and jurisdiction screening against public sanctions lists for the worked decision-set assets. Screen date 23 Jun 2026. Method: named-entity search against OFAC SDN / Consolidated lists and public reporting; not an exhaustive 50%-rule ownership trace. A "no match" is a screening result, not a clearance guarantee.
DRC — designated-network context (jurisdiction-level, not asset-level). The Dan Gertler network — 46 designated entities/individuals incl. Ventora Development Sasu and Fleurette Properties (a.k.a. Ventora Mining) — was designated under E.O. 13818 (Global Magnitsky) across Dec 2017, 2018 and Dec 2021; a January 2021 OFAC licence was revoked March 2021. No de-listing has been confirmed as of the 23 Jun 2026 screen date, and the OFAC designation entry persists — but a de-listing was reported under active discussion in 2025 (secondary: Bloomberg, Jul 2025). Sanctions status is volatile: re-verify against the live OFAC SDN list before any reliance.
Diligence implication, not an allegation: DRC mining counterparty chains warrant enhanced due diligence and OFAC 50%-rule checking. This flag is jurisdiction context. Afrimintel makes no claim that Ivanhoe Mines, AVZ, Zijin, KoBold, or any named operator of Manono or Kamoa-Kakula is connected to the Gertler network; no such link is asserted absent primary-source verification.
Source: U.S. Treasury press releases (Dec 2017; 2018; Dec 2021), U.S. State Dept licence-revocation notice (Mar 2021), Federal Register 2021-26852. De-listing-discussion item: secondary (Bloomberg via public reporting, Jul 2025) — Watch.
Hosts: Loulo-Gounkoto, Goulamina. Transitional-government era carries targeted-measures and security context that may bear on counterparty screening. Not screened this pass — held Absent pending a dedicated verification against OFAC / EU / UK lists and current Mali measures. Do not assert a Mali sanctions position until sourced.
Tanzania (Kabanga), Botswana (Motheo), Mozambique (Balama): no elevated jurisdiction sanctions flag identified in this screen.
| Asset | Named operator(s) | Jurisdiction | Screen result (23 Jun 2026) | State |
|---|---|---|---|---|
| Kabanga | Lifezone Metals | Tanzania | No OFAC SDN designation identified (named-entity screen) | Sourced |
| Motheo | Sandfire Resources | Botswana | No OFAC SDN designation identified | Sourced |
| Loulo-Gounkoto | Barrick Mining | Mali | Operator: no SDN designation identified. Jurisdiction: see Mali · Verify | Sourced / Absent |
| Manono | AVZ / Dathcom; Zijin Mining; KoBold | DRC | Operators: no SDN designation identified. Jurisdiction: DRC · Elevated (above) | Sourced |
| Kamoa-Kakula | Ivanhoe Mines; Zijin Mining | DRC | Operators: no SDN designation identified. Jurisdiction: DRC · Elevated (above) | Sourced |
| Balama | Syrah Resources | Mozambique | No OFAC SDN designation identified | Sourced |
| Goulamina | Leo Lithium / Ganfeng | Mali | Operators: no SDN designation identified. Jurisdiction: see Mali · Verify | Sourced / Absent |
Beneficial ownership (UBO): full UBO traces (UK PSC / EU UBO registers, 50%-rule cascade) are Absent this pass — scoped as the next ingestion step. The screen above is operator-name level only.
A per-asset synthesis combining the Sourced ownership chain (/ownership/) with the sanctions screen above and the remaining integrity inputs. Three states only: clean flagged unknown. Verdict logic — clean = ownership Sourced AND no sanctions match across OFAC+EU+UN+UK AND UBO cascade complete AND licence-allocation Sourced AND no integrity event; flagged = any positive sanctions match OR a documented unresolved licence-integrity event; unknown = any required input Absent. The OFAC 50%-rule is not applied this pass, so a 50%-rule-only exposure surfaces as unknown, not flagged.
Not a clearance. A clean read is not a sanctions or compliance clearance and creates no reliance — see the not-a-compliance-tool statement below. Screen currency is 23 Jun 2026; the volatile items (DRC OFAC designation status, Tanzania EITI) carry re-verify and have not been re-checked since that date.
| Asset | Ownership chain | Sanctions (23 Jun) | Inputs still Absent | Jurisdiction / licence event | Integrity read |
|---|---|---|---|---|---|
| Kabanga | Sourced /ownership/ | OFAC no-match Sourced | EU/UN/UK screen · full UBO · licence-allocation Absent | Tanzania EITI enhanced-scrutiny re-verify | unknown |
| Motheo | Sourced /ownership/ | OFAC no-match Sourced | EU/UN/UK · full UBO · licence-allocation Absent | none identified | unknown |
| Balama | Sourced /ownership/ | OFAC no-match Sourced | EU/UN/UK · full UBO · licence-allocation Absent | none identified | unknown |
| Loulo-Gounkoto | Sourced /ownership/ | operator no-match; Mali regime Absent | EU/UN/UK · full UBO · licence-allocation Absent | 2023 Mining Code dispute — resolved Nov 2025 (settlement; permit renewed). Public-record event, surfaced. | unknown |
| Goulamina | Absent not on /ownership/ | operator no-match; Mali regime Absent | ownership chain · EU/UN/UK · full UBO · licence-allocation Absent | Mali · verify (see above) | unknown |
| Manono | Absent not on /ownership/ | operators no-match (OFAC) | ownership chain · EU/UN/UK · full UBO · licence-allocation Absent | DRC — see jurisdiction context above | unknown |
| Kamoa-Kakula | Sourced /ownership/ | operators no-match (OFAC) | EU/UN/UK · full UBO · licence-allocation Absent | DRC — see jurisdiction context above | unknown |
Read of the read. No asset reaches clean: licence-allocation provenance, full UBO cascade, and multi-regime (EU/UN/UK) screening are Absent platform-wide. No asset is flagged: no operator returned a positive sanctions match. The DRC and Mali entries are jurisdiction context, not asset-level flags. Absence of a flag is not "clean" — an unknown read means a required input has not yet been completed, not that integrity is in question.
Path to clean (ingestion roadmap). Each read moves off unknown as inputs are pulled and dated: EU/UN/UK re-screen; OFAC 50%-rule UBO cascade (UK PSC / EU UBO registers); licence-allocation provenance per national cadastre + EITI contract disclosure. COI discipline: Rwanda excluded; DRC surfaced as public-record fact only, no editorial overlay.
Method & limits (stated, not hidden). This is a named-entity screening pass against public OFAC lists and reporting, dated 23 Jun 2026. It is not an exhaustive ownership-chain trace, does not apply the OFAC 50% rule across full corporate structures, and does not screen UK/EU/UN lists comprehensively this pass. "No match identified" means no designation surfaced for that name on this date — it is a screening result, re-run on cadence, never a legal clearance.
Not a compliance tool. This surface is decision-support context, not a sanctions-compliance or legal-screening tool and not a substitute for an institution's own screening. Do not rely on it for compliance, onboarding, or transaction decisions. Afrimintel accepts no liability for reliance — run your own screening of record.
Regime scope this pass: OFAC only. EU consolidated, UN, and UK (OFSI) lists are Absent this pass — material for EU/UN/UK-mandated institutions (EBRD, EIB, AfDB, World Bank). Multi-regime screening is sequenced.