Critical Minerals Supplier Due Diligence Checklist (2026)

By Folarin Jackson · 20 October 2026

Most supplier due diligence fails in one of two ways. Either it's a 40-page questionnaire nobody reads, or it's a phone call and a gut feeling. Neither holds up when your bank, your auditor or a customs officer asks how you know where the material came from.

Below is the working checklist we use when vetting suppliers of lithium, cobalt, copper, rare earths, tin, tantalum, tungsten and gold for US and EU buyers. It's organised in the order the checks should happen, so you stop spending money on a supplier the moment one item fails.

Why this matters more in late 2026

Three forces are raising the stakes for buyers right now:

• Export rules at origin are shifting. Ghana now requires gold doré to be refined locally before export under GoldBod offtake arrangements, effective 1 September 2026 (GoldBod). Nigeria is moving to curb raw-mineral exports in favour of processed products (AJOT). A supplier who was compliant last year may not be compliant today.
• China's paused export controls have an expiry date. China suspended six October 2025 export-control announcements, covering rare earths, magnets, lithium-battery inputs and super-hard materials, originally until 10 November 2026. A separate suspension of US-focused dual-use licensing for items such as gallium, germanium, antimony and graphite was set to run to 27 November 2026 (CIRS Group, Clark Hill). At least one report says the first pause has been extended into January 2027, so check MOFCOM's latest announcement before relying on any date. We are not predicting what happens next. The point is that a supplier's upstream exposure to Chinese-origin material is now a due-diligence question, not a background fact.
• US policy is pulling demand onshore. Project Vault, the $12 billion US Strategic Critical Minerals Reserve financed with a $10 billion EXIM loan, is built around OEM purchase commitments (EXIM). Programmes like this come with documentation expectations that flow down to suppliers.

Stage 1: Identity and ownership (do this before anything else)

1. Legal entity confirmed on the official company registry in the supplier's country (for example, Nigeria's Corporate Affairs Commission). Registration number, directors and registered address all match what the supplier sent you.
2. Ultimate beneficial owners identified. Ask for names and percentages down to 25% or lower, and get IDs for each.
3. Politically exposed persons (PEP) check on directors and owners.
4. Bank account name matches the legal entity. Payments to a personal account or a third-party "agent" account are a hard stop.
5. Track record you can verify. Ask for references from past buyers you can independently contact, plus export records if available.

Stage 2: Sanctions, export-control and forced-labour screening

6. OFAC screening of the entity, owners, directors and key staff via the OFAC Sanctions List Search.
7. Consolidated Screening List check (trade.gov), which covers the Commerce Entity List and other export-control lists.
8. EU and UK sanctions lists if you or your customers are EU- or UK-based.
9. Forced-labour exposure. If any part of the supply chain touches Xinjiang or listed entities, the US Uyghur Forced Labor Prevention Act presumes the goods are barred from import unless proven otherwise. Map this before you sign.
10. Rescreen right before each payment, not just at onboarding. Lists change weekly.

Stage 3: Mineral title and right to sell

11. Mining licence or mineral title verified on the government cadastre, not from a PDF. In Nigeria, the Mining Cadastre Office runs a public online cadastre at miningcadastre.gov.ng.
12. Title is active and covers the mineral being sold. Holding a licence for one mineral doesn't let you sell another.
13. Seller-to-title link documented. If the seller isn't the title holder, get the offtake, aggregation or trading agreement that connects them.
14. Export authorisation confirmed for the specific mineral and form (ore, concentrate, doré, refined) under the current rules.

Stage 4: Origin and responsible sourcing

15. Origin documentation is consistent. The certificate of origin, export permit, packing list and assay should all agree on names, weights and dates.
16. Conflict-affected and high-risk area (CAHRA) assessment. Run it under the five-step framework in the OECD Due Diligence Guidance: management systems, risk identification, risk response, independent audit, reporting.
17. Regulatory fit. For tin, tantalum, tungsten and gold, check whether you fall under US Dodd-Frank Section 1502 reporting (via your customers) or the EU Conflict Minerals Regulation (EU) 2017/821 as an EU importer.
18. Site visit or credible third-party verification for any new origin. Desk checks alone are not enough.

Stage 5: Product verification

19. Independent sampling and assay by an inspection company you appoint, with the sample drawn in your inspector's presence and kept sealed.
20. Spec matches contract. Check grade, moisture and penalty elements (for example arsenic in copper concentrate, or uranium and other radioactivity in some cobalt and rare-earth material).
21. Radioactivity screening where relevant, for monazite and other rare-earth feedstocks, some tantalum ores, and cobalt hydroxide.

Stage 6: Logistics and payment structure

22. Incoterms agreed in writing, with title and risk transfer points clearly defined.
23. Warehouse or port receipts verified directly with the warehouse or port operator, not through the seller.
24. Payment against performance. That means a letter of credit, escrow, or payment on inspection or outturn. No advance fees for "clearance," "insurance," "certificates" or "release."
25. Price sanity check. If the discount to the published benchmark is far deeper than logistics, treatment and financing costs can explain, find out why before you go further.

How to use this checklist without drowning

• Gate it. Stage 1 and Stage 2 failures end the conversation. Don't pay for inspection until Stages 1–3 pass.
• Keep a file. Save a dated screenshot or PDF for every check. Your auditor, bank or customer cares less about what you believe than about what you can show.
• Assign an owner. One named person signs off each stage. Shared responsibility usually means nobody checks.
• Re-verify on change. A new origin, a new bank account or a new intermediary means rerunning Stages 1–3.

The one thing to do today

Pick your highest-volume critical-minerals supplier and run checks 6, 7 and 11: OFAC, the Consolidated Screening List, and a direct cadastre lookup of their title. It takes under an hour. If any of the three surprises you, you've found your biggest supply-chain risk.

If you want this done for you, see how we verify counterparties in our sample verification report, or run a live offer through our free Check a Deal for Red Flags tool. For a gold-specific walkthrough, read How to Verify a Gold Doré Seller.

Frequently Asked Questions

What is supplier due diligence for critical minerals?

It is the documented process of confirming that a supplier is who they say they are, is legally allowed to sell and export the material, is not sanctioned or linked to forced labour or conflict financing, and can deliver product that matches the contract. It is usually structured around the OECD Due Diligence Guidance.

What are the OECD five steps of due diligence?

Establish strong management systems, identify and assess supply-chain risks, design and carry out a strategy to respond to those risks, carry out independent third-party audits at identified points in the supply chain, and report publicly on supply-chain due diligence.

Which sanctions lists should a US minerals buyer check?

At minimum, the OFAC Sanctions List Search and the US Consolidated Screening List, which combines Commerce, State and Treasury export-control and sanctions lists. EU and UK lists apply if you or your customers operate there. Rescreen before each payment.

How long does critical minerals supplier due diligence take?

Desk-based identity, sanctions and title checks can often be done in days if the supplier cooperates. Site visits, independent assays and OECD-style risk assessments for a new origin take longer. A supplier who resists basic checks is giving you an answer.

Do small buyers need to follow the OECD guidance?

The guidance applies to any company potentially sourcing minerals from conflict-affected and high-risk areas, whatever its size. Even when it isn't legally required, banks, refiners and downstream customers increasingly expect it.

Get a second set of eyes before you commit capital

Aurefield Global Resources combines West Africa sourcing relationships with Western compliance discipline (OECD, OFAC, KYC/AML). We verify suppliers, title and product so procurement and compliance teams can move with confidence. Book a consultation or see our sourcing and verification services.

This checklist is general information, not legal advice. Confirm current requirements with counsel and the relevant authorities.