The non-binding MOU between Virtus Minerals and Kennametal for tungsten exploration on DRC concessions is a commercially interesting development that intersects three policy frameworks simultaneously — and the interaction between them will determine whether this agreement progresses beyond a memorandum into an operational mining programme.
The first framework is the US-DRC strategic minerals partnership. Virtus's copper-cobalt acquisition of Chemaf in March 2026 was explicitly positioned as a partnership-framework transaction. The Kennametal MOU extends that narrative into tungsten — broadening Virtus's DRC portfolio story from a copper-cobalt operator into a multi-mineral, US-aligned critical minerals platform. That broadening is commercially valuable for a company whose copper-cobalt execution track record in the DRC has not yet been operationally demonstrated.
The second framework is Dodd-Frank Section 1502. Tungsten from the DRC is explicitly covered by the conflict minerals due diligence requirements that apply to US-listed companies sourcing from the DRC and its neighbours. Kennametal, as a NYSE-listed company, would be required to conduct supply chain due diligence on any Congolese tungsten it sources. The traceability certification infrastructure — the iTSCi programme, OECD-aligned chain of custody systems — that makes Congolese tungsten commercially usable for US industrial companies is real but demanding. Whether the Virtus concessions' tungsten can be developed under a compliant traceability framework, at a cost structure that makes it competitive with Chinese supply, is the central commercial question the MOU does not yet answer.
The third framework is the EU Conflict Minerals Regulation, which covers tungsten from conflict-affected and high-risk areas including the DRC and imposes its own due diligence requirements on EU importers. A Congolese tungsten supply chain that satisfies Dodd-Frank would likely also satisfy EU requirements — but the cumulative compliance cost is real and material.
