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What to ask a seller for a mineral asset .
Eight groups, from title at the ANM to the transaction, each item with the rule or code that asks for it.
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How to use this list# Tick each item as the document is located; the ticks stay in your browser and are sent to no one. Use the clear button to start over and the browser's print function to take the list to the meeting. This is the list of the buyer and the Competent Person : it describes what is usually requested and where the rule or code asks for it. It is not a promise that an asset meets it, nor a technical report, nor legal advice.
References to JORC 2012 Table 1 use the criterion name, because the code does not number its criteria. Numbered clauses (cl. 17, 20, 29, 38 and so on) are those of the 2012 text; a new edition is being finalised. Items marked as market practice or secondary source are not rules.
A. Mining title and ownership ANM process number, current stage (application, exploration permit, final report, mining application, concession) and registered holder, with the process extract and the polygon checked in SIGMINE. Mining Code, art. 22, III (permit of up to 4 years); Decree 9,406/2018, arts. 25, 28 and 33; SIGMINE (ANM) Area in hectares, permit term and any extension used or pending; final report filed within the term. Mining Code, art. 22, III; Decree 9,406/2018, art. 25 (failure to file: title is cancelled) Status of the TAH (annual per-hectare fee) and, where applicable, the RAL (annual mining report): proof of payment and filing. Mining Code, art. 20, II; Decree 9,406/2018, art. 47 (TAH); RAL: gov.br/anm (deadlines 15 March and 31 March) Encumbrances, assignments and agreements recorded (averbados) at the ANM (full or partial assignment, encumbrance, security); confirm each act is recorded. A purchase option is not an act of alienation: it is not recorded and does not change the holder. Decree 9,406/2018, arts. 42 and 44; Mining Code, art. 55, §1 (concession) Transferability of the right: a research application, a licence registration and a PLG are not assignable. DNPM Ordinance 155/2016, art. 224, §3 Agreement with the surface owner and an up-to-date land registry entry (the surface is distinct from the mineral right), with property encumbrances and access agreements. Mining Code (relationship with the surface owner); JORC 2012, Table 1, Section 2, Mineral tenement and land tenure status Holder incorporated under Brazilian law, with head office and management in Brazil; rural land acquisition by foreign capital is subject to Law 5,709/1971. Constitution, art. 176, §1; Law 5,709/1971 If under the licensing regime (Law 6,567/78): municipal licence and ANM registration; area of up to 50 ha; the holder is the landowner or whoever the landowner authorises. Law 6,567/1978, arts. 1 to 3 and sole paragraph of art. 1 B. Licensing and restrictions Environmental licences in progress or issued (LP, LI, LO) and proof that licensing was filed; the environmental licence is presented before the mining concession is granted. Decree 9,406/2018, art. 31; ANM Summary 16 (six-monthly proof). The LP, LI, LO sequence: practice described in a secondary source Overlap with conservation units, indigenous lands and heritage areas: spatial check and certificate from the competent body. No clause confirmed in this review; JORC 2012, Table 1, Section 2, Mineral tenement and land tenure status (mentions national parks and historical sites) Border strip (150 km): check whether the area falls within it and the holder's capital structure. Constitution, art. 176, §1; Law 6,634/1979 (government reading on foreign capital: secondary source) Known impediments to obtaining a licence to operate and the timeline of open requirements. JORC 2012, Table 1, Section 2, Mineral tenement and land tenure status (security of tenure and impediments) Mine closure plan in the PAE and, if there is a dam, its design and emergency action plan. Decree 9,406/2018, art. 32; Law 14,066/2020 (dams) C. Sampling and drilling Sampling techniques, representativity and calibration of instruments (pits, auger, core, reverse circulation, handheld XRF). JORC 2012, Table 1, Section 1, Sampling techniques Drill type and details (diameter, core orientation); sample recovery and any relationship between recovery and grade. JORC 2012, Table 1, Section 1, Drilling techniques; Drill sample recovery Geological and geotechnical logging to a level that supports estimation, mining and metallurgical studies; photography and logged length. JORC 2012, Table 1, Section 1, Logging Preparation and sub-sampling: field duplicates, control at each stage, sample size suited to grain size. JORC 2012, Table 1, Section 1, Sub-sampling techniques and sample preparation Laboratory and QA/QC: partial or total method, standards, blanks, duplicates and external laboratory checks, with accuracy and precision demonstrated. JORC 2012, Table 1, Section 1, Quality of assay data and laboratory tests Database integrity: twinned holes, primary-data documentation, entry, storage, assay adjustments and validation against transcription errors. JORC 2012, Table 1, Section 1, Verification of sampling and assaying; Section 3, Database integrity Collar survey and down-hole survey (deviation), grid system and topographic control. JORC 2012, Table 1, Section 1, Location of data points Data spacing and compositing, orientation relative to structure, chain of custody (sample security) and previous audits. JORC 2012, Table 1, Section 1, Data spacing and distribution; Orientation of data in relation to geological structure; Sample security; Audits or reviews Bulk density: assumed or measured, method, frequency, and whether it accounts for voids, moisture and alteration zones. JORC 2012, Table 1, Section 3, Bulk density (Section 1 has no density criterion) D. Exploration results and exploration target Table of material drill holes: collar easting, northing and elevation, dip, azimuth, hole length and intercept depth. JORC 2012, Table 1, Section 2, Drill hole Information Aggregation methods: weighted averages, high-grade cutting, cut-off grade and the assumptions behind any equivalent value. JORC 2012, Table 1, Section 2, Data aggregation methods True width, or a statement that only down-hole length is known; maps and sections with scale. JORC 2012, Table 1, Section 2, Relationship between mineralisation widths and intercept lengths; Diagrams Balanced reporting, other material data (geophysics, geochemistry, bulk samples, metallurgical tests, contaminants) and planned further work. JORC 2012, Table 1, Section 2, Balanced reporting; Other substantive exploration data; Further work Exploration by other parties acknowledged and appraised, including historical estimates, with source, date and category differences. JORC 2012, Table 1, Section 2, Exploration done by other parties; ASX Listing Rules, 5.12 Exploration Target stated as a range of tonnes and a range of grade, without the terms Resource or Reserve, with a cautionary statement. JORC 2012, cl. 17 E. Resource estimation Geological interpretation, dimensions, factors affecting grade and geological continuity, effect of alternative interpretations. JORC 2012, Table 1, Section 3, Geological interpretation; Dimensions Estimation method: domaining, treatment of extreme values, interpolation, software and parameters, block size relative to sample spacing, model validation against drill holes. JORC 2012, Table 1, Section 3, Estimation and modelling techniques Cut-off grade or quality parameter and its basis; moisture (dry or natural basis). JORC 2012, Table 1, Section 3, Cut-off parameters; Moisture Reasonable prospects for eventual economic extraction (RPEEE): mining, metallurgical and environmental assumptions, even if preliminary. JORC 2012, cl. 20; Table 1, Section 3, Mining factors or assumptions; Metallurgical factors or assumptions; Environmental factors or assumptions Classification into Inferred, Indicated and Measured, with an explicit basis and the Competent Person's view; audits of the estimate; relative accuracy. JORC 2012, cl. 20 to 24; Table 1, Section 3, Classification; Audits or reviews; Discussion of relative accuracy/confidence Site visit by the Competent Person and its outcome, or why none took place. JORC 2012, Table 1, Section 3, Site visits Final Exploration Report (RFP) using the ANM Res. 94/2022 concepts (exploration potential; Inferred, Indicated, Measured resource), prepared by a qualified professional. An earlier RFP uses old categories that are not equivalent to CRIRSCO's. ANM Resolution 94/2022, arts. 4 and 5 F. Metallurgy and mineralogy Assumptions or tests of metallurgical amenability and recovery factors, with the nature, amount and representativeness of the tested sample. JORC 2012, Table 1, Section 3, Metallurgical factors or assumptions; Section 4, Metallurgical factors or assumptions Ionic clay (rare earths): desorption test and heavy rare earth fraction (Tb, Dy) in the concentrate. USGS MCS 2026, Rare Earths (Heavy). Desorption testing as technical practice: secondary source Carbonatite and pyrochlore (niobium): mineralogy, grain size of the ore mineral and processing route. USGS MCS 2026, Niobium (resources as pyrochlore in carbonatite) Deleterious elements and, for minerals defined by a specification, mineralogy that meets it. JORC 2012, Table 1, Section 4, Metallurgical factors or assumptions Bulk sample or pilot-scale test work and its representativeness; exceptional extraction before the concession requires a Guia de Utilização (utilisation permit). JORC 2012, Table 1, Section 4, Metallurgical factors or assumptions; Decree 9,406/2018, art. 24; ANM Res. 37/2020 G. Studies and reserves Level of study supporting the conversion: pre-feasibility or feasibility. A Scoping Study cannot support a Reserve. JORC 2012, cl. 29, 38, 39 and 40; Table 1, Section 4, Study status Resource used as the basis for conversion and a statement that it is inclusive of or additional to the reserves. JORC 2012, cl. 36; Table 1, Section 4, Mineral Resource estimate for conversion to Ore Reserves Modifying Factors: mining, dilution and recovery, metallurgy, infrastructure, costs, revenue, market, economic and social. JORC 2012, cl. 29; Table 1, Section 4, Mining factors or assumptions; Costs; Revenue factors; Market assessment; Economic; Social Use of Inferred resources in mining studies and sensitivity of the outcome to their inclusion. JORC 2012, Table 1, Section 4, Mining factors or assumptions Economic Development Plan (PAE) of the mining application, using the ANM Res. 94/2022 concepts. Decree 9,406/2018, art. 32; ANM Resolution 94/2022, art. 4 Critical government approvals, legal and marketing agreements, and reasonable grounds to expect them within the study timeframe. JORC 2012, Table 1, Section 4, Other H. Transaction Data room organised by this list, with an index, dated versions and an owner for each document (market practice). Market practice, no specific rule Technical and legal vendor due diligence, delivered to the buyer with the Competent Person's report and disclosure of the CP's relationships (market practice). Market practice; JORC 2012, cl. 9 (disclose relationships and conflicts) Assignment: instrument, assignee requirements and recording at the ANM; without recording the act has no validity for a concession. Decree 9,406/2018, arts. 42 and 44; Mining Code, art. 55, §1 Option phase: not recorded and does not change the holder; after the RFP is approved there is 1 year, extendable, to apply for mining, and negotiation is allowed. Decree 9,406/2018, art. 28 Consideration held in escrow until recording, with conditions precedent and deadlines (market practice). Market practice, no specific rule Listed buyer reporting an estimate under another code or a historical one: source, date, category differences and verification programme. ASX Listing Rules, ch. 5, 5.12 NI 43-101 (Form 43-101F1) has its own items on data verification and on sample preparation, analyses and security; this list does not map them by number. None of the codes requires the Competent Person to be independent, except in specific cases (for example ASX LR 5.16.6); independence is the buyer's choice.
Technical and informational content, reviewed on 24 Sep 2026. It is not legal advice, an investment recommendation, an offer of securities, or a technical report by a Competent or Qualified Person. Always confirm against the rule in force and with your advisers.