Case Studies

In Q4 2024, ONGOLO received an urgent call from an African Ambassador based in Asia. A foreign buyer was in advanced discussions to purchase copper cathodes from a company claiming to operate in Zambia, but something felt off. The buyer had been unable to conclusively verify the seller’s legitimacy, despite being presented with a full set of professional-looking documents. The transaction value—just under USD 20 million—sat in a grey zone: material enough to matter, yet small enough to evade the scrutiny of global compliance teams.

On paper, the deal looked sound. The seller had shared a signed sales and purchase agreement on letter-headed paper, provided bank details, company registration information, and a mineral analysis certificate purportedly issued by the Zambian Ministry of Mines. For many counterparties, that would have been sufficient. In African extractives, it rarely is and buyers should be vigilant.

Was the seller a real company?

The first step was to confirm whether the company legally existed. A search through Zambia’s corporate registry, the Patents and Companies' Registration Agency (PACRA), showed that it was indeed registered. However, the trail quickly grew cold. The company had failed to file financial statements since its first year of incorporation and was technically non-compliant. Its registered business classification was logistics, not mining. While weak enforcement in Zambia means such gaps are not uncommon, they are rarely accidental.

Reviewing the company's digital footprint

Attention then turned to the company’s digital footprint. At first glance, it inspired confidence. The website was slick, filled with language about ethical sourcing and responsible mining, and even claimed experience in exploration and processing. Yet closer inspection revealed inconsistencies. The company described itself as being based in the Democratic Republic of Congo rather than Zambia, despite being registered in Zambia.

There was no meaningful information about the individuals behind the business—no directors, no management team, no ownership structure. The firm also appeared on commercial databases, reporting seven-figure dollar revenues and listing the same individual named on the sales agreement. The presence of data, however, did not equate to credibility.

How ONGOLO used its local network to uncover the truth

In Zambia, the absence of public information about company principals is not unusual. Many businesses operate with minimal transparency, and entire sectors are populated by entities with little visible human footprint.

Ordinarily, this is where ONGOLO would activate local networks in the city where the company claims to operate—lawyers, bankers, miners, and fixers who know who is real and who is not. In this case, another route proved faster.

With no audited financials available, the next question was whether the company’s claimed revenues made sense. Informal intelligence remains one of the most powerful verification tools in African markets, and bankers are often the most reliable sources of commercial truth. Without breaching confidentiality, a simple question was posed to trusted contacts: does this company’s account activity resemble the level of turnover it claims? The answer was unambiguous. It did not.

The smoking gun

The final and decisive test lay in the mineral documentation. The analysis and valuation certificates were shared directly with a senior official at the Ministry of Mines, followed by a phone call to walk through them together. The response was immediate and verified by a second official hours later. The documents were clearly forged.

The certificate templates were outdated and no longer in use, key information—such as the source of the mineral samples—was missing, and the valuation certificate was signed by an official who had retired years earlier.

Ironically, the current Director reviewing the documents was the person whose signature should have appeared on them. To complete the illusion of legitimacy, the sellers had also provided a tax clearance certificate from the Zambia Revenue Authority. That too was fake. The Ministry informally confirmed that none of the mineral documents were genuine.

The seller was encouraged to speak to formally file a complaint with the Ministry which would enable to them to launch a criminal investigation but they chose to simply walk away.

Lessons learnt

The lesson from this near-miss is simple but often forgotten. In many African markets, paper is easy to manipulate, systems are fragmented, and enforcement is uneven. Trust does not flow from documents alone. It flows from people. Local knowledge, informal verification, and trusted relationships remain indispensable—particularly in high-value sectors such as mining.

ONGOLO exists precisely to bridge this gap. By combining formal checks with on-the-ground intelligence, we help clients navigate complexity, avoid fraud, and transact with confidence. In African commodity markets, relying solely on what is written can be costly. Relying on who knows whom is often what saves the deal.

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