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The architecture of exclusion: critical minerals geopolitics and the November 2026 deadline
On 9 October 2025, China's Ministry of Commerce published its second critical minerals export control package of the year. The package extended licensing requirements to five additional rare earth elements (holmium, erbium, thulium, europium, and ytterbium), brought refining and magnet-manufacturing equipment within scope, and codified an extraterritorial dimension that applies Chinese regulatory authority to foreign-made products incorporating Chinese material or processing
Alvaro Antoni
May 15


Venezuela's Mining Sector Opens to US Commerce: What OFAC General License 51 Means for Strategic Minerals
Context On 6 March 2026, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) issued General License No. 51 , "Authorizing Certain Activities Involving Venezuelan-Origin Gold," a measure that begins to reopen Venezuela's mining sector to regulated US commercial activity. The licence was signed by OFAC Director Bradley T. Smith under the Venezuela Sanctions Regulations, 31 CFR part 591. It is the first general licence under the Venezuela sanctions framew
Alvaro Antoni
Mar 8


The Refining Gap: Why the Transatlantic Critical Minerals Agenda Must Move Beyond the Mine
When representatives of 54 countries gathered in Washington on 4 February 2026 for the inaugural Critical Minerals Ministerial, the scale of ambition was unmistakable. In the space of a single week, the Trump administration launched Project Vault, a public-private strategic minerals stockpile backed by approximately $12 billion in seed funding; unveiled the Forum on Resource Geostrategic Engagement (FORGE) as successor to the Biden-era Minerals Security Partnership; and annou
Alvaro Antoni
Feb 11
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