On March 2, 2026, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) imposed sanctions on the Rwanda Defence Force (“RDF”, the military of Rwanda) and four senior RDF officials pursuant to the Democratic Republic of the Congo Sanctions Regulations (“DRCSR”) (codified at 31 C.F.R. Part 547).[1] Concurrent with the designations, OFAC issued General License No. 1 (“GL 1”) authorizing the wind down of transactions involving the RDF through April 1, 2026.[2]
Link to Impact of Designations Impact of Designations
As a result of the designations, all property and interests in property of the RDF and the designated individuals that are located in the United States or in the possession or control of U.S. persons are blocked as a matter of law and must be reported to OFAC. Any entities owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. All transactions within U.S. jurisdiction that involve blocked parties, or any property in which such parties have an interest, generally are prohibited unless otherwise authorized.
According to the OFAC press release accompanying the designations, the RDF is providing direct operational support to the March 23 Movement (“M23”), a U.S.- and United Nations-sanctioned armed group responsible for human rights abuses and a mass displacement crisis in the Democratic Republic of the Congo (“DRC”), as well as M23 affiliates.[3] In exchange for its support for M23, Rwanda allegedly has gained access to mineral-rich areas of eastern DRC that contribute to the financing of M23’s armed rebellion.
Companies and financial institutions with exposure to Rwanda and the DRC, particularly in the mining, minerals trading, logistics, and financial services sectors, should carefully review their counterparty relationships for potential nexus to the RDF or entities in which the RDF holds a 50 percent or more ownership interest.
Link to Wind-Down General License Wind-Down General License
Concurrent with the designations, OFAC issued GL 1, which authorizes, through April 1, 2026, all transactions prohibited by the DRCSR that are ordinarily incident and necessary to the wind down of any transaction involving the RDF, or any entity in which the RDF owns, directly or indirectly, a 50 percent or greater interest. GL 1 does not authorize transactions with the four designated individual senior RDF officials described above.
Cleary’s international trade team continues to monitor developments in the DRC sanctions program and is available to offer guidance on assessing exposure and managing compliance with OFAC’s requirements.
[1] OFAC designated the RDF and the four individual RDF officials pursuant to Executive Order (“E.O.”) 13413, as amended by E.O. 13671, for “being responsible for or complicit in, or having engaged in, directly or indirectly, actions or policies that threaten the peace, security, or stability of the DRC, and for having materially assisted, sponsored, or provided financial, material, logistical, or technological support for, or goods or services in support of, M23.” Democratic Republic of the Congo-Related Designations; Issuance of Associated General License, U.S. Department of the Treasury (Mar. 2, 2026), https://ofac.treasury.gov/recent-actions/20260302.
[2] General License No. 1, Authorizing the Wind Down of Transactions Involving the Rwanda Defence Force, U.S. Department of the Treasury (Mar. 2, 2026), https://ofac.treasury.gov/media/934971/download?inline.
[3] Press Release, Treasury Sanctions Rwanda Officials, Condemns Blatant Violations of Washington Peace Accords, U.S. Department of the Treasury (Mar. 2, 2026), https://home.treasury.gov/news/press-releases/sb0411.