In short
- Thousands of Rwanda Defense Force troops have fought alongside M23 and supplied weapons and training, including surface-to-air missiles and jamming equipment.
- The sanctions are pursuant to E.O. 13413, as amended, and target material support for the RDF, M23, and AFC.
What happened
The United States announced sanctions against Rwanda’s Ministry of Defense and Zigama Credit and Savings Society for materially assisting the March 23 Movement (M23) armed group in eastern Democratic Republic of the Congo. The sanctions are issued under E.O. 13413, as amended, due to support including weapons, training, and logistical aid provided by Rwanda Defense Force troops.
The State Department highlighted that these actions violate the Washington Accords for Peace and Prosperity, signed on December 4, 2025, and undermine efforts to end conflict in the region. The statement also calls for scrutiny of supply chains linked to gold and coltan mining areas under M23 control, where civilians face forced labor and illegal taxation.
We urge our partners and the private sector to examine their supply chains closely.
What compliance teams should check
- Screen all transactions and relationships for exposure to Rwanda’s Ministry of Defense and Zigama Credit and Savings Society, as designated under E.O. 13413.
- Review supply chains for links to gold and coltan mining areas under M23 control, including Rubaya in North Kivu.
- Monitor for updates from the Department of the Treasury’s press releases regarding these sanctions and related entities.
Why it matters
This development is significant for AML/CFT compliance because it expands the list of sanctioned entities to include Rwanda’s Ministry of Defense and Zigama Credit and Savings Society, both now designated under E.O. 13413. Financial institutions and businesses must ensure they do not facilitate transactions or provide services to these entities, directly or indirectly. Enhanced due diligence is required for supply chains connected to gold and coltan mining in M23-controlled areas, as these are linked to forced labor and illegal taxation, increasing the risk of sanctions violations and reputational harm.
Catch stories like these on your own customers.
complead screens your customers against adverse media, sanctions and PEP lists, and re-checks them every day. When a name you hold turns up in the news, it lands in your case queue with the evidence attached.