OFAC designates Rwanda's defence ministry and Zigama over M23 support

The US Office of Foreign Assets Control (OFAC) on 28 October added Rwanda's Ministry of Defence and Zigama Credit and Savings Society to its Specially Designated Nationals (SDN) List, Treasury said, citing their support for the M23 armed group in eastern Congo.

Both entries carry the DRCONGO programme tag in the OFAC notice. The ministry is listed in Kigali with the target type "Government Entity" and Zigama, also in Kigali, as a "Financial Institution". The notice lists no general licence for either name.

Treasury describes Zigama as "a Rwandan financial institution that has played a key role in facilitating Rwanda's support for the March 23 Movement (M23) and its political wing, the Congo River Alliance". Both designations are made under Executive Order 13413, as amended.

What Treasury says each entity did

Treasury calls the Ministry of Defence "the umbrella organization for Rwanda's security services, including the Rwanda Defence Force (RDF)", which OFAC sanctioned on 2 March 2026. The release says "at the direction of the Rwandan MoD, the RDF has deployed thousands of troops across eastern DRC's North and South Kivu provinces, where they conduct operations alongside M23 and provide the armed group with military equipment, supplies, logistical support, and training".

On Zigama, Treasury says the lender "operates on behalf of Rwanda's security services" and "has facilitated payments to entities in China and additional countries for weapons, ammunition, and other military equipment for the RDF". It says "a Zigama branch enabled the transportation of gold sourced from M23-controlled territory in eastern DRC to Kigali", and that Zigama "has facilitated financial transactions for M23 and the Congo River Alliance, amounting to tens of millions of dollars".

On minerals, Treasury says M23 has taken control of gold mines in South Kivu province and of Rubaya, which it calls "an expansive area for coltan mining in North Kivu province". It states that "minerals sourced from M23-controlled territory are integrated into supply chains in Rwanda, whose domestic mining capacity is smaller than export volumes reported since M23's rebellion began".

Treasury Secretary Scott Bessent said the action "makes good on President Trump's promise to hold Rwanda accountable for its commitments under the Washington Accords for Peace and Prosperity", which the Congolese and Rwandan presidents signed on 4 December 2025. "Rwanda must halt its support for M23 and withdraw its troops from eastern DRC," he said.

Rwanda's response

Rwandan government spokesperson Yolande Makolo said the Washington Accords contain commitments on the neutralisation of the FDLR, a militia rooted in the 1994 genocide, that are unmet, Reuters reported. "Rwanda remains ready to fully implement the Washington Accords, concurrently with the willingness of the DRC to fulfill those commitments, and with the mediator holding all parties accountable," she said, according to the agency. Reuters also reported that Rwanda denies backing the M23 rebels and that Zigama's chief executive did not immediately respond to a request for comment. Treasury's release notes that on 12 October the Front for the Refoundation of the Nation announced its formation as the successor to the Congo River Alliance, which the release describes as M23's political wing. The website of the Ministry of Foreign Affairs and International Cooperation listed no statement on the action when checked on 30 October.

Congo's foreign ministry welcomed the sanctions in a statement quoted by Reuters. The Associated Press reported that the United States earlier this year sanctioned the Rwanda Defence Force and four of its senior officials.

What changes in screening

A designation is an administrative measure by the US Treasury, not a finding by a court, and Treasury states that "the ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior". For compliance teams, the practical consequences are set out in the release itself. All property and interests in property of the two entities in the United States or in the control of US persons are blocked and must be reported to OFAC. Entities owned 50 per cent or more, directly or indirectly and in the aggregate, by one or more blocked persons are also blocked.

Treasury adds that non-US persons are prohibited from causing or conspiring to cause US persons to violate US sanctions, and that "financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons". The prohibitions cover receiving funds, goods or services from a blocked person as well as providing them.

For banks, the practical step is to load both names, with the aliases in the notice (MINADEF, MOD of the Republic of Rwanda, Zigama CSS, Zigama Credit and Savings Bank), into screening lists and to check customer and payment data for entities owned 50 per cent or more, directly or indirectly, individually or in the aggregate, by one or more blocked persons, the test the release sets. Treasury says Zigama has facilitated payments to entities in China and other countries for military equipment, so payment messages that name Zigama as a party deserve review.

For buyers of minerals, the line in the release on Rwandan supply chains is the one to read. Treasury links Zigama to the movement of gold from M23-controlled mines to Kigali. Refiners and traders handling Rwandan gold or coltan will want records that show the mine of origin and the payment channel, including whether Zigama appears in it. The release names no minerals buyer, and nothing in it says that dealing with Rwandan exporters in general is prohibited.

Related reading: the Panama law firm OFAC listed on 21 October and the IMF staff agreement on Rwanda's first programme review.

OFAC published a second action on the same day, sanctioning 10 individuals and one entity over North Korean IT worker schemes, in a separate release.