Why Kagame Defies US Sanctions: Minerals, Western Partners and the Roots of Rwanda’s Occupation of Eastern Congo

Washington has now sanctioned the ministry that commands Rwanda’s army. Twenty months of escalating measures have not moved Rwandan troops out of eastern Congo, and the people of North and South Kivu are paying for every month of delay.

African lives are not worth less. African deaths are not normal. Western interests must never become a licence to kill African people.

Introduction: Sanctioned Again, Still in Congo

On 28 October 2026 the US Treasury sanctioned Rwanda’s Ministry of Defence and Zigama Credit and Savings Society, the financial institution that serves Rwanda’s security services, for supporting the M23 rebellion in eastern Democratic Republic of Congo (DRC). Treasury Secretary Scott Bessent’s demand was direct: “Rwanda must halt its support for M23 and withdraw its troops from eastern DRC.”

The measures are the most serious the United States has taken against the Rwandan state. They are also the latest in a series that has not yet changed what happens on the ground. Rwanda denies supporting M23, its forces remain in the Kivus, and M23 still holds Goma and Bukavu. For many Congolese, and for many observers of the region, even these measures still fall short of what the scale of the occupation demands.

This analysis explains what the new sanctions do, why earlier measures have not ended Rwanda’s military role in Congo, the economic incentives behind that role, thirty years of US–Rwanda relations, why the United States and other Western governments continue economic, diplomatic and security cooperation with Kigali despite sanctions, whether a Democratic administration would change course, what the conflict means for civilians and accountability, and what would make sanctions work. Throughout, we distinguish documented findings from allegations and from our own editorial judgements.

What the US Sanctioned on 28 October 2026

The Treasury’s Office of Foreign Assets Control (OFAC) designated both entities under Executive Order 13413, as amended, which targets those who threaten the peace, security or stability of the DRC. It described the Ministry of Defence as the umbrella body for Rwanda’s security services and said it had materially supported the Rwanda Defence Force (RDF), which OFAC had already sanctioned on 2 March 2026.

According to the Treasury, the RDF has deployed thousands of troops across North and South Kivu, where they operate alongside M23 and have supplied it with weapons, equipment, training and logistics. The Treasury also said the RDF had brought surface-to-air missile systems and jamming equipment into eastern Congo, creating risks for civilian aviation.

The case against Zigama is the most detailed part of the announcement. The Treasury says the institution paid entities in China and other countries for weapons, ammunition and equipment for the RDF, financed travel and accommodation for military training, enabled one of its branches to move gold from M23-held territory to Kigali, and processed transactions worth tens of millions of dollars for M23 and its political wing, the Congo River Alliance.

What the Sanctions Do, and Do Not Do

Any property of the two entities in the United States or held by US persons is frozen, and US persons are generally barred from dealing with them, as well as with any entity they own 50 per cent or more. Non-US persons are prohibited from causing US persons to breach the sanctions, which in practice affects most dollar transactions.

The measures do not automatically penalise every foreign bank that deals with Zigama or the ministry. The Treasury warns that financial institutions “may risk exposure to sanctions” through certain transactions, and anyone, anywhere, who materially assists a designated party can themselves be designated under the same order. That risk is discretionary rather than automatic, but it is usually enough to make international banks cautious.

Counting the Rounds

This is the fourth US action against Rwandan state targets since February 2025, and each has reached higher. It began with an individual, James Kabarebe, Minister of State for Regional Integration, in February 2025. It moved to an institution in March 2026, when the RDF itself was sanctioned along with four senior commanders, followed by visa restrictions on Rwandan officials. It then reached a commercial network in June 2026, with the Gasabo Gold Refinery, three mining companies and two linked individuals. The October designations of the Ministry of Defence and Zigama complete that sequence. They followed an earlier precedent from August 2023, when the US sanctioned Brigadier General Andrew Nyamvumba, the first senior RDF commander designated for backing M23.

Why Previous Sanctions Have Not Ended Rwanda’s Role

The demand for withdrawal is not new. On 21 February 2025 the UN Security Council unanimously adopted Resolution 2773, calling on the RDF to stop supporting M23 and withdraw from Congolese territory without preconditions. Rwanda and the DRC signed a US-mediated agreement in June 2025 and the Washington Accords for Peace and Prosperity on 4 December 2025. Within days of the Accords, M23 took Uvira on the Burundian border. A US deadline for withdrawal expired on 15 July 2026 without change on the ground.

Each round of pressure has followed the same pattern. Kigali denies backing M23, describes the measures as unjust, and argues that its forces are acting defensively against the FDLR, an armed group established in 2000 whose origins include former members of forces involved in the 1994 genocide against the Tutsi. It says it will disengage in step with Kinshasa meeting its own obligations. That position deserves to be stated fairly, and it is examined below.

“One-Sided” Sanctions? It Is Not Congo That Is in Rwanda

Kigali’s central defence is that the sanctions are one-sided. The government said so in March 2026, and the argument is repeated by Rwanda’s paid advocates and sympathetic voices in Washington: the United States, they say, punishes Rwanda while ignoring Kinshasa’s failures, especially its collaboration with the FDLR.

The argument fails on a single fact. It is not the DRC that is in Rwanda. It is Rwanda that is in the DRC. There are no Congolese troops on Rwandan soil, no Congolese-backed rebels administering Rwandan towns and no Congolese officials taxing Rwandan mines. The UN Group of Experts estimated that around 6,000 Rwandan soldiers were deployed in eastern Congo in early 2025, and Resolution 2773 names the RDF. Sanctions fall on one side because the cross-border military presence is on one side. And that presence has grown. In its June 2026 report, the Group of Experts gave a conservative estimate of 14,000 to 18,000 RDF troops in eastern Congo as of December 2025, between 8,000 and 10,000 in South Kivu and between 6,000 and 8,000 in North Kivu, and found no evidence of significant withdrawals since.

Nor has Washington ignored Kinshasa. The Washington Accords require the DRC to neutralise the FDLR. In 2026 the Treasury sanctioned FDLR commanders and, in April, former Congolese president Joseph Kabila for supporting M23. The UN experts reported in July 2025 that the Congolese government continues to rely on the FDLR and Wazalendo militias as auxiliary forces, a serious violation that Kinshasa must end. But a state that tolerates a militia on its own territory and a state that sends its army across a border to seize cities and mines are not in equivalent positions. Treating them as equal parties is not balance. It rewards the stronger, foreign force. If the FDLR threat were the real driver, Rwanda could defend its border from inside Rwanda, as other states facing cross-border threats do, rather than holding mining zones hundreds of kilometres away.

Presence, Control or Occupation? What the Law Says

Military presence, support for an armed group and belligerent occupation are related but legally distinct. Under international humanitarian law, territory is occupied when it is actually placed under the authority of a hostile foreign army, which courts assess by whether that army exercises effective control. In 2005 the International Court of Justice found that Uganda had been the occupying power in Ituri, in north-eastern Congo, during the Second Congo War, and in 2022 it ordered Uganda to pay $325 million in reparations.

No court has yet ruled on Rwanda’s status in the Kivus. But in June 2026 Human Rights Watch concluded, on the basis of detainee testimony and military, intelligence and UN sources, that Rwandan forces exercise effective control over areas held by M23, meeting the legal threshold for belligerent occupation. When this article describes Rwanda’s presence as an occupation, it relies on that assessment and on the scale of the deployment documented by the UN and the US Treasury. Rwanda rejects the characterisation.

Congolese Refugees as a Source of Fighters

Rwanda’s occupation does not depend only on its own soldiers. Both the UN and the US government have reported that Congolese refugees living in Rwanda have been recruited to fight in eastern Congo.

The UN Group of Experts reported in 2024 that Rwandan soldiers and military intelligence agents recruited children from refugee camps in Rwanda with promises of money, smuggled them across the border and had them trained by RDF soldiers for M23, some of them as young as 15; Rwanda called the findings absurd. The US State Department’s 2025 Trafficking in Persons Report, citing UN reporting, states that Rwandan officials forcibly and fraudulently recruited children from Rwandan refugee camps, primarily Congolese, for use by M23 in combat and support roles. In June 2026 the Group of Experts estimated M23’s strength at around 30,000 fighters, drawn in part from refugee camps in Rwanda. This was an estimate, not a verified individual headcount of trained, equipped and operational combatants; the report drew on different categories of recruits and former security personnel and documented substantial desertions, particularly among forcibly recruited fighters. The number of M23 fighters available for combat at any one time remains uncertain.

The camps themselves are in crisis. Rwanda hosts around 120,000 refugees, roughly 70,000 of them Congolese. By September 2025, after international aid cuts, only about 23,000 were still receiving food and other essentials, rations had been cut by more than half in some camps, and aid workers reported refugees returning to conflict zones and women and girls exposed to sexual exploitation. Desperation of this kind makes recruitment easier.

In our assessment, this is one reason sanctions have had so little effect on Rwanda’s military presence. Part of the manpower for the occupation is supplied by M23’s own recruitment, including forced recruitment documented by Human Rights Watch, and by refugees recruited in Rwanda, rather than drawn entirely from the RDF’s payroll. The costs of recruitment, training, equipping and maintaining these fighters are not independently established, and the proportion of M23 personnel recruited from refugee camps remains uncertain. And according to the US Treasury, the RDF has for years bought weapons and equipment from suppliers in China and elsewhere through Zigama. In our judgement, Kigali prepared for a long campaign well before the latest sanctions: financial measures that target future payments do not remove the arsenal or the recruits already in place.

Evidence From Behind the Front Line

Any discussion of evidence must start from a basic fact: the areas where serious abuses and mineral trafficking are reported are exceptionally difficult to investigate independently. Armed control, threats to witnesses and journalists, and restrictions on access prevent investigators from establishing a complete account of activities there. Occupation is not only the subject of the evidence; it is a major obstacle to gathering it.

Foreign journalists have needed Rwandan or Ugandan press accreditation to enter M23-held areas, with reported fees of up to $1,000, so access is controlled by the very parties under scrutiny. Human Rights Watch documented threats, detentions and killings of Congolese journalists and activists in Goma and Bukavu after M23 took them. In August 2026 the M23-appointed governor of South Kivu banned political debate programmes and coverage of the Congolese government, and a Bukavu presenter was suspended after criticising the rebel administration. The UN mission, MONUSCO, has reported access and movement restrictions in M23-controlled areas. Rwanda refuses the fingerprint test that could verify where its minerals were mined.

That has three consequences for how the evidence in this article should be read. First, what has been documented is a minimum, not a full account: Global Witness notes that its customs data may be incomplete and that the true volumes are probably much higher. Second, much of the evidence has had to be gathered from outside the occupied zone, through former detainees, traders, smugglers and customs records. Third, the absence of evidence about a particular event in occupied Kivu cannot be treated as proof that it did not happen. When a territory is closed to independent scrutiny by the forces that control it, the burden falls on those forces, and on Rwanda as their backer, to open it.

Conflict Minerals and Economic Incentives

The evidence falls into three layers: what has been documented about the mineral trade, what Rwanda’s own export figures show about the revenue it generates, and what we judge that means for Rwanda’s decisions.

What Is Documented

The UN Group of Experts reported in January 2025 that at least 150 tonnes of coltan had been fraudulently exported from M23-held areas to Rwanda during 2024, after the rebels seized Rubaya, one of the world’s largest coltan deposits. It called this the most significant contamination of the region’s mineral supply chains in a decade, and estimated that M23 collected at least $800,000 a month in taxes on Rubaya’s coltan. Its July 2025 report found that Rwanda exercised direct control over M23 in order to secure minerals, farmland and political influence. Its June 2026 report found that Rwanda’s coltan and cassiterite exports rose sharply from the second quarter of 2025, a trend not supported by domestic production and closely aligned with output from M23-controlled areas around Rubaya, where it described systematic taxation and tight control of transport.

Yet Washington has not targeted the Rubaya trade directly. Its June 2026 designations named the Gasabo gold refinery and three Rwandan mining companies, Bugambira Mines, Wolfram Mining and Processing, and Rwinkwavu Mining Corporation, but none of the coltan exporters that Global Witness found buying from Rubaya, and not the M23 mining administration that taxes it. It is not clear why the world’s most documented conflict-coltan route remains outside US sanctions.

The US Treasury has since described RDF soldiers and M23 fighters escorting gold from rebel-held areas to the Gasabo refinery in Kigali, and a Zigama branch enabling gold transfers. Congolese ministers have claimed that Rwanda’s coltan exports rose 213 per cent in the first half of 2025, a figure that has not been independently verified.

The Export Figures: Exporting More Than It Produces

Rwanda’s official trade statistics provide measurable evidence of the economic importance of mineral exports, while investigations by the UN, Global Witness and US authorities identify Congolese minerals entering those export chains and report financial benefits to Rwandan institutions and authorities. According to the Rwanda Mines, Petroleum and Gas Board, mineral export earnings rose from about $772 million in 2022 to more than $1.1 billion in 2023. In 2024 they reached about $1.75 billion, more than four times the $373 million recorded in 2017, with gold alone worth $1.5 billion. Shipments of tin, tungsten and tantalum rose a further 46 per cent in 2025. The government has set a target of $2.17 billion a year by 2029. These are export earnings, the value of minerals sold abroad, not government revenue; the state’s own receipts come through taxes, royalties and fees, which Rwanda does not publish separately for this trade.

These increases have not been matched by any published discovery of large new reserves. In 2023 Rwanda exported 2,070 tonnes of coltan, more than the DRC’s 1,918 tonnes, although the DRC holds far larger deposits. Reuters reported that Rwanda exported at least 2,300 tonnes of coltan ore in 2024, while experts say it produces far less. An analysis by Swissinfo, using National Bank of Rwanda, UN Comtrade and US Geological Survey data, found that Rwanda officially produced 350 tonnes of tantalum in 2024 but exported an estimated 715 tonnes, more than double its own output. The ENACT organised crime observatory concluded in 2022 that the majority of coltan exported from Rwanda probably originates in the DRC.

The trade has become better documented since M23 took Rubaya. Global Witness reported in June 2026, after a year-long investigation of customs data, that Rwanda’s official coltan exports rose more than two and a half times between 2021 and 2025. It found that at least 1,400 tonnes were smuggled from the DRC into Rwanda within a year of M23 taking Rubaya, and that at least five of the seven companies that exported almost 85 per cent of Rwanda’s coltan bought conflict coltan from Rubaya. Traders told Global Witness they paid “taxes” of $4 a kilo to M23 and $3 a kilo to the Rwandan government, that Rwandan officials recorded coltan arriving from the DRC, and that smuggled material was tagged as Rwandan under the industry’s traceability scheme. If accurate, that is a direct payment into Rwandan state revenue, not merely a boost to private exports. A confidential UN experts’ report reviewed by Reuters said 195 tonnes of smuggled minerals crossed into Rwanda in a single week in March 2025, and that one significant exporter, Boss Mining Solution, had bought smuggled Congolese minerals; the company denies it. In September 2026 Amnesty International reported that gold and coltan from M23-controlled mines, including Rubaya and the Lomera gold site, were being trafficked into Rwanda.

Rwanda denies plundering Congolese minerals and says it complies with international traceability rules. It attributes rising exports to better extraction, investment and higher world prices, and prices for tin and tantalum have indeed risen. But price rises cannot explain export volumes that exceed domestic production. Rwanda does have genuine domestic production of tantalum, tin and tungsten, recorded by the US Geological Survey, so not all of its mineral exports originate in the DRC. But taken together, the export volumes, the earnings and the investigations show that documented quantities of Congolese minerals are entering Rwandan export channels and being sold as Rwandan, and that the Rwandan economy is earning from them.

The Missing Paper Trail Is Kigali’s Choice

Beyond the per-kilo payments traders describe, the public record does not yet trace how much of these earnings reaches the state budget, how much goes to traders, refiners and military-linked businesses, or which projects it ends up paying for. That gap should not be mistaken for innocence. The absence of a published money trail does not mean the money did not flow. It means the accounts have not been opened.

Some of this information has simply never been published; some has been actively withheld. The distinction matters, but both are choices made in Kigali.

Withheld or refused. When the Bugesera deal with Qatar was signed in 2019, the infrastructure minister said details of how Rwanda would finance its 40 per cent share were “not for public consumption”. According to Global Witness, Rwanda has repeatedly refused to apply the analytical fingerprint test, a laboratory method that can verify where coltan was mined. The Rwanda Mines, Petroleum and Gas Board did not answer Global Witness’s questions, and Rwandan authorities did not respond to Amnesty International.

Not disclosed. Rwanda does not publish the value of its Visit Rwanda sponsorship contracts, its tax and royalty receipts from mineral exports by mineral and origin, the accounts or ownership arrangements of Zigama, which the US Treasury says moved tens of millions of dollars for M23, or the terms on which its troops are now funded in Mozambique. Its independent press has little room to investigate any of this. Where governments keep their books closed, the absence of a public money trail is a measure of their secrecy, not proof that nothing happened.

The burden should therefore be on Kigali. A government that insists its mineral boom is legitimate can publish production data by mine, export data by origin, the state’s revenue from the sector and how its prestige projects are financed. Until it does, the reasonable conclusion from the evidence that is public is that Congolese minerals are feeding Rwanda’s economy and, through it, the state’s spending choices. The ICJ’s 2005 judgment held Uganda responsible for looting by its soldiers even without proof of a deliberate state policy; the evidence against Rwanda is already stronger, because it shows state institutions, including the army and Zigama, directly involved in moving minerals.

Our Judgement: Why the Incentives Matter

In our assessment, eastern Congo has become one of Rwanda’s most valuable sources of foreign exchange, and its government has strong reasons to protect it. That matters because of the commitments Kigali has made. Bugesera International Airport was re-scoped in 2019 with Qatar Airways taking a 60 per cent stake, and its estimated cost has since risen to as much as $2 billion. Rwanda’s direct contribution has not been published. In a projection reported in 2025, the IMF warned that the airport would significantly increase debt service pressure and raise public debt to 86.3 per cent of GDP in 2026; Fitch expected debt to stabilise around 81 per cent including airport liabilities. Kigali has also secured a 10-year agreement to host the Formula 1 African Grand Prix at a planned circuit in Bugesera, with the first race expected in the early 2030s. Announced on 13 October 2026, two weeks before the latest US sanctions, the agreement adds another major international sporting commitment alongside the airport project and Rwanda’s existing football sponsorships. Its cost to the Rwandan state has not been published. In 2023 Rwanda also signed to host an experimental nuclear reactor.

Supporters see investment in a modern economy. We see prestige projects that do little for most Rwandans, who remain largely rural and poor, while committing the state to debts it must service regardless of what happens in Congo. A government under that pressure has every reason to keep control of a lucrative zone, and withdrawal would mean surrendering it as the bills arrive.

From Congolese Mines to European Football Shirts

The same priorities are visible in world sport. Rwanda’s Visit Rwanda brand has sponsored Arsenal since 2018 in a deal reported at more than £10 million a year, which ends after the 2025–26 season. It has sponsored Paris Saint-Germain since 2019, with an extension to 2028, Bayern Munich since 2023 and Atlético de Madrid until June 2028. The RDF itself owns the APR sports clubs; after the March 2026 sanctions, APR’s basketball team withdrew from the NBA-backed Basketball Africa League.

Rwanda has never published what it pays these clubs, so no one outside government can trace particular mineral sales to particular sponsorship payments, and Rwanda rejects the charge of sportswashing. That silence is not an answer. Rwanda’s mineral earnings have more than quadrupled since 2017 on volumes its own mines cannot account for, and money is fungible. A government whose foreign earnings depend increasingly on minerals leaving territory its army helps control, while paying millions a year to promote itself through foreign clubs, is in effect financing its image with resources taken from Congo. In February 2025 Congo’s foreign minister, Thérèse Kayikwamba Wagner, wrote to Arsenal, PSG and Bayern Munich asking them to end what she called blood-stained sponsorship deals. Arsenal’s decision not to renew leaves the others to answer the same question.

Sanctions and Partnership at the Same Time: Washington’s Mixed Signals

Sanctions are meant to signal that a relationship has changed. Yet in many areas the United States remains Rwanda’s partner, and in our assessment Kigali reads that as the weak side of the sanctions: proof that Washington’s anger is confined to one department while the rest of the relationship carries on.

Health and Aid

On 5 December 2025, the day after the Washington Accords were signed, the State Department agreed a five-year, $228 million health framework with Rwanda under its “America First Global Health Strategy”, only the second such deal after Kenya. Of that total, the United States is expected to provide $158 million, with Rwanda committing $70 million in domestic health investment. We have found no report that it has been suspended since the RDF and the Ministry of Defence were sanctioned. Support for the health of ordinary Rwandans is right in itself. But continuing a flagship bilateral agreement while sanctioning the army sends Kigali a mixed message about how serious Washington is.

Minerals and US Industry

The minerals relationship is closer still. The US International Development Finance Corporation (DFC), a government agency, has financed Trinity Metals, which operates tungsten, tin and tantalum mines inside Rwanda. Trinity says it has shipped more than 320 tonnes of tungsten concentrate to Pennsylvania and can supply up to 20 per cent of the primary tungsten concentrate processed in the United States. The American tin supplier Nathan Trotter has signed a letter of intent with Trinity to build a US–Rwandan supply chain feeding a planned $65 million refinery in Virginia. In August 2026 US Under Secretary Helberg publicly highlighted Trinity as an example of a secure minerals supply chain. During the peace negotiations, Reuters reported that Washington had engaged “probably up to 30” American investors about mining and processing in Rwanda, and that the planned economic framework could allow Congolese minerals to be exported to Rwanda for processing.

There is no evidence that Trinity’s own production comes from the DRC; its mines are in Rwanda. The risk lies in the wider system that US policy is building on. Between 2013 and 2022 Rwanda shipped more than 2,000 tonnes of tantalum ore and concentrate worth over $135 million to the United States, at one point supplying more than half of US imports, according to an Oakland Institute analysis of US Geological Survey data. Argus Media reports that these direct imports have since fallen to almost nothing, but Rwandan coltan still reaches products sold in the US through smelters in China and elsewhere, according to Global Witness. And as shown above, Rwanda’s export system has been used to tag smuggled Congolese coltan as Rwandan, while Kigali refuses the fingerprint test that could verify origin.

This is a concern about Rwanda’s wider export system, not an allegation against Trinity. In our judgement, it is the central contradiction of US policy. Washington sanctions the RDF for helping M23 seize Congolese mines, while encouraging American industry to depend more heavily on Rwandan minerals and promoting Rwanda as a regional processing hub for Congolese ore. Unless every US-bound mineral from Rwanda is independently verified as Rwandan in origin, American companies risk buying the very minerals the sanctions are meant to stop, and Kigali has little reason to believe Washington will let the sanctions damage a supply chain it is itself trying to build.

Thirty Years of US Political and Military Relations With Rwanda

Kigali’s confidence that it can outlast pressure is rooted in history. That history includes documented US assistance, credible allegations of deeper involvement, years of diplomatic reluctance and at least one period of real pressure. Each needs to be identified for what it is.

1990–1994: Fort Leavenworth to Genocide

Paul Kagame was attending the US Army Command and General Staff College at Fort Leavenworth in October 1990 when the Rwandan Patriotic Front (RPF) invaded Rwanda from Uganda. He left to take command. During the genocide in 1994, declassified records published by the National Security Archive show that the United States first sought to leave: on 15 April the State Department instructed diplomats to oppose keeping the UN mission in Rwanda, and on 21 April, at US urging, the Security Council reduced it to a remnant. Officials avoided the word genocide for weeks. Once the RPF had won, inaction gave way to partnership, and President Clinton apologised in Kigali in 1998 for the world’s failure. In our view, that guilt became one foundation of Western reluctance to scrutinise the RPF’s own conduct.

1996–1998: The Congo Wars

Rwandan troops led the 1996 campaign that dismantled refugee camps in eastern Zaire and brought Laurent-Désiré Kabila to power. A 1997 Human Rights Watch and FIDH report documented large-scale killings of refugees by the rebel alliance and Rwandan forces. It stated that the United States gave key political support to Rwanda during the campaign, and it recorded claims from knowledgeable witnesses that US military personnel trained and assisted Rwandan troops on Congolese soil. That last point remains an allegation that has not been independently established; Human Rights Watch called on Washington to disclose its military involvement. The UN Mapping Report of 2010 later documented serious crimes in Congo between 1993 and 2003, including by Rwandan forces. Rwanda rejected it, and no international prosecution followed.

2000s: The Model Partner

Documented US assistance grew in this period. Washington helped train and airlift Rwandan peacekeepers from 2004, beginning with Darfur. Prominent Western figures, including Bill Clinton through his foundation’s health work and Tony Blair through advisers placed in Kigali, became public admirers of Rwanda’s governance. That made criticism of its regional conduct politically awkward in Washington and London.

2012–2013: When Pressure Worked

US policy was not uniformly protective. When M23 first captured Goma in 2012, the Obama administration suspended Foreign Military Financing to Rwanda, and in October 2013 it blocked military training and financing under the Child Soldiers Prevention Act. European donors followed. M23 collapsed in November 2013 under a reinforced UN brigade and a reorganised Congolese army; analysts at Just Security concluded that international pressure contributed to Rwanda suspending its support. But many restrictions were later waived without accountability, and Kigali learned that pressure could be outlasted.

The Accusations Against Washington

African critics, Congolese civil society and rights organisations have long made several charges against US policy. These are criticisms and interpretations, not settled findings, but they explain why many Congolese view today’s sanctions with suspicion.

Selective outrage. In December 2012 the New York Times examined the relationship between Susan Rice, then US ambassador to the UN and a long-standing acquaintance of Kagame, and US handling of the Congo crisis, at a time when critics accused American diplomats of softening pressure on Kigali. Rice defended her record.

Minerals before peace. Alongside the Washington Accords, the US signed a Strategic Partnership Agreement with the DRC. A January 2026 memo from Public Citizen, Friends of the Congo and partners to the House Africa subcommittee said it reserves critical mineral assets for US companies with a right of first offer, binds the DRC to change its mining law within a year and leaves most US commitments non-binding. It was not put to the Congolese parliament.

Leverage traded away. In November 2025 Democratic Senators Tim Kaine, Cory Booker, Chris Van Hollen, Peter Welch and Jeff Merkley asked Secretary of State Marco Rubio how the US deportee arrangement with Rwanda would avoid weakening American leverage, and criticised cuts to UN peacekeeping funding that reduce MONUSCO’s capacity.

Building the army now sanctioned. Critics note that the RDF’s professionalism, which makes it valuable as a peacekeeper and a hired security force, was developed partly with Western training and logistics.

Paid Advocates

Kigali invests in its US relationships. It hired Yorktown Solutions in March 2025 on an $80,000 monthly retainer, and the Forbidden Stories Rwanda Classified investigation identified at least a dozen PR and lobbying firms working for Kigali in the US and UK. Filings under the Foreign Agents Registration Act show the Rwandan embassy registering new agents in 2026, after the RDF was sanctioned. Lobbying is lawful and widely used, including by the DRC. The point is that Rwanda has the networks and patience to work on every branch of government, and both parties, while it waits.

Why Western Governments Keep Cooperating With Kigali

Mobutu Sese Seko held power in Zaire for 32 years partly because he was useful to Western capitals. In our assessment, Rwanda has built a modern version of that bargain. It offers disciplined troops for missions others will not staff, security for energy investments, cooperation on migration and a development story donors can promote. Each service creates a constituency abroad with an interest in smooth relations.

Mozambique, TotalEnergies and Migration

Rwanda deployed troops to Cabo Delgado in July 2021 after an Islamic State-linked attack halted TotalEnergies’ $20 billion liquefied natural gas project. It now maintains around 5,000 personnel there, and TotalEnergies resumed construction after lifting force majeure in October 2025. The EU funded the deployment through the European Peace Facility with €20 million in 2022 and again in 2024. That funding was not renewed when it expired in May 2026. Rwanda had warned in March that it would leave if funding was not secured. In May its foreign minister said Mozambique had secured funds for the mission, without disclosing the amount, the source or the terms.

Europe’s position is therefore contradictory. Governments condemn Rwanda’s role in Congo while relying on its army to secure European energy assets. The UK’s Rwanda asylum scheme ended in 2024, though Rwanda is pursuing arbitration over its cancellation, and Kigali agreed in August 2025 to accept up to 250 migrants from the United States. The EU sanctioned several Rwandan officers and the Gasabo refinery in March 2025, and the UK and Germany suspended aid, but neither the EU nor the UK has matched US designations of the RDF or the Ministry of Defence.

Qatar and the Donors

Qatar mediates the separate talks between Kinshasa and M23 and, through Qatar Airways, holds 60 per cent of the Bugesera airport project. Western aid has also proved forgiving. Several donors suspended budget support in early 2025, but by July President Kagame said some had quietly reversed their decisions, and the Congo Research Group reported releases by the World Bank and African Development Bank. In April 2026, weeks after the RDF was sanctioned, Rwanda raised a €213 million commercial loan backed by a World Bank IDA guarantee. Because money is fungible, external support for health or roads frees domestic funds for other priorities.

Rwanda’s Three Military Roles

According to UN figures, Rwanda was the largest contributor of uniformed personnel to UN peacekeeping in February 2026, with 4,405 uniformed personnel, mainly in South Sudan and the Central African Republic. Of these, 3,379 were troops, 47 staff officers and 22 military experts on mission, drawn from the RDF, while 880 formed police personnel and 77 individual police officers came from the Rwanda National Police. Alongside this UN role, the RDF plays two others. It deploys forces through bilateral agreements in Mozambique and the Central African Republic, and, according to the UN Group of Experts and the US Treasury, it deploys troops alongside M23 in the Kivus: between 14,000 and 18,000 by the UN’s conservative estimate, more than three times the number Rwanda contributes to the UN. All three military roles answer to the Ministry of Defence that Washington has now designated.

US sanctions do not legally disqualify a country from UN peacekeeping; that decision rests with the UN, its human rights screening and the Security Council. But the contradiction is plain. On 29 September 2026 the DRC asked the Security Council to exclude Rwanda from future deployments. Forbidden Stories has reported that Kigali treats its peacekeeping role as a shield against UN sanctions, with a former official describing threats to withdraw troops as a standard response to pressure. In our view, a UN that relies on troops commanded by a ministry defying a unanimous Chapter VII resolution is undermining its own authority, and should freeze new Rwandan deployments until Resolution 2773 is implemented.

Would Democrats Change US Sanctions Policy?

Many observers in the Great Lakes believe Kigali is playing for time, hoping that a Democratic return to power will ease the pressure. That is our reading of Rwandan strategy rather than a stated policy. Tested against the calendar, the law and the record, the hope looks weak.

The Calendar

The midterm elections on 3 November 2026 decide control of Congress, not sanctions policy. Designations under Executive Order 13413 are made and lifted by the executive branch. A Democratic Congress could hold hearings, require reports and condition aid, but it could not delist the RDF or the Ministry of Defence. The earliest a Democratic president could take office is January 2029.

The Law

A future administration would have real legal discretion. OFAC can remove designations when circumstances change or the basis for listing no longer applies, and a president can amend or revoke the executive order itself. The Treasury states that the purpose of these sanctions is a change in behaviour. The obstacle is therefore not legal but political: lifting sanctions without verified withdrawal would carry heavy diplomatic and reputational costs, including from within the Democratic Party.

The Record

The Democratic record on Rwanda is mixed, but its recent direction points towards more pressure. A Democratic administration cut military aid in 2012 and 2013. The Biden administration sanctioned Brigadier General Nyamvumba in 2023. In March 2023 Senators Dick Durbin and Cory Booker urged the State Department to act against Rwanda under the Child Soldiers Prevention Act. In August 2024 Democratic Senator Jeff Merkley joined Republican Marsha Blackburn in questioning the NBA’s relationship with Kagame’s government. In November 2025 five Democratic senators criticised the Trump administration for trading leverage for deportee and minerals arrangements. The fair counter-argument is that Democratic administrations also included some of Kagame’s closest Western admirers, and a future one might prefer quiet diplomacy. A change of style is possible.

The Price of Reversal

Lifting sanctions while Rwandan troops remain in Congo would reward the conduct the sanctions were imposed to stop: military support for M23, the extraction of coltan and gold, and defiance of a unanimous Security Council resolution. It would mean accepting a humanitarian catastrophe in which millions are displaced and tens of thousands of sexual violence cases are recorded each year. A party that has accused its opponents of transactional foreign policy cannot credibly lift pressure on an army the US Treasury has found fighting alongside an abusive rebel group. Any administration that did so, of either party, would be judged in Congo and beyond as having made peace with the atrocities rather than with Congo.

Our assessment: the hope that a Democratic victory will free Kigali from sanctions while its troops remain in Congo is not realistic. The greater risk is different: that any US administration accepts a minerals-and-investment bargain in which Rwanda’s withdrawal is promised but never verified.

Civilians and Accountability

The Human Cost

Every month of delay is measured in Congolese lives. The 2026 humanitarian response plan identifies 14.9 million people in need across the DRC. Sida’s March 2026 crisis analysis cites 6.4 million internally displaced people as of January 2026, most in the east, and about 3.2 million people in emergency food insecurity. Between January and September 2025, agencies documented more than 160,000 cases of gender-based violence, including over 90,000 cases of sexual violence.

The fighting around Uvira in December 2025 killed more than 70 civilians and displaced over 200,000 people within days; nearly 25,000 fled into Burundi, and the World Food Programme suspended operations across South Kivu. Meanwhile, humanitarian funding has collapsed. By December 2025 the previous year’s plan had received only about a fifth of its funding, the lowest level since 2017.

Life Under Armed-Group Administration

In June 2026 Human Rights Watch published “Death Was Everywhere”, based on interviews with 102 former detainees, witnesses and officials. It found that M23 seized people at checkpoints, hospitals, churches and schools and held them at camps in Rumangabo and Tshanzu, where hundreds, possibly more, died during 2025, many by summary execution. It documented forced recruitment of civilians and captured combatants, including children as young as 12, and said former detainees identified Rwandan soldiers among trainers and commanders. Human Rights Watch described the abuses as war crimes that should be investigated as possible crimes against humanity. Rwanda and M23 deny the allegations.

Daily life in Goma reflects the same isolation. A Goma-based journalist writing in The New Humanitarian in early 2026 described banks closed by the Congolese government since the takeover, scarce dollars, a closed airport that forces travellers through Kigali or Uganda, lost jobs and relocated businesses, and compulsory Saturday clean-ups enforced with fines or physical punishment. In September 2026 Amnesty International documented the killing of 18 miners at Rubaya and Lomera, along with torture and forced labour at mines under M23 control, abuses it said could amount to war crimes.

A Refuge From Accountability

M23-held territory has also become a place where people facing sanctions, criminal convictions or serious allegations live beyond the reach of any court. Their legal positions differ and should be stated precisely.

Sultani Makenga, M23’s military commander, has been under UN and US sanctions since 2012. Corneille Nangaa, leader of the Congo River Alliance, was sanctioned by the United States in July 2024; in August 2024 a Kinshasa military court convicted him in absentia of war crimes, insurrection and treason and sentenced him to death; he was later added to the UN sanctions list alongside M23’s intelligence chief, John Imani Nzenze, whom the US also sanctioned in 2026. Former president Joseph Kabila was photographed at his residence in M23-held Goma in May 2025. In September 2025 a Congolese military court convicted him in absentia of treason, crimes against humanity and other offences and sentenced him to death, and in April 2026 the US Treasury sanctioned him for supporting M23. None of these men has been convicted by an international court, and the domestic verdicts were handed down in their absence. The DRC has offered a $5 million reward for M23’s leaders. None has been arrested.

Their freedom of movement depends on the Congolese state being unable to enter the territory they hold, and that is a direct consequence of the military protection Rwanda provides to M23. Courts in Kinshasa can convict, the UN can list and Washington can freeze assets, but warrants cannot be served in Goma or Bukavu. The same protection extends to the Rwandan officers the Treasury and UN experts have linked to M23 operations. In our judgement, as long as Rwanda remains, eastern Congo will be a refuge from accountability and the rule of law, and every person sanctioned or accused there will have reason to support Kigali’s decision to stay.

What Would Make Sanctions More Effective

If the goal is withdrawal rather than condemnation, the measures that matter are those that reach Rwanda’s alternative revenue and its leverage.

Align Europe with Washington. The EU and UK should match US designations of the RDF, its commanders, the Ministry of Defence and Zigama, and the EU should suspend its 2024 critical raw materials memorandum with Rwanda.

Sanction the Rubaya chain. The US, EU and UK should designate the M23 mining administration that taxes Rubaya and the exporters, traders and refiners found to be buying its coltan.

Close the mineral route. Refiners, smelters and technology firms should treat coltan, tin and gold exported from Rwanda as high risk until independent tracing can separate Rwandan production from Congolese supply.

End Washington’s mixed signals. Humanitarian and health support for ordinary Rwandans should continue, but new US government financing for Rwandan mining and processing should be conditioned on verified withdrawal, and every US-bound mineral shipment from Rwanda should require independent proof of origin, including the analytical fingerprint test.

Stop buying the services. No member state should fund the RDF bilaterally in Mozambique while it remains in Congo, and Western governments should not expand migration arrangements with Kigali.

Condition peacekeeping. The UN should freeze new Rwandan deployments until Resolution 2773 is implemented, with a public timetable for review.

Verify both sides. Rwanda’s disengagement and the FDLR’s neutralisation should be monitored by an independent mechanism with access on both sides of the border, so neither government can hide behind the other’s delay.

Protect civilians and pursue justice. Donors cutting support to Kigali should redirect resources to Congolese civilians, and the international community should support investigations into the abuses documented by the UN and Human Rights Watch.

Conclusion: Sanctions Without Consequences Are Only Statements

The 28 October designations name the ministry, the bank and the gold route. They are the clearest statement yet that Washington holds Rwanda responsible for M23’s war. But Kigali has learned over three decades that Western condemnation and Western dependence often arrive together. While Europe relies on Rwandan troops to guard its gas, donors restore support and Gulf partners invest in its prestige projects, sanctions from Washington alone are more likely to be absorbed than obeyed.

On present evidence, Rwanda remains in eastern Congo because staying still costs less than leaving. Changing that requires every government that condemns the occupation to stop rewarding it. It also requires recognising that withdrawal is the precondition for justice: until Rwandan forces leave, eastern Congo will remain a place where sanctioned commanders and people accused of grave crimes live beyond the reach of any court, and where civilians bear the cost of everyone else’s convenience.

Frequently Asked Questions

Why did the US sanction Rwanda’s Ministry of Defence?

The US Treasury says the ministry materially supported the Rwanda Defence Force, which deployed thousands of troops to fight alongside M23 in North and South Kivu and supplied it with weapons, training and logistics, in breach of the December 2025 Washington Accords.

What is Zigama Credit and Savings Society?

Zigama is a Rwandan financial institution serving the country’s security services. The Treasury says it paid for RDF weapons purchases, moved gold from M23-held areas to Kigali and processed tens of millions of dollars for M23 and the Congo River Alliance.

Do the sanctions affect foreign banks?

Not automatically. US persons must block the entities’ assets, and non-US persons may not cause US persons to breach the sanctions. Foreign banks risk exposure for certain transactions and can be designated if they materially assist sanctioned parties.

Is Rwanda occupying eastern DRC?

No court has ruled on it. Human Rights Watch concluded in June 2026 that Rwandan forces exercise effective control over M23-held areas, meeting the legal threshold for belligerent occupation. Rwanda denies having troops there.

Why have sanctions not made Rwanda withdraw?

In our assessment, Rwanda still gains from its position in eastern Congo: its mineral export earnings rose from about $772 million in 2022 to $1.75 billion in 2024, on coltan volumes that appear to exceed its own production, while continuing US partnerships in health and minerals, European security partnerships, donor support, Gulf investment and its role in UN peacekeeping reduce the cost of sanctions.

Has the United States supported Paul Kagame in the past?

Yes. Kagame trained at Fort Leavenworth, the US gave Rwanda political support during the 1996 Congo war according to Human Rights Watch, and Washington trained and airlifted Rwandan peacekeepers from 2004. The main exception was 2012 to 2013, when the Obama administration cut military aid over M23.

Would a Democratic administration lift US sanctions on Rwanda?

It would have the legal power to do so, but lifting sanctions without verified withdrawal would carry heavy political costs. The earliest Democratic presidency would begin in January 2029, and recent Democratic positions favour more pressure on Rwanda.

What is life like for civilians in M23-held areas?

Human Rights Watch documented arbitrary detention, killings and forced recruitment, including of children, in 2025. In Goma, banks and the airport remain closed, and 6.4 million people were internally displaced across the DRC in January 2026.

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Reuters via The EastAfrican (2025) ‘UN: Rwandan coltan exporter Boss Mining bought smuggled Congo minerals’, July. Available at: [https://www.theeastafrican.co.ke/tea/business-tech/un-rwandan-coltan-exporter-boss-mining-smuggled-congo-minerals-5106116](https://www.theeastafrican.co.ke/tea/business-tech/un-rwandan-coltan-exporter-boss-mining-smuggled-congo-minerals-5106116)

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US Department of the Treasury (2026) ‘Treasury sanctions Rwandan Ministry of Defence and financial institution supporting M23’, 28 October. Available at: [https://home.treasury.gov/news/press-releases/sb0668](https://home.treasury.gov/news/press-releases/sb0668)

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WebRwanda (2026) ‘U.S. Under Secretary Helberg highlights Rwanda’s Trinity Metals as model for secure minerals supply chain’, August. Available at: [https://en.webrwanda.com/2026/08/us-under-sec-helberg-highlights-rwanda.html](https://en.webrwanda.com/2026/08/us-under-sec-helberg-highlights-rwanda.html)

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Author: Africa Realities Media Editorial Team

Meta Title: Why Kagame Defies US Sanctions on Rwanda Over DR Congo

Meta Description: The US has sanctioned Rwanda’s Defence Ministry over M23. Minerals, Western partnerships and three decades of US support explain why Kagame still defies the pressure.

Meta Keywords: US sanctions Rwanda, Rwanda Ministry of Defence sanctions, Zigama sanctions, M23, Rwanda DRC conflict, Resolution 2773, US support for Kagame, Democrats Rwanda policy, Visit Rwanda, eastern DRC humanitarian crisis

Disclaimer: This article combines reporting from publicly available sources with the editorial analysis of Africa Realities Media. Statements identified as our assessment or judgement are editorial opinions based on the evidence available; where the Government of Rwanda has not published relevant financial information, we say so. Allegations by governments, rights organisations and others are attributed to their sources. The Government of Rwanda denies supporting M23 or deploying troops in the DRC. Nothing in this article constitutes legal, financial or investment advice.