In what amounts to a material expansion of its existing sanctions program arising out of the conflict in the Democratic Republic of the Congo (“DRC”), on March 2, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions against the Rwanda Defence Force (“RDF”)—an organization described by OFAC as Rwanda’s military—along with four senior RDF officials. According to Treasury, the RDF has been “supporting, training, and fighting alongside” M23, an armed group already designated by both the United States and United Nations and operating in the eastern DRC. Treasury tied the action  to alleged violations of the “Washington Accords for Peace and Prosperity,” including a recent M23 offensive that resulted in the capture of the city of Uvira in eastern DRC.

Under this blocking action, all property and interests in property of the RDF and the designated officials that are in the United States, or in the possession or control of U.S. persons, are blocked and must be reported to OFAC. U.S. persons are generally prohibited from engaging in transactions or dealings with the designated parties unless authorized by OFAC.

OFAC’s “50 Percent Rule” also applies to entities owned, directly or indirectly, 50% or more– individually or in the aggregate– by one or more blocked persons, even if not separately identified on OFAC’s Specially Designated Nationals (“SDN”) List.  

Also on March, 2, 2026, OFAC issued Treasury’s General License No. 1 under the DRC Sanctions Regulations (31 CFR part 547). The General License authorizes transactions that are ordinarily incident and necessary to wind down pre-existing dealings involving the RDF, and any entity owned 50 percent or more by the RDF, through April 1, 2026.  The authorization is limited and it does not permit the initiation of new business, nor does it unfreeze blocked property.  Any payments involving a blocked person must be placed into a blocked account.  The General License also does not authorize transactions with any other persons blocked under the DRC program (or any other otherwise-prohibited conduct) unless separately authorized.

These actions build on Treasury’s February 20, 2025 designations of James Kabarebe and Lawrence Kanyuka Kingston, along with two associated companies registered in the United Kingdom and France. The March 2026 designations reflect a continued expansion of Treasury’s focus from individual actors to state-affiliated institutions alleged to be supporting destabilizing activities in the DRC.

Practically, companies with operations, counterparties, or financial flows connected to Rwanda, or the DRC region, particularly those with potential connections to regional military or defense sector or supply chains, should treat this development as an immediate compliance priority. In particular, businesses involved in regional logistics, extractive industries, commodities trading, defense-related activities or financial services should consider:

• Conducting enhanced screening of counterparties and beneficial owners;
• Reviewing existing contracts for potential RDF nexus;
• Assessing whether wind-down activity is required before April 1, 2026; and
• Confirming that any required blocking and reporting procedures are implemented.

Crowell & Moring will continue to monitor developments related to sanctions enforcement actions and their potential impact to industry.