3T, gold and traceability: proof of origin and the offences for illegally extracted minerals under Law N° 072/2024, the iTSCi tagging system run by RMB since 2010, MCIS export certificates and the ICGLR Regional Certification Mechanism, gold refining, the OECD Due Diligence Guidance, the EU Conflict Minerals Regulation and Dodd-Frank section 1502, and what buyers will ask a Rwandan supplier for

Why traceability decides market access

Most of Rwanda's mineral output is of the "3T" minerals: tin from cassiterite, tantalum from coltan and tungsten from wolframite. With gold, they are the minerals that international rules treat as potential conflict minerals when they come from the Great Lakes region. Rwanda borders the eastern Democratic Republic of the Congo (DRC), where armed groups have financed themselves from mineral trade, and the same minerals are mined on both sides of the border. Any buyer of Rwandan 3T or gold, whether a smelter in Asia, a refiner in Europe or a manufacturer listed in the United States, therefore needs evidence that a lot was mined in Rwanda, by a licensed operator, and moved through a documented chain of custody.

That evidence has become more important since 2025. In March 2025 the Council of the European Union listed a Kigali gold refinery that its announcement described as responsible for illegally importing gold from M23-controlled regions of the DRC, and in June 2026 the United States Office of Foreign Assets Control (OFAC) designated the same refinery and three Rwandan mining companies, stating that minerals sourced in eastern DRC are smuggled through Rwanda. The Rwandan legal system answers with three tools described in this section: the offences and fines for minerals without proof of origin, the iTSCi tagging system for 3T minerals, and RMB's export certificates under the regional certification mechanism. The sanctions themselves, and the due diligence a buyer, lender or acquirer should run, are covered in Sanctions, due diligence and reforms.

Proof of origin and the offences

Because all minerals belong to the State until extracted under a licence (Article 3(a) of Law N° 072/2024 of 26/06/2024 on mining and quarry operations), every lot must be traceable to a licensed source. Article 50 makes it a fault to be caught with minerals without proof of their origin: the person is liable to an administrative fine equal to 10% of the value of the minerals, and the minerals are confiscated so that RMB can sell them at auction. The fault applies to "any person", not only to licence holders, so it reaches transporters, warehouse keepers and unlicensed intermediaries as well as traders and processors.

The criminal offences go further. Possessing illegally extracted minerals is punishable by one to three years' imprisonment and a fine of RWF 30,000,000 to RWF 60,000,000, or one of these penalties; a company, cooperative or other legal person faces RWF 70,000,000 to RWF 90,000,000 and may be dissolved (Article 64). Trading in illegally extracted minerals is punishable by more than five and up to ten years' imprisonment and RWF 60,000,000 to RWF 120,000,000, or one of these penalties; a legal person faces RWF 130,000,000 to RWF 150,000,000 and may be dissolved (Article 65). In each case the court orders confiscation of the minerals for sale by auction. Mining without a licence, the usual source of illegally extracted minerals, carries two to five years and RWF 25,000,000 to RWF 50,000,000 (Article 63), and a landowner who lets unlicensed miners work its land commits an offence too (Article 66).

Proof of origin rests on records that the law requires in any event. A mining licence holder keeps technical and production records at its address in Rwanda and reports to RMB (Article 24); processing and trading licence holders must keep records of contracts and transactions with miners, suppliers, buyers, smelters, refineries and banks, together with assay reports and customs records, report quarterly, and send RMB or a designated laboratory a sample of any minerals to be exported (Articles 7 and 12 of Regulations N° 003/MINES/RMB/2019 of 18/07/2019). For 3T minerals, the iTSCi tags and logbooks described below are the practical proof that links a bag to a mine.

iTSCi in Rwanda: tags, logbooks and RMB's role

The International Tin Supply Chain Initiative (iTSCi) is an upstream traceability and due diligence programme developed by the tin industry body ITRI, now the International Tin Association, and operated with the non-governmental organisation Pact. According to RMB, the iTSCi pilot began in the DRC in June 2010, a memorandum of understanding between ITRI and the then Rwanda Natural Resources Authority was signed on 10 September 2010, and the Government implemented iTSCi nationwide in December 2010, making Rwanda the first country in the Great Lakes region to commit to nationwide implementation of a traceability and due diligence system. In March 2016 a second memorandum was signed with RCS Global Group, formerly the Better Sourcing Program, to provide supply chain due diligence and assurance services.

In Rwanda the scheme is run through RMB, which describes its role as follows: it distributes and manages tags and logbooks, weighs and tags all minerals produced at each mine site of mining companies and cooperatives, records production, follows up on risks, carries out joint inspections with the service providers, and handles the payments and fees related to chain of custody, keeping the chain-of-custody data in a database. Each bag of concentrate therefore carries a tag that links it to a mine and a logbook entry, and every subsequent sale, processing step and export must match that record. RMB describes iTSCi as a certification scheme for domestically produced 3T minerals that helps buyers meet the Dodd-Frank requirements and the Responsible Minerals Assurance Process (RMAP) used by smelters.

Two cautions apply. First, Be Rwanda Wise FAQ 108 describes ITSCI as run by RMB "jointly with iTSCi across Rwanda, Burundi, the DRC and Uganda"; the accurate position is that RMB runs the system in Rwanda with the iTSCi programme operators and RCS Global as service providers, and each country implements its own arrangements. Second, industry press reported in August 2024 that the Responsible Minerals Initiative (RMI) had suspended, in July 2024, its process for recognising ITSCI as an upstream assurance mechanism, "until 2026 at the earliest". Whether that review has concluded could not be confirmed at 10 October 2026, and some smelters apply additional checks to material from the region. RMB also lists a digital mineral traceability project among its key projects without publishing details; until RMB announces otherwise, iTSCi remains the system in use for 3T minerals. Gold is outside iTSCi, which is a tin, tantalum and tungsten scheme, and relies on licensing, RMB certification and the refiner's own due diligence.

Export certificates: MCIS and the ICGLR Regional Certification Mechanism

A company allowed to export minerals must request certification services from RMB online, through the Mineral Certification Information System (MCIS), which issues either a Mineral Export Certificate or an ICGLR Mineral Export Certificate. RMB's MCIS mobile application lets anyone verify that a printed certificate matches the record in MCIS, to prevent the use of fake certificates; a buyer should verify every certificate it receives. Before export, the trader or processor submits a sample of the lot to RMB or a designated laboratory (Regulations N° 003/MINES/RMB/2019), RMB determines grade and value for the tax on minerals, and the export tax on raw minerals is paid before the minerals leave Rwanda (Mineral tax, royalties and fiscal terms).

The Regional Certification Mechanism (RCM) of the International Conference on the Great Lakes Region (ICGLR) is a regional standard covering cassiterite, wolframite, coltan and gold. Under it, mine sites are inspected and classified green, yellow or red according to conflict and human rights risk, with a red classification leading to suspension of supplies from that site; chain-of-custody documentation follows each lot; traders report monthly; an independent ICGLR auditor reviews the system; and exports from member States must carry an ICGLR certificate. Rwanda implemented the RCM through Ministerial Regulations N° 002/2012/MINIRENA of 28/03/2012, under which an ICGLR certificate has been required since 15 December 2012. Those Regulations were made under a mining law that has since been repealed twice, and the International Energy Agency's policy database lists them as in force; RMB continues to issue ICGLR certificates through MCIS. Mining licence holders' model agreements under Regulations N° 004/MINES/RMB/2019 require compliance with the ICGLR traceability and certification mechanisms (Mining agreements, local content and community).

Exporting a lot of 3T minerals from Rwanda

1. Licensed sourceBuy only from holders of a valid RMB mining licence, or from licensed traders who can document such a source; check the licence on GIMCS and the mine site's ICGLR status.
2. Tag at the mineRMB weighs and tags each bag at the mine site and records it in the logbook and chain-of-custody database; untagged material cannot be documented.
3. Document each transferRecord every purchase and sale with the counterparty's licence, tag numbers, weights, grades and payments made through financial institutions in Rwanda (Regulations N° 003/MINES/RMB/2019, Article 12).
4. Sample and valueSubmit a sample to RMB or a designated laboratory; RMB determines grade, value and processing charges for the tax on minerals.
5. Apply on MCISRequest a Mineral Export Certificate or an ICGLR Mineral Export Certificate online through MCIS.
6. Pay the export tax and clear customsFor minerals in raw form, declare and pay the export tax before export; lodge the customs export declaration, which fixes the tax point, and pay withheld royalty within 15 days after the month.
7. Let the buyer verifySend the certificate and chain-of-custody documents; the buyer can verify the certificate with the MCIS mobile application.
8. ReportFile quarterly reports to RMB under the 2019 Regulations and keep all records for inspection and audit.

Gold: refining, taxation and heightened scrutiny

Gold is treated more lightly by the tax law and more strictly by everyone else. The tax on minerals on gold is 0.5% royalty plus, for raw exports, 0.5% export tax, against 6% under the 2013 law, and imported gold re-exported from Rwanda is expressly excluded from the exemption that applies to other imported minerals (Article 7(2) of Law N° 056/2024 of 26/06/2024 establishing tax on minerals). RMB stated in December 2025 that refining of gold, tin and tantalum was already operational in Rwanda, and processing licences under Regulations N° 003/MINES/RMB/2019 allow licensed refiners to import minerals in accordance with the relevant laws.

The sanctions history makes gold the highest-risk mineral in a Rwandan supply chain. On 17 March 2025 the Council of the European Union listed Gasabo Gold Refinery in Kigali, as "responsible for illegally importing gold from M23-controlled regions in the DRC", together with the then Chief Executive Officer of RMB, subjecting them to an asset freeze and travel ban. On 25 June 2026 OFAC designated Gasabo Gold Refinery LTD under Executive Order 13413, as amended, together with its chairman Jean Malic Kalima, its general manager Bosco Kayobotsi, and three companies it described as controlled by the chairman, Bugambira Mines LTD, Wolfram Mining and Processing LTD and Rwinkwavu Mining Corporation LTD. OFAC stated that at least 60 kg of gold were moved from eastern DRC to Gasabo Gold in early 2026, and that entities owned 50% or more by blocked persons are also blocked. A Rwandan export licence or RMB certificate does not protect a buyer that deals with a designated person; screening against the current lists is a separate step (Sanctions, due diligence and reforms; Anti-money laundering and sanctions compliance).

The OECD Guidance and what buyers expect

The reference standard for responsible sourcing from conflict-affected areas is the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. The Rwanda Development Board (RDB) states that Rwanda adheres to it, and in the Regional Economic Integration Framework signed with the DRC on 4 December 2025 both States committed to apply it and to make full use of the ICGLR RCM, with mine-to-export traceability and third-party audits (Strategic minerals and regional deals). The Guidance is not itself Rwandan law, but it is the standard that downstream rules and smelter audit programmes adopt, so a Rwandan supplier is in practice assessed against it.

For an upstream supplier, that means a written supply chain policy, a management system that identifies the mine of origin of every lot, an assessment of risks such as payments to armed groups, smuggled material entering the chain, child labour and serious human rights abuses, a plan to respond to the risks found, cooperation with audits of the smelters and refiners it supplies, and annual public reporting. Buyers will ask for documents that show each of these elements, and the table below lists the usual ones. Payments for minerals should go through formal financial institutions, as Regulations N° 003/MINES/RMB/2019 already require of licensed traders and processors and as the 2025 regional framework envisages for the whole region.

Foreign rules that reach Rwandan exporters

Regulation (EU) 2017/821, the EU Conflict Minerals Regulation, has applied since 1 January 2021 to EU importers of tin, tantalum, tungsten and gold above set volumes. It requires them to carry out supply chain due diligence based on the OECD Guidance, with third-party audits and reporting, which they pass upstream to their suppliers through contract terms and information requests. The European Commission recognised the RMI's Responsible Minerals Assurance Process as an industry due diligence scheme on 16 October 2025, and in 2026 began procurement for a review of the Regulation, with a prior information notice of 11 May 2026 and a call for tenders of 16 June 2026. The EU and Rwanda signed a memorandum of understanding on sustainable raw materials value chains on 19 February 2024; members of the European Parliament asked for its suspension in February 2025, and its current status could not be confirmed (Strategic minerals and regional deals).

In the United States, section 1502 of the Dodd-Frank Act, codified at 15 U.S.C. §78m, requires issuers that use tin, tantalum, tungsten or gold in their products to report whether the minerals originated in the "Democratic Republic of the Congo or an adjoining country", which includes Rwanda, on Form SD. Securities and Exchange Commission staff no-action relief has limited enforcement of parts of the rule since April 2017, but issuers still file Form SD, and filings for the 2025 calendar year were due by 1 June 2026. The duty falls on the issuer, not on the Rwandan exporter, but the issuer's due diligence travels down the chain to the smelter and from the smelter to its Rwandan suppliers, as Be Rwanda Wise FAQ 109 explains (FAQ 109).