Sanctions, due diligence and reforms: the EU listings of 17 March 2025, the US Treasury designations of 2 March and 25 June 2026 including the Gasabo Gold Refinery, who they bind and the 50 percent rule, what buyers, refiners, lenders and investors must do, Rwanda's own anti-money-laundering duties for mineral dealers, EU and US conflict-minerals rules, the 2024-26 reforms and the 2027 horizon

Why sanctions sit at the centre of mineral due diligence

Between March 2025 and June 2026 the European Union and the United States adopted three sets of measures that reach Rwanda's mineral sector: the European Union listings of 17 March 2025, the United States designations of the Rwanda Defence Force on 2 March 2026, and the United States designations of a Kigali gold refinery and three mining companies on 25 June 2026. This section describes them as the sanctioning authorities' own announcements and legal acts state them. They are measures of foreign governments under their own law; they are not findings of a Rwandan court, they do not change Rwandan law, and each regime provides a procedure by which a listed person may seek removal.

Their practical reach is nonetheless wide. Rwanda's mineral exports are priced and paid largely in United States dollars, sold to refiners and traders in Europe, Asia and North America, and financed by banks with international correspondent relationships. A buyer, smelter, lender, insurer or acquirer connected with the European Union or the United States must be able to show that no listed person, and no entity owned by one, is in its supply chain or its counterparty structure. Sanctions screening has therefore joined licence checks and traceability documents, explained in 3T, gold and traceability, as a standard part of any Rwandan mineral transaction.

The European Union listings of 17 March 2025

On 17 March 2025 the Council of the European Union adopted Council Implementing Decision (CFSP) 2025/510, implementing Decision 2010/788/CFSP concerning restrictive measures in view of the situation in the Democratic Republic of the Congo (DRC). According to the Council's announcement of that date, it listed nine individuals and one entity in response to the escalation of the conflict in eastern DRC. Two of the listings concern Rwanda's mineral sector. The entity is Gasabo Gold Refinery, based in Kigali, which the Council's announcement states imported gold from regions of the DRC controlled by the M23 armed group. One of the individuals is Francis Kamanzi, described in the announcement as chief executive of the Rwanda Mines, Petroleum and Gas Board (RMB), whom the Council lists in connection with the exploitation of and trade in natural resources. RMB has had a new chief executive since July 2025, as reported in the Rwandan press. The other listings concern leaders of M23 and three officers of the Rwanda Defence Force.

The measures are an asset freeze, a travel ban into or through the European Union, and a prohibition on European Union citizens and companies making funds or economic resources available to the listed persons. The Council stated that its autonomous measures for the DRC then applied to 32 individuals and 2 entities, alongside 53 listings by the United Nations. European Union sanctions bind persons within the territory of the Union, nationals of Member States wherever they are, companies incorporated in the Union, and any business done in whole or in part within the Union. A listed person may ask the Council to reconsider its listing and may challenge it before the General Court of the European Union.

The United States designations of 2 March and 25 June 2026

On 2 March 2026 the United States Department of the Treasury announced (press release sb0411) that OFAC had designated the Rwanda Defence Force under Executive Order 13413, as amended by Executive Order 13671, citing actions it said threatened the peace, security or stability of the DRC and material assistance to M23, and had designated four senior officers as leaders of the Rwanda Defence Force. On the same day OFAC published DRC-related General License 1, 'Authorizing the Wind Down of Transactions Involving the Rwanda Defence Force'; the licence text authorised wind-down transactions only until 12:01 a.m. eastern daylight time on 1 April 2026, and required any payment to a blocked person to be made into a blocked account. Because of the 50 percent rule, any entity owned 50 percent or more by the Rwanda Defence Force, alone or with other blocked persons, is also blocked, whether or not it is named.

On 25 June 2026 the Treasury announced (press release sb0543) the designation under Executive Order 13413, as amended, of Gasabo Gold Refinery LTD. According to the announcement, it was designated under two criteria of that Order: having materially assisted, sponsored or provided support for M23, and involvement in the illicit trade in natural resources of the DRC. OFAC designated at the same time the refinery's chairman, listed as Jean Malic Kalima Karekezi, and its general manager, Bosco Kayobotsi, as owned or controlled by, or acting for, the refinery; and three companies it describes as controlled by the chairman: Bugambira Mines LTD (also known as Multiserve Consults Ltd), Wolfram Mining and Processing LTD and Rwinkwavu Mining Corporation LTD, as owned or controlled by, or acting for, him. OFAC's list of Specially Designated Nationals and Blocked Persons (SDN List) records Kigali and Rwinkwavu addresses, company websites and, for the refinery, its Rwandan company number, which compliance teams should use for matching. OFAC's notice of that day lists no general licence for these designations.

The consequences stated in the Treasury's announcements are the same for both actions. All property and interests in property of the designated persons that are in the United States or in the possession or control of United States persons are blocked and must be reported to OFAC. Entities owned 50 percent or more, directly or indirectly, individually or in the aggregate, by one or more blocked persons are also blocked. Unless authorised by an OFAC general or specific licence or exempt, United States persons and transactions within or transiting the United States may not deal in blocked property, including by providing or receiving funds, goods or services. Civil penalties may be imposed on a strict liability basis, non-United States persons may not cause United States persons to violate the rules or engage in evasion, and the 25 June 2026 announcement states that 'financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions' with designated persons. Delisting is available through OFAC's petition procedure.

Who is bound, and where Rwandan law stands

The European Union and United States measures bind those within the jurisdiction of the sanctioning authority. A Rwandan company with no European or United States owners, staff, assets, bank accounts or payment flows is not itself subject to them as a matter of law. In practice few mineral businesses are in that position: payments in United States dollars normally clear through United States correspondent banks, buyers and refiners are often European or American or supply customers that are, and international lenders and insurers apply both regimes as a condition of their facilities. Rwandan banks with correspondent relationships typically screen against these lists under their own risk policies.

Rwanda's own sanctions law is narrower. Article 67 of Law N° 001/2025 of 22/01/2025 on the prevention and punishment of money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction concerns targeted financial sanctions related to terrorist financing and proliferation financing, with the role of the National Counter-terrorism Committee set by Prime Minister's Order, and Regulations N° 001/FIC/2025 of 15/01/2025 relating to targeted financial sanctions require reporting persons to freeze 'without delay but no later than 24 hours'. Those rules apply to the designations made under that regime; they do not, by themselves, give effect in Rwanda to European Union or United States listings. The full anti-money-laundering framework is explained in Anti-money-laundering and sanctions compliance.

Rwanda's own rules for mineral dealers and exporters

Rwandan law imposes its own controls on the mineral trade, independent of foreign sanctions. Under Article 8 of Law N° 001/2025, dealers in precious metals and precious stones are reporting persons, alongside banks, lawyers, accountants and others. Under Regulations N° 002/FIC/2026 of 22/06/2026 of the Financial Intelligence Centre (FIC), they must apply customer due diligence to occasional cash transactions of RWF 15,000,000 or more, linked transactions being added together, and report cash transactions at that level to the FIC within two working days; suspicious transactions of any amount, including attempted ones, must be reported within 24 hours, and tipping off is prohibited. A legal person that breaches its preventive duties faces a fine of RWF 5,000,000 to RWF 20,000,000 under Article 66 of the Law, and administrative fines under Regulations N° 001/FIC/2026. Beneficial owners holding 25% or more of shares or voting rights must be identified.

The Mining Law adds provenance offences. Under Law N° 072/2024 of 26/06/2024 on mining and quarry operations, a person found with minerals without proof of origin pays an administrative fine of 10% of their value and the minerals are confiscated for auction (Article 50); possessing illegally extracted minerals is punished by 1 to 3 years' imprisonment (Article 64); and trading in them by more than 5 and up to 10 years and a fine of RWF 60,000,000 to RWF 120,000,000, or RWF 130,000,000 to RWF 150,000,000 for a company, which may be dissolved (Article 65). Export certificates, including the certificate of the International Conference on the Great Lakes Region (ICGLR), are issued through RMB's online Mineral Certification Information System (MCIS). Mineral traders are among the persons deemed authorised to transact in foreign currency under the National Bank of Rwanda (BNR) Directive N° 4230/2025-00042 of 17/09/2025, and anyone crossing the border with RWF 10,000,000 or more in cash or bearer instruments must declare it.

What buyers, refiners and investors must do

The reference standard is the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Rwanda states that it adheres to it, the Regional Economic Integration Framework signed with the DRC on 4 December 2025 commits both States to it, and RMB's model agreements require compliance with traceability and certification mechanisms. Its five steps are: establish strong company management systems; identify and assess risks in the supply chain; design and implement a strategy to respond to identified risks; carry out an independent third-party audit of the due diligence of smelters and refiners; and report publicly each year on supply chain due diligence.

Sanctions screening is the layer on top. Every counterparty in the chain, from licence holder and trader to exporter, refiner and logistics provider, should be screened against the European Union consolidated list and the OFAC SDN List, together with its directors, shareholders and beneficial owners, and the ownership of each entity should be traced far enough to apply the 50 percent rule, which aggregates holdings of different blocked persons. Screening should be repeated at each shipment, because designations change. Transaction documents should check the RMB licence, the ICGLR or Mineral Export Certificate, the traceability tags and logbook entries, and the payment route. Industry schemes help but do not replace this work: the Responsible Minerals Initiative suspended its recognition process for the ITSCI traceability programme in July 2024, as reported in the trade press, while the European Commission recognised the Responsible Minerals Assurance Process for Regulation (EU) 2017/821 on 16 October 2025.

EU and United States conflict-minerals reporting

Regulation (EU) 2017/821 has applied since 1 January 2021 to importers into the European Union of tin, tantalum, tungsten and gold, their ores and metals, above set annual volumes. They must carry out supply chain due diligence in line with the OECD Guidance, obtain third-party audits and report. The European Commission published a prior information notice on 11 May 2026 and a call for tenders on 16 June 2026 for a review of the Regulation.

In the United States, section 1502 of the Dodd-Frank Act, codified at 15 U.S.C. §78m(p), requires issuers reporting to the Securities and Exchange Commission that use tin, tantalum, tungsten or gold originating in the DRC or an 'adjoining country', a term that includes Rwanda, to disclose it. The Commission's staff have applied no-action relief to parts of the rule since April 2017, but Form SD remains due by 31 May each year (on 1 June in 2026, because 31 May fell on a Sunday). The disclosure duty falls on the listed buyer, not on the Rwandan exporter, but buyers will ask exporters for the traceability and due diligence information they need (FAQ 109).

Investors, acquirers and lenders

Acquiring a Rwandan mining company or licence calls for sanctions and provenance diligence alongside the corporate, tax and land work described in Due diligence in Rwanda. The buyer should identify every direct and indirect shareholder, director and beneficial owner and screen them; review the target's sales to refiners and traders since at least 2024, including any dealings with the persons listed in 2025 and 2026; check the target's ICGLR certificates, traceability records and FIC reporting; and confirm that RMB's licence is in good standing. Transfers of a licence or of shares in its holder need RMB's prior written approval under Articles 16 to 18 of the Mining Law, and the gain is subject to 10% capital gains tax under Law N° 014/2025 of 27/05/2025 (Mining licences and quarry licences).

Contracts should contain sanctions warranties covering the counterparty and its owners, an undertaking to notify any designation, the right to suspend or terminate without liability if performance would breach applicable sanctions, and a payment clause avoiding channels that would involve blocked persons. Lenders will add sanctions and anti-corruption covenants, and RMB's model agreement already provides that nothing in it permits derogation from laws on anti-corruption, human rights and national security. Where a counterparty becomes listed during a contract, performance must stop to the extent the applicable regime requires, and any wind-down must rely on a licence from the sanctioning authority.

The reforms of 2024 to 2026

The legal framework for minerals has been rebuilt in two years. Law N° 056/2024 of 26/06/2024 establishing tax on minerals took effect on 5 July 2024, cutting royalties to between 0.5% and 3% and adding an export tax on raw minerals. Law N° 072/2024 on mining and quarry operations took effect on 24 July 2024, keeping the small-, medium- and large-scale mining licences and the special radioactive minerals licence of the 2018 law, adding a power to grant the Government a free carried interest (Article 49) and setting new faults and penalties. Law N° 014/2025 of 27/05/2025 raised capital gains tax to 10% and extended it to licence transfers. Ministerial Order N° 003/MoE/25 of 19/08/2025 replaced the environmental and social impact assessment rules. The anti-money-laundering framework was replaced by Law N° 001/2025 of 22/01/2025 and FIC regulations of January 2025 and June 2026.

Institutions and markets changed too. RMB launched competitive licensing rounds through its Mining Investment Pitchbook in May and December 2025, had a new chief executive from July 2025, and on 4 March 2026 the Cabinet appointed new senior managers of RMB, including a Division Manager for Mining Cadastre and Digital Information. Rwanda and the DRC signed their Peace Agreement on 27 June 2025 and the Regional Economic Integration Framework on 4 December 2025, when Rwanda also signed an economic framework with the United States, and in September 2026 the Government took a 25% stake in a tungsten venture with Almonty Industries (Strategic minerals and regional deals). Several instruments the 2024 Laws require have not yet been made, and RMB continues to apply its 2019 regulations in the meantime (The Mining Law 2024 and regulators).