The Trump Administration Sanctioned the Rwandan Army. What Next?

After weeks of anticipation, the United States finally delivered a response to what many within the U.S. administration felt was an affront to President Donald Trump by Rwanda. Just a few days after the signing of the Washington Accords by Rwandan president Paul Kagame and Congolese president Félix Tshisekedi, in the presence of their American counterpart, the Rwanda-backed March 23rd (M23) rebellion seized control of the city of Uvira, in South Kivu—the latest escalation in a conflict that has gone on for over five years.

This time, on March 2, the Trump administration went much further than its previous round of sanctions in 2025 (and certainly much further than any previous administrations), designating the Rwanda Defence Force (RDF)—its national army—and four of its highest ranking officers, for “actively supporting, training, and fighting alongside the M23.”

Rwanda’s response was swift but comparatively tepid given the scope of the action, “regret[ting] one-sided sanctions” that “misrepresent the reality and distort the facts of the conflict” in the eastern Democratic Republic of the Congo (DRC). The DRC, for its part, appeared thrilled, expressing its “deep gratitude” to the United States for its “determination and leadership in efforts to restore peace.”

On its face, the announcement is monumental: the designation of the entire Rwandan army by the Treasury Department’s Office of Foreign Assets Control (OFAC) explicitly recognizes the role that the Rwandan military, as an institution, plays in the DRC conflict. It is rare for an entire national army to be placed under U.S. sanction; think Iran, Eritrea, and the like. As an act of political communication, sanctioning the RDF is more a slap in the face than a strongly worded demand. And sanctions can be as much about sending political messages as they are about blocking access to resources.

In practice, the announcement means that the four RDF officers and the RDF itself, as well as any entities or property in which they own greater than 50% interest, cannot do business with or own any assets in the United States, and any assets they currently have in the U.S. or with U.S. institutions must be frozen. Effectively, it also means that none of the sanctioned individuals or entities can do business in U.S. dollars or, potentially in some cases depending on the details, with non-U.S. companies that do business in or have a corporate presence in the United States.

This may have limited short-term impact on the RDF’s capacity, since it can draw on an increasingly diverse set of arms sources, but longer-term effects could set in as secondary sanctions risks could outweigh the benefits to suppliers to keep arming the RDF. Other businesses linked to the RDF and the Rwandan Ministry of Defence (MoD), such as Horizon Group, could also be at risk. 

Rwanda’s reputation for opacity, and the notoriously complex ownership structures of Rwandan holding companies, will not be a benefit to it here Any U.S. companies or financial institutions will need to press hard for information to satisfy themselves that no sanctions violations may occur. Sanctions violations are imposed by OFAC on a per se/strict liability basis, meaning that no intention is required to be demonstrated and ignorance is no defense. De-risking by companies wary of involuntarily violating sanctions could have important effects, given that penalties can range up to $377,700 or twice the value of a transaction, amounts that can add up quickly. 

The administration’s action is therefore politically clear but operationally ambiguous, until we can see how it plans to follow it up with diplomatic pressure and enforcement. For example, Rwanda is the second largest UN peacekeeping troop contributing country. But U.S. sanctions regulations, including for the DRC, have an exception for the official business of the UN and other international organizations. This means that the UN is under no legal obligation to stop doing business with the RDF, although it could take a political decision to wind down Rwandan participation in peace operations. It may also be forced to take such a decision if the financial institutions or other companies through which the UN works refuse to process payments or engage in transactions with the RDF. Similarly, the nature of the legal relationship between the RDF and the Rwandan Ministry of Defence (MoD) may determine the extent to which these sanctions affect MoD holdings like the ones mentioned above. 

In sum, the action puts pressure on Rwanda by signaling how serious the U.S. administration is about getting it to stop interfering in eastern DRC, and it places a burden of compliance on companies doing business with the Rwandan army and related entities, including Total Energy’s operations in Northern Mozambique. To be clear, there were (and still are) human rights, conflict, and related due diligence risks already extant with respect to the RDF before the sanctions were imposed, so these questions for companies and other governments should not be new, but they have certainly been brought into sharper relief, and with much more significant consequences, through the sanctions action. 

Sanctions are not an end in themselves. As a policy tool, the U.S. DRC sanctions program is intended to disrupt actors that threaten peace, security, and stability in the DRC. Thus, there will need to be strong messaging, engagement, and a plan for additional, stronger sanctions, in order to maximize the impact over time. Additionally, their impact in bringing peace to eastern Congo will also depend on how others respond. If the European Union, United Kingdom, and other partners complement the U.S., either in form (by mirroring the designations) or practice (by encouraging their banks and companies to respect it, even with no actual designations), it would be a force multiplier, adding to the pressure on Rwanda and by extension, the M23. 

If the DRC feels emboldened by the U.S.’s targeting of the RDF, however, it could escalate the situation by further ramping up its drone attacks, like the one that recently killed M23 spokesperson Willy Ngoma. The DRC’s partners, including the U.S., must make clear that the new sanctions are not an endorsement of a military solution to the conflict, which Tshisekedi has tried and failed numerous times. Instead, the U.S. and others should use the political leverage created by the new designations to discourage Rwanda from doubling down on its support for the M23 while compelling both parties to resume their engagement in the peace process.

The sanctions mark a potential watershed moment; how the parties react, how companies and financial institutions implement them, and how the United States and allies work to bring about policy change will determine whether the watershed moment lasts, or just rolls down the river.

1. Joshua Z. Walker,  Program Director, Congo Research Group, Center on International Cooperation, New York University

2. Brad Brooks-Rubin, Partner, Arktouros pllc