Sanctioning an army mostly limits arms purchases and travel. Sanctioning the bank that pays for them reaches every institution in its payment chain. That is the significance of the US Treasury’s 28 October action against Zigama Credit and Savings Society, designated alongside Rwanda’s Ministry of Defence.
OFAC describes Zigama as “a Rwandan financial institution that operates on behalf of Rwanda’s security services”. Its case covers both payments and gold. Zigama “has facilitated payments to entities in China and additional countries for weapons, ammunition, and other military equipment for the RDF”. It also paid for RDF travel and accommodation for training. “A Zigama branch enabled the transportation of gold sourced from M23-controlled territory in eastern DRC to Kigali.” And Zigama “has facilitated financial transactions for M23 and the Congo River Alliance, amounting to tens of millions of dollars.”
Taken together, those activities describe a full financial chain. Money went out to buy equipment, money moved for M23 and its political wing, and gold flowed from the conflict zone into the Rwandan capital. Zigama sat at the centre of all of it.
The consequences for other institutions are set out in the release. Property of designated persons in the United States or held by US persons is blocked. US persons are generally barred from dealing with it. Non US persons are barred from causing US persons to violate sanctions. And “financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons.” That last line is the one compliance teams will focus on. Foreign banks that clear for Zigama now carry the risk themselves.
OFAC also writes that minerals from M23 controlled territory “are integrated into supply chains in Rwanda, whose domestic mining capacity is smaller than export volumes reported since M23’s rebellion began.” Put simply, the US government is saying Rwanda’s reported exports exceed what Rwanda can mine. Any bank financing those exports, or any buyer accepting Rwandan origin documents, now has that statement on the record from the US Treasury.
The Rwanda Defence Force was already sanctioned on 2 March 2026. The Congo River Alliance has a successor, the Front for the Refoundation of the Nation, which announced its formation on 12 October. Both new designations were made under Executive Order 13413, as amended.
Secretary of the Treasury Scott Bessent said: “Today, the United States makes good on President Trump’s promise to hold Rwanda accountable for its commitments under the Washington Accords for Peace and Prosperity. Rwanda must halt its support for M23 and withdraw its troops from eastern DRC.”
Digital Trade Outlook’s View: The Gold Trail Now Runs Through Compliance
Zigama connected payments, gold and armed groups, and OFAC has now cut that link. Banks with any exposure to it face secondary sanctions risk. Buyers relying on Rwandan origin documents face a US finding that exports outrun domestic mining. Legitimate Rwandan exporters will feel the tighter scrutiny first. Kigali loses room to deny its role.
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Image: US Department of the Treasury seal and Zigama CSS logo