United States Sanctions Two war kingpins in the Democratic Republic of Congo

The United States Department of the Treasury’s Office of Foreign Assets Control has imposed sanctions on commanders of the Democratic Forces for the Liberation of Rwanda and the March 23 Movement.

The Democratic Forces for the Liberation of Rwanda (FDLR) and M23 are the armed groups operating in the Democratic Republic of Congo (DRC) designated by the United States and United Nations (UN), with long histories of human rights abuse and regional destabilization. 

According to Thomas Pigott, the Spokesperson of the U.S Department of State, both the FDLR and M23 have violently occupied territory and killed civilians in eastern DRC. 

The sanctions target Gustave Kubwayo, the commander of an FDLR intelligence and special operations unit and John Imani Nzenze, an M23 commander and chief of intelligence, both of whom lead armed groups undermining stability in eastern DRC.

“President Trump has been clear that there is an urgent need to resolve the horrific conflict in eastern Democratic Republic of the Congo, and the United States is committed to peace and prosperity in the region,” said Secretary of the Treasury Scott Bessent. 

He said the United States is committed to working with international partners to help bring an end to decades of conflict, foster economic growth and cooperation, and build a foundation for peace and prosperity for the people of the DRC and Rwanda. 

“As such, the United States expects the DRC to neutralize FDLR and affiliated groups.  The United States also expects Rwanda to withdraw its troops and military equipment from the DRC and cease all support to M23, in accordance with the commitments outlined in the Washington Accords for Peace and Prosperity of December 4, 2025.”

 FDLR: Threat to peace and security

FDLR is a rebel group that formed in 2000 from the remnants of the ex-Rwandan Armed Forces and extremist militias that fled Rwanda in the wake of the 1994 Rwandan genocide. 

Over the course of its history, FDLR has waged a campaign of ethnically motivated violence against civilians, including summary killings, forced recruitment of children to take part in hostilities, and conflict-related sexual violence.

FDLR finances its activities by looting from civilians, imposing unlawful taxes, kidnapping people for ransom, illegal logging in Virunga National Park, and additional illegal activities. 

The armed group has also solicited support from DRC militias and Congolese Army units in the DRC’s North Kivu province, despite a DRC government ban on cooperation with FDLR. 

Office of Foreign Assets Control (OFAC) designated FDLR on January 3, 2013, pursuant to Executive Order (E.O.) 13413, for committing serious violations of international law involving the targeting of children in situations of armed conflict in the DRC, including killing and maiming, sexual violence, abduction, and forced displacement.

Gustave Kubwayo, commonly known as “Colonel Sirkoof,” is an FDLR commander and the leader of the Commando de Recherche et d’Action en Profondeur, an FDLR intelligence and special operations unit. 

In addition to this unit, Kubwayo led an FDLR operational command structure in North Kivu’s Nyiragongo territory that formed in 2022, after M23 attacks forced FDLR to geographically disperse. 

OFAC designated Kubwayo pursuant to E.O. 13413, as amended by E.O. 13671, for being a leader of FDLR, an entity whose property and interests in property are blocked pursuant to E.O.13413.  OFAC’s designation of Kubwayo was taken in close coordination with the United Nations.

March 23: A violent armed group

M23 is a Rwanda-backed armed group that occupies large portions of North and South Kivu provinces.  The armed group first emerged in the DRC in 2012, when it briefly controlled the border city of Goma, before being defeated in 2013 by the Congolese military with assistance from the UN Force Intervention Brigade.

 In April 2024, M23 seized Rubaya, a town at the center of an expansive mining area for coltan, a key material used in the production of electronic devices.  On July 8, 2024, the U.S. State Department issued a statement of concern related to mineral supply chains that contribute to ongoing instability in eastern DRC.

On November 15, 2025, the DRC government and M23 signed a peace framework agreement in Qatar.  Following the signing, M23 seized the strategic port city of Uvira located in South Kivu province along the DRC-Burundi border. 

Although M23 eventually withdrew from Uvira, the rebel group still controls Goma and Bukavu, the provincial capitals of North and South Kivu provinces, which M23 captured in January and February 2025, respectively. 

M23’s military campaigns have claimed the lives of thousands of civilians and resulted in a mass displacement crisis.  Over the course of its rebellion, M23 has also perpetrated human rights abuses, killings, attacks targeting noncombatants, and sexual violence.

OFAC designated M23 on January 3, 2013, pursuant to E.O. 13413, for committing serious violations of international law involving the targeting of children in situations of armed conflict in the DRC, including killing and maiming, sexual violence, abduction, and forced displacement, and for receiving arms and related materiel, including military aircraft and equipment, or advice, training, or assistance, including financing and financial assistance, related to military activities in the DRC.

John Imani Nzenze is an M23 commander and M23’s chief of intelligence. 

He is regarded as one of the closest collaborators and confidants of Sultani Makenga, the U.S.- and UN-sanctioned overall military commander of M23. 

Nzenze has been an M23 leader since the armed group’s first rebellion from 2012–2013, when he led M23 attacks on Congolese military positions.  OFAC designated Nzenze pursuant to E.O. 13413, as amended by E.O. 13671, for being a leader of M23, an entity whose property and interests in property are blocked pursuant to E.O.13413.  OFAC’s designation of Nzenze was taken in close coordination with the United Nations.

Sanctions implications

As a result of today’s action, all property and interests in property of the designated or blocked persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. 

In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. 

Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons.

Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons.  OFAC may impose civil penalties for sanctions violations on a strict liability basis. 

OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions. 

In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons. 

The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person.

 Non-U.S. persons are also prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions. 

Individuals located in the United States or abroad who provide information about sanctions violations to FinCEN’s Whistleblower Incentive Program may be eligible for awards if the information they provide leads to a successful enforcement action that results in monetary penalties exceeding US$1,000,000. 

The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the Specially Designated Nationals and Blocked Persons List (SDN List), but also from its willingness to remove persons from the SDN List consistent with the law.