Twenty-five individuals have been sanctioned by the Rwandan government for terrorism and terrorism financing, according to a new sanctions list released by the Financial Intelligence Centre (FIC) on Tuesday, October 14.

The list includes members of the FDLR, a DR Congo-based Rwandan militia linked to the 1994 Genocide against the Tutsi, as well as members of the RNC, MRCD, FLN, and affiliated militia groups.

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The term ‘designated person’ on the list refers to a person designated for their involvement in terrorism and/or terrorist financing.

The Financial Intelligence Centre has outlined restrictions and potential consequences for dealing with the 25 Rwandans sanctioned for terrorism.

All reporting entities, competent authorities, supervisory authorities, or any other persons have been instructed to screen names and addresses against the domestic sanctions list of ‘designated persons’ to verify whether the details match those of their clients.

If a match is found, the FIC states that the reporting entity must determine whether the designated person owns any funds or other assets.

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"The screening must also be conducted before establishing any business relationship. If no funds or other assets are identified, a report must be submitted to the FIC via report@fic.gov.rw without delay. If funds or other assets belonging to designated persons are identified, they must be immediately frozen or seized without prior notice to the designated person, and a report must be submitted to the FIC,” the agency said.

Prohibitions

All persons have been informed that it is prohibited to "make any funds or other assets, including economic resources, financial services, or other related services, available—directly or indirectly, wholly or jointly—for the benefit of a designated person; to an entity owned or controlled, directly or indirectly, by a designated person; or to a person or entity acting on behalf of, or at the direction of, a designated person.”

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It is also prohibited to engage in any dealings involving the funds or other assets of a designated person, including those wholly or jointly owned, held, or controlled—directly or indirectly—by the designated person; funds or assets derived from such sources; or those held by a person acting on behalf of or at the direction of a designated person.

Offences

"Failure to comply with these prohibitions constitutes an offence punishable by criminal sanctions as provided under Articles 59 and 60 of Law nº 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,” the FIC explained.

Article 59 states that a person who knows, or has reasonable grounds to believe, that funds or other assets are owned or controlled by a designated person—whether wholly, partly, or jointly, directly or indirectly—and who deals with such funds or assets, commits an offence.

Upon conviction, the offender is liable to imprisonment for a term of three years to five years, and a fine of Rwf3 million to Rwf5 million.

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Article 60 states that a person who makes funds, other assets, financial services, or any related services available—directly or indirectly—to or for the benefit of a designated person, an entity acting on behalf of or at the direction of a designated person, or an entity owned or controlled by a designated person, commits an offence.

Upon conviction, the offender is liable to imprisonment for a term of not less than three years and not more than five years, and a fine of not less than Rwf3 million and not more than Rwf5 million.

Restrictions

The Financial Intelligence Centre also informs all persons of additional restrictions that must be observed.

"It is prohibited to engage, directly or indirectly, in the manufacture, supply, sale, transfer, carriage, or delivery of arms and related equipment—including weapons, ammunition, military vehicles and equipment, paramilitary equipment and their spare parts—and the provision of technical advice, assistance, or training related to military activities, if the weapons or equipment are intended to be imported by a designated person or supplied to, or at the order of, a designated person.”

It is also prohibited for any person to use a vehicle, vessel, or aircraft from or to Rwanda—or any vessel or aircraft bearing the Rwandan flag outside Rwanda—for the carriage of weapons or related materials to or from, or for the use or benefit of, a designated person.

Non-compliance with these restrictions constitutes an offence punishable under Article 61.

This article states that a person who engages—directly or indirectly—in the manufacture, supply, sale, transfer, carriage, or delivery of arms and related equipment, including weapons, ammunition, military vehicles and equipment, paramilitary equipment and their spare parts, and the provision of technical advice, assistance, or training related to military activities, where such items are intended for import by or delivery to a designated person, commits an offence.

Upon conviction, the offender is liable to imprisonment for a term of not less than ten years and not more than fifteen years, and a fine of not less than Rwf5 million and not more than Rwf10 million.