Rwanda Under Scrutiny: AGOA Violations Tied to Sexual Violence, Child Soldiers, & Killings

Accountability for Rwanda: M23 Militia Atrocities Violate AGOA & International Law

The Donald Trump Administration faces mounting pressure to address Rwanda’s continued support for the M23 militia, a group implicated in severe human rights abuses in the Democratic Republic of the Congo (DRC). This backing violates key provisions of the African Growth and Opportunity Act (AGOA), specifically Section 104 Subsections (A)(2) and (A)(3), which mandate adherence to U.S. national security interests and human rights standards.

The Strategic Importance of the DRC

The DRC is a critical region for global supply chains due to its vast mineral wealth, including cobalt, coltan, and gold—resources essential for technology, renewable energy, and defense industries. Instability fuelled by armed groups like M23 threatens U.S. economic and geopolitical interests by disrupting access to these critical materials. In January 2025, M23’s seizure of Goma, the largest city in eastern DRC, resulted in nearly 3,000 civilian deaths and displaced over 500,000 people , exacerbating an already dire humanitarian crisis.

Rwanda’s sponsorship of M23 has been a major driver of this instability. According to credible reports from the U.S. Department of State , the United Nations (UN) , and human rights organizations, Rwandan military personnel provide training, arms, and operational guidance to M23 fighters. This “de facto control” makes Rwanda complicit in the militia’s atrocities under international law.

Gross Human Rights Violations Linked to Rwanda

M23’s violent campaigns have included:

Extrajudicial Killings: Between January 26 and 28, 2025, M23 summarily executed at least 12 civilians during its offensive in Goma.
Sexual Violence as a Weapon of War: Reports from Human Rights Watch and Amnesty International document rampant sexual violence targeting women and girls in both public and private settings.
Recruitment of Child Soldiers: M23 forcibly recruits children, violating international laws protecting minors.
Forced Displacement: Over 500,000 civilians were displaced during M23’s recent offensive, adding to the millions already uprooted by decades of conflict.

These actions constitute gross violations of internationally recognized human rights and align with definitions of war crimes and crimes against humanity under the Geneva Conventions and the Rome Statute of the International Criminal Court (ICC) .

Undermining U.S. National Security and Foreign Policy Goals

Rwanda’s involvement with M23 directly undermines U.S. efforts to promote stability and accountability in Africa. By destabilizing the DRC, Rwanda threatens regional peace and complicates multilateral initiatives supported by Washington, including those led by the UN and the African Union (AU). For example:

M23’s attacks on UN peacekeepers and humanitarian workers hinder efforts to protect civilians and deliver aid.
The conflict spills over into neighboring countries, creating cross-border tensions and refugee flows that strain regional alliances.

Moreover, Rwanda’s defiance of repeated calls from the U.S. government and international bodies to cease its involvement with M23 demonstrates a blatant disregard for U.S. foreign policy priorities.

Calls for Accountability and Action

To uphold the integrity of AGOA and promote accountability, experts recommend the following steps:

Reevaluate Rwanda’s AGOA Eligibility: Conduct a formal review of Rwanda’s compliance with AGOA criteria and suspend trade benefits if violations persist.
Impose Targeted Sanctions: Implement sanctions against Rwandan officials and entities involved in supporting M23, including asset freezes and travel bans.
Strengthen Diplomatic Pressure: Work with African nations, the AU, and the International Conference on the Great Lakes Region (ICGLR) to demand Rwanda’s immediate cessation of support for M23.
Support Accountability Mechanisms: Advocate for investigations into M23’s atrocities through mechanisms like the ICC and allocate resources for transitional justice initiatives in the DRC.

Why This Is significant for the U.S. and Africa

Addressing Rwanda’s violations is crucial not only for ensuring compliance with AGOA but also for advancing broader U.S. strategic objectives in Africa. By taking decisive action, the Donald Trump Administration can:

Promote human rights and sustainable development in the region.
Counter the influence of adversarial powers seeking to exploit instability in Africa.
Reaffirm U.S. leadership in fostering peace, stability, and accountability.

Detailed Analysis of Rwanda’s Violation of AGOA Section 104 Subsection (A)(2) & (A)(3)

The African Growth and Opportunity Act (AGOA) is designed to promote economic growth and development in sub-Saharan Africa by providing trade preferences for eligible countries. However, these benefits are contingent upon beneficiary countries adhering to specific criteria outlined in the legislation. Two critical requirements under Section 104 are:

Subsection (A)(2): Countries must not engage in activities that undermine United States national security or foreign policy interests.
Subsection (A)(3): Countries must not engage in gross violations of internationally recognized human rights and must cooperate with efforts to eliminate such violations.

Rwanda’s continued support for the M23 militia—a group widely documented as committing atrocities and destabilizing the Democratic Republic of the Congo (DRC)—raises serious concerns about its compliance with these provisions. Below is a detailed analysis of how Rwanda’s actions contravene AGOA requirements:

Violation of Section 104(A)(2): “Engaging in Activities That Undermine United States National Security or Foreign Policy Interests”

1. Undermining Regional Stability and U.S. Strategic Interests

Destabilization of the DRC: The DRC is a geopolitically significant country due to its vast mineral resources, including cobalt, coltan, and gold, which are essential for global supply chains, particularly in technology and defense industries. Instability in the DRC threatens U.S. economic and security interests by disrupting access to these critical resources.
- Rwanda’s backing of M23 has directly contributed to escalating violence in eastern DRC, resulting in massive civilian casualties, displacement, and humanitarian crises. For example:
  - In January 2025, M23 seized Goma, leading to nearly 3,000 deaths and displacing over 500,000 civilians.
  - This destabilization undermines U.S. efforts to promote peace and stability in Central Africa, a key component of its regional strategy.
Impact on Neighboring Countries: The conflict fueled by M23 spills over into neighboring states like Uganda and Burundi, further complicating U.S. diplomatic and security initiatives in the Great Lakes Region.

2. Threatening U.S.-Led Multilateral Efforts

The United States has long supported multilateral efforts, including those led by the United Nations, to stabilize the DRC and address root causes of conflict. Rwanda’s sponsorship of M23 undermines these efforts by:
- Attacking UN peacekeepers and humanitarian workers, as documented in 2025.
- Disrupting humanitarian operations, exacerbating suffering among vulnerable populations.
Such actions contradict U.S. foreign policy goals of fostering cooperation and resolving conflicts through diplomacy and international institutions.

3. Contradicting U.S. Calls for Accountability

The U.S. government has repeatedly condemned Rwanda’s involvement with M23 and called for accountability. Despite these warnings, Rwanda has persisted in supporting the militia, signalling a disregard for U.S. foreign policy priorities.
This defiance weakens U.S. influence in the region and emboldens other actors who may seek to challenge international norms.

Violation of Section 104(A)(3): “Gross Violations of Internationally Recognized Human Rights”

1. Complicity in Atrocities Committed by M23

Rwanda’s direct support for M23 makes it complicit in the militia’s widespread and systematic human rights abuses. Key examples include:
- Extrajudicial Killings: M23 summarily executed at least 12 civilians between January 26 and 28, 2025, during its offensive in Goma.
- Sexual Violence: M23 fighters have used sexual violence as a weapon of war, targeting women and girls in both public and private settings. Reports from Human Rights Watch and Amnesty International detail rapes, gang rapes, and sexual enslavement.
- Recruitment of Child Soldiers: M23 has forcibly recruited children into its ranks, violating international laws protecting minors.
These acts constitute gross violations of internationally recognized human rights and align with definitions of war crimes and crimes against humanity.

2. Failure to Cooperate with Efforts to Eliminate Human Rights Violations

AGOA requires beneficiary countries to cooperate with international efforts to eliminate human rights abuses. Rwanda’s actions demonstrate a lack of cooperation:
- Instead of disarming M23, Rwanda provides training, arms, and operational guidance, enabling the group to carry out atrocities.
- Rwanda has ignored calls from the UN, the U.S., and other international bodies to cease its involvement with M23.
This non-compliance violates AGOA’s mandate for cooperation and accountability.

3. Systematic Targeting of Civilians

M23’s deliberate targeting of civilians suspected of supporting rival groups or the Congolese army reflects a pattern of systematic human rights abuses. Examples include:
- Indiscriminate shelling of civilian-populated areas, resulting in civilian injuries and deaths.
- Raids on villages where fighters shoot indiscriminately, loot homes, and burn property.
These tactics terrorize local populations and exacerbate the humanitarian crisis, forcing millions to flee their homes.

Legal and Ethical Implications

1. Responsibility Under International Law

As a state actor, Rwanda bears responsibility for the actions of M23 under principles of state responsibility. By exercising “de facto control” over M23 operations, Rwanda is legally accountable for the militia’s crimes.
This accountability extends to violations of international humanitarian law, including the Geneva Conventions and the Rome Statute of the International Criminal Court (ICC).

2. Ethical Obligations

Supporting a militia implicated in atrocities contradicts ethical norms and undermines Rwanda’s credibility as a responsible member of the international community.
It also tarnishes Rwanda’s reputation as a beneficiary of AGOA, which is intended to reward countries committed to good governance and human rights.

Rwanda’s Non-Compliance with AGOA Criteria

Based on the evidence presented, Rwanda’s support for M23 clearly violates AGOA Section 104 Subsections (A)(2) and (A)(3). By engaging in activities that undermine U.S. national security and foreign policy interests while facilitating gross human rights violations, Rwanda fails to meet the statutory requirements for AGOA eligibility.

To uphold the integrity of AGOA and promote accountability, the U.S. government should take decisive action, including:

Conducting a formal review of Rwanda’s AGOA eligibility.
Suspending trade benefits if Rwanda continues to support M23.
Imposing targeted sanctions on Rwandan officials and entities involved in backing M23.
Advocating for investigations into M23’s atrocities and holding perpetrators accountable through judicial mechanisms.

By addressing Rwanda’s violations, the U.S. can reaffirm its commitment to promoting human rights, stability, and sustainable development in Africa while ensuring that AGOA benefits are reserved for countries that genuinely adhere to its principles.

Detailed Explanation of Rwanda’s Violation of Section 104(A)(2): “Engaging in Activities That Undermine United States National Security or Foreign Policy Interests”

Section 104(A)(2) of the African Growth and Opportunity Act (AGOA) requires beneficiary countries to refrain from engaging in activities that undermine U.S. national security or foreign policy interests. Rwanda’s continued support for the M23 militia, which has destabilized the Democratic Republic of the Congo (DRC) and the broader Great Lakes Region, constitutes a clear violation of this provision. Below is an expanded analysis of how Rwanda’s actions contravene this requirement:

1. Destabilization of the Democratic Republic of the Congo (DRC)

The Strategic Importance of the DRC

The DRC is one of the most resource-rich countries in the world, possessing vast reserves of minerals critical to global supply chains, including cobalt, coltan, copper, and gold. These resources are essential for industries such as technology, renewable energy, and defense.
- Cobalt: The DRC produces approximately 70% of the world’s cobalt, a key component in lithium-ion batteries used in electric vehicles, smartphones, and other high-tech devices.
- Coltan: This mineral, abundant in the eastern DRC, is vital for manufacturing capacitors used in electronics.
- Gold: Illicit trade in conflict minerals, including gold, funds armed groups like M23, perpetuating violence and undermining legitimate economic development.
Instability in the DRC directly threatens U.S. economic and geopolitical interests by:
- Disrupting access to these critical resources, which are essential for maintaining U.S. competitiveness in global markets.
- Creating opportunities for adversarial powers, such as China, to expand their influence in Africa by exploiting the chaos.

Rwanda’s Role in Fuelling Instability

Rwanda’s sponsorship of M23 has been a major driver of instability in eastern DRC. Key examples include:
- Seizure of Goma (January 2025): M23’s capture of Goma, the largest city in eastern DRC, marked a significant escalation in the conflict. The offensive resulted in:
  - Nearly 3,000 civilian deaths , including women, children, and elderly individuals.
  - Over 500,000 people displaced , exacerbating an already dire humanitarian crisis. The DRC is home to over 2 million internally displaced persons (IDPs) due to ongoing violence, with M23 playing a central role in this displacement.
- Humanitarian Impact: The seizure of Goma disrupted access to food, water, healthcare, and shelter for hundreds of thousands of civilians. Humanitarian organizations reported widespread malnutrition, disease outbreaks, and psychological trauma among affected populations.
- Economic Consequences: The conflict has devastated local economies, destroying infrastructure, disrupting trade routes, and deterring investment in the region.

Broader Regional Implications

The destabilization of the DRC has ripple effects across Central and East Africa, threatening regional stability and complicating U.S. efforts to promote peace and prosperity in the continent.
- Neighboring Countries: Violence in the DRC spills over into neighboring states, including Uganda, Burundi, and Tanzania, creating cross-border tensions and fueling refugee flows.
- Regional Alliances: Rwanda’s involvement in the conflict undermines trust among African nations, weakening regional alliances that the U.S. relies on to address shared challenges.

2. Undermining Regional Stability

Challenging Multilateral Efforts

The resurgence of M23, backed by Rwandan forces, has undermined multilateral initiatives aimed at promoting peace and stability in the Great Lakes Region. For example:
- Attacks on UN Peacekeepers: M23 has repeatedly targeted United Nations Organization Stabilization Mission in the Democratic Republic of the Congo (MONUSCO) personnel. In 2025 alone, several peacekeepers were killed or injured during M23 offensives.
  - These attacks not only endanger lives but also hinder MONUSCO’s ability to fulfill its mandate of protecting civilians and facilitating humanitarian aid delivery.
- Disruption of Humanitarian Operations: M23 fighters have fired upon UN displacement sites, killing at least two children and destroying shelters. Such actions obstruct efforts to provide life-saving assistance to vulnerable populations.

Complicating U.S. Diplomatic Goals

The U.S. has long supported diplomatic solutions to conflicts in the Great Lakes Region, including through partnerships with the African Union (AU), the International Conference on the Great Lakes Region (ICGLR), and other stakeholders.
- Rwanda’s backing of M23 complicates these efforts by:
  - Undermining confidence-building measures between the DRC and its neighbors.
  - Encouraging other actors to pursue militarized approaches rather than peaceful negotiations.

3. Impact on U.S.-Rwanda Relations

Contradicting U.S. Calls for Accountability

The U.S. government has consistently condemned Rwanda’s involvement with M23 and called for accountability. For example:
- In 2022, the U.S. Department of State issued statements urging Rwanda to cease its support for M23 and respect the sovereignty of the DRC.
- Despite these warnings, Rwanda has persisted in arming, training, and directing M23 operations, demonstrating a disregard for U.S. foreign policy priorities.

Weakening U.S. Influence

Rwanda’s defiance weakens U.S. influence in the region by:
- Sending a message that Washington’s calls for restraint and cooperation can be ignored without consequences.
- Emboldening other actors who may seek to challenge international norms or pursue aggressive policies.

Straining Bilateral Ties

Rwanda’s actions strain its relationship with the U.S., particularly given the historical partnership between the two countries. Key areas of tension include:
- Trade Preferences: Rwanda’s eligibility for AGOA benefits is contingent upon adherence to human rights and foreign policy criteria. Continued support for M23 jeopardizes these privileges.
- Security Cooperation: The U.S. provides military training and assistance to Rwanda under various programs. However, Rwanda’s use of these resources to destabilize the DRC raises ethical and legal concerns.

Rwanda’s Actions Undermine U.S. Interests

Rwanda’s support for M23 represents a direct violation of Section 104(A)(2) of AGOA. By engaging in activities that destabilize the DRC, undermine regional stability, and contradict U.S. foreign policy priorities, Rwanda has demonstrated a blatant disregard for the principles underlying AGOA eligibility.

To address this issue, the U.S. government should:

Conduct a Formal Review: Evaluate Rwanda’s compliance with AGOA criteria and consider suspending trade benefits if violations persist.
Impose Targeted Sanctions: Hold Rwandan officials and entities accountable for their role in supporting M23.
Strengthen Diplomatic Pressure: Work with international partners to demand Rwanda’s immediate cessation of support for M23 and cooperation with efforts to restore peace in the DRC.

By taking decisive action, the U.S. can uphold the integrity of AGOA, promote accountability, and advance its strategic interests in Africa.

Detailed Explanation of Rwanda’s Violation of Section 104(A)(3): “Gross Violations of Internationally Recognized Human Rights”

Section 104(A)(3) of the African Growth and Opportunity Act (AGOA) requires beneficiary countries to refrain from engaging in gross violations of internationally recognized human rights and to cooperate with efforts to eliminate such violations. Rwanda’s continued support for the M23 militia, which has committed widespread atrocities in the Democratic Republic of the Congo (DRC), constitutes a clear violation of this provision. Below is an expanded analysis of how Rwanda’s actions contravene AGOA’s human rights requirements:

1. Direct Involvement in Atrocities Committed by M23

Credible Documentation of Human Rights Abuses

Reports from authoritative sources, including the U.S. Department of State, the United Nations (UN), Human Rights Watch (HRW), and Amnesty International, consistently document the severe human rights violations perpetrated by M23. These include:
- Extrajudicial Killings: M23 fighters have summarily executed civilians suspected of supporting rival groups or the Congolese army. For example:
  - Between January 26 and 28, 2025, M23 summarily executed at least 12 civilians during its offensive in Goma. Witnesses reported that these killings were carried out in public spaces, instilling fear among local populations.
  - The UN documented additional cases of extrajudicial killings, including instances where entire families were targeted and killed.
- Sexual Violence: M23 has systematically used sexual violence as a weapon of war, targeting women and girls in both public and private settings. HRW and Amnesty International have reported numerous cases of gang rape, sexual enslavement, and forced marriages.
- Recruitment of Child Soldiers: M23 forcibly recruits children into its ranks, violating international laws protecting minors. Children as young as 12 have been abducted from schools and villages and forced to fight on the front lines.
- Forced Displacement: M23’s attacks on civilian populations have resulted in massive displacement. According to the UN, over 500,000 people were displaced during M23’s seizure of Goma in January 2025 alone, exacerbating an already dire humanitarian crisis.

Rwanda’s Responsibility Under International Law

Under principles of state responsibility, Rwanda bears responsibility for the atrocities committed by M23 because it exercises “de facto control” over the militia’s operations. Evidence supporting this claim includes:
- Training and Arming: Rwandan military personnel have provided training and high-tech weaponry to M23 fighters, enabling them to carry out violent campaigns.
- Operational Guidance: UN reports indicate that Rwandan officers oversee M23 operations, issuing orders and coordinating attacks.
- Logistical Support: Rwanda provides logistical support, including medical care and transportation, to M23 fighters injured in combat.
This level of involvement makes Rwanda complicit in M23’s crimes under international law, including the Geneva Conventions and the Rome Statute of the International Criminal Court (ICC).

2. Use of Sexual Violence as a Weapon of War

Prevalence of Sexual Violence

Sexual violence is a hallmark of M23’s tactics, targeting vulnerable populations to terrorize communities and assert control. Key findings include:
- Public and Private Settings: HRW and the UN have documented rapes occurring in both public spaces (e.g., markets, roadsides) and private settings (e.g., homes). These acts are often accompanied by physical mutilation and verbal threats.
- Psychological Trauma: Survivors of sexual violence face long-term physical and psychological consequences, including injuries, sexually transmitted infections, unwanted pregnancies, and stigma within their communities.
- Impact on Society: The systematic use of sexual violence undermines social cohesion and perpetuates cycles of trauma, particularly in regions already affected by decades of conflict.

Violation of International Norms

Sexual violence as a weapon of war violates fundamental human rights enshrined in international treaties, including:
- The Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW) .
- The Rome Statute of the ICC , which classifies sexual violence as a war crime and crime against humanity when committed systematically or on a widespread basis.

Rwanda’s Complicity

By supporting M23, Rwanda indirectly facilitates these abuses. Its failure to prevent or address sexual violence further underscores its non-compliance with AGOA’s human rights criteria.

3. Systematic Targeting of Civilians

Patterns of Abuse

M23’s deliberate targeting of civilians reflects a pattern of systematic human rights abuses. Examples include:
- Indiscriminate Shelling: M23 fighters have indiscriminately shelled civilian-populated areas, resulting in civilian casualties and destruction of property. Medical facilities in Goma reported treating dozens of civilians injured by shrapnel during M23’s offensive.
- Village Raids: Fighters enter villages, shoot indiscriminately, loot homes, and burn property. Survivors describe chaotic scenes of terror, with families separated and livelihoods destroyed.
- Ethnic and Political Motives: M23 often targets individuals based on perceived ethnic affiliations or political allegiances, exacerbating divisions within affected communities.

War Crimes and Crimes Against Humanity

These actions align with definitions of war crimes and crimes against humanity under international law, including:
- Murder: Deliberate killings of civilians constitute murder, a grave breach of the Geneva Conventions.
- Persecution: Systematic targeting of specific groups based on ethnicity or political affiliation qualifies as persecution, a crime against humanity.
- Forced Displacement: Deliberately displacing civilians through violence violates international humanitarian law.

4. Failure to Cooperate with International Efforts

Ignoring Calls for Accountability

Despite repeated calls from the UN, the U.S., and other international bodies, Rwanda has refused to cease its involvement with M23 or cooperate with efforts to address human rights violations. Examples include:
- Disregard for UN Resolutions: The UN Security Council has passed multiple resolutions condemning M23’s activities and demanding disarmament. Rwanda’s continued backing of the militia undermines these efforts.
- Obstruction of Investigations: Rwanda has obstructed investigations into M23’s atrocities by denying access to investigators and withholding information.

Non-Compliance with AGOA Requirements

AGOA requires beneficiary countries to cooperate with efforts to eliminate human rights abuses. Rwanda’s actions demonstrate a lack of cooperation, including:
- Providing material support to M23 despite evidence of its crimes.
- Failing to hold accountable those responsible for atrocities committed by M23.

Rwanda’s Gross Violations of Human Rights

Rwanda’s support for M23 represents a clear violation of Section 104(A)(3) of AGOA. By facilitating gross violations of internationally recognized human rights—including extrajudicial killings, sexual violence, recruitment of child soldiers, and forced displacement—Rwanda fails to meet the statutory requirements for AGOA eligibility. Furthermore, its refusal to cooperate with international efforts to address these abuses underscores its disregard for human rights norms.

To uphold the integrity of AGOA and promote accountability, the U.S. government should:

Reevaluate Rwanda’s Eligibility: Conduct a formal review of Rwanda’s compliance with AGOA criteria and suspend benefits if violations persist.
Advocate for Investigations: Support investigations into M23’s atrocities and hold perpetrators accountable through judicial mechanisms.
Strengthen Diplomatic Pressure: Work with international partners to demand Rwanda’s immediate cessation of support for M23 and cooperation with efforts to restore peace and justice in the DRC.

By addressing Rwanda’s violations, the U.S. can reaffirm its commitment to promoting human rights and sustainable development in Africa while ensuring that AGOA benefits are reserved for countries that genuinely adhere to its principles.

Expanded Analysis of Evidence Supporting Rwanda’s Non-Compliance with AGOA

To substantiate claims that Rwanda has violated Section 104(A)(2) and (A)(3) of the African Growth and Opportunity Act (AGOA), it is essential to examine the robust body of evidence provided by authoritative sources. These include reports from the U.S. Department of State, findings by the United Nations (UN) Group of Experts, investigations by human rights organizations such as Human Rights Watch (HRW) and Amnesty International, and media coverage from outlets like The Guardian and analyses by the International Crisis Group. Below is an expanded discussion of how each source highlights Rwanda’s non-compliance:

1. U.S. Department of State Reports

Annual Country Reports on Human Rights Practices

The U.S. Department of State’s annual Country Reports on Human Rights Practices provide comprehensive documentation of human rights abuses committed by armed groups in the Democratic Republic of the Congo (DRC), including M23. Key findings include:
- Brutal Tactics: The reports detail M23’s use of extreme violence against civilians, including executions of adults and children, torture, abductions, and forced recruitment.
  - For example, the 2025 report highlighted that M23 summarily executed at least 12 civilians during its offensive in Goma, targeting individuals suspected of supporting rival groups or the Congolese army.
- Sexual Violence: The reports emphasize M23’s systematic use of sexual violence as a weapon of war, targeting women and girls in both public and private settings.
- Forced Displacement: The militia’s attacks have displaced hundreds of thousands of civilians, exacerbating the humanitarian crisis in eastern DRC.

Rwanda’s Complicity

The reports underscore Rwanda’s complicity in these abuses by highlighting its role in supporting M23:
- Training and Arming: The State Department has repeatedly noted that Rwandan military personnel provide training, arms, and logistical support to M23 fighters.
- Operational Control: The reports confirm that Rwanda exercises “de facto control” over M23 operations, making it accountable for the group’s actions under international law.

Impact on U.S. Foreign Policy

By documenting Rwanda’s involvement with M23, the State Department underscores how this relationship undermines U.S. foreign policy objectives, including efforts to promote stability, human rights, and accountability in the Great Lakes Region.

2. UN Group of Experts Findings

Role of the UN Group of Experts

The UN Group of Experts on the DRC is tasked with investigating violations of sanctions and arms embargoes in the region. Its findings provide some of the most credible and detailed evidence of Rwanda’s support for M23:
- Training and Arming: The Group has consistently reported that Rwandan military officers train M23 recruits in camps within Rwanda. High-tech weaponry, including heavy machine guns and rocket launchers, has been traced back to Rwandan military stockpiles.
- Operational Guidance: The Group has documented instances where Rwandan officers issue direct orders to M23 commanders, effectively controlling the militia’s operations.
- Logistical Support: Rwanda provides medical care, transportation, and other logistical assistance to M23 fighters injured in combat.

Confirmation of Rwanda’s Direct Role

The Group’s findings confirm Rwanda’s direct role in enabling M23’s violent activities. For example:
- In its 2025 report, the Group identified specific Rwandan military units involved in coordinating M23’s seizure of Goma, which resulted in nearly 3,000 civilian deaths and the displacement of over 500,000 people .
- The report also highlighted Rwanda’s obstruction of UN investigations by denying access to key locations and withholding information.

Undermining Multilateral Efforts

Rwanda’s actions directly undermine multilateral efforts to stabilize the DRC and address root causes of conflict. By supporting M23, Rwanda challenges the credibility of UN peacekeeping missions and complicates diplomatic initiatives supported by the U.S. and other international actors.

3. Human Rights Organizations

Human Rights Watch (HRW)

HRW has extensively documented M23’s atrocities and linked them back to Rwandan support. Key findings include:
- Killing of Civilians: HRW has reported numerous cases of extrajudicial killings, including incidents where M23 fighters executed entire families suspected of supporting rival groups.
- Recruitment of Child Soldiers: The organization has documented M23’s forcible recruitment of children, violating international laws protecting minors.
- Sexual Violence: HRW has highlighted rampant sexual violence perpetrated by M23, including gang rapes, sexual enslavement, and forced marriages.
- Humanitarian Impact: The group emphasizes the devastating impact of Rwanda’s actions on local communities, including widespread displacement, destruction of property, and long-term trauma.

Amnesty International

Amnesty International has corroborated HRW’s findings and provided additional context:
- Extrajudicial Killings and Enforced Disappearances: Amnesty has documented cases where M23 fighters killed civilians suspected of collaborating with rival groups or government forces.
- Forced Displacement: The organization notes that thousands of people have been forcibly displaced due to M23’s violence, exacerbating the humanitarian crisis in eastern DRC.
- Accountability Gap: Amnesty criticizes Rwanda’s failure to cooperate with investigations into M23’s crimes, highlighting a lack of accountability for perpetrators.

Linking Abuses to Rwanda

Both HRW and Amnesty International explicitly link M23’s atrocities to Rwanda’s support, emphasizing that Rwanda’s provision of training, arms, and operational guidance enables the militia to carry out these abuses.

4. Media Coverage

The Guardian

Articles in The Guardian have covered various aspects of M23’s resurgence and its reliance on Rwandan backing:
- Mass Killings and Sexual Violence: Reports detail mass killings and rampant sexual violence committed by M23, particularly against women and children.
- Displacement and Terror: Interviews with displaced individuals reveal harrowing experiences of fleeing from M23 attacks, describing sudden raids where fighters entered villages, shot indiscriminately, and terrorized communities.
- Rwandan Involvement: The articles corroborate claims of Rwanda’s involvement, citing eyewitness accounts and leaked documents that implicate Rwandan military personnel in M23 operations.

International Crisis Group

Analyses by the International Crisis Group provide additional context on M23’s resurgence and its destabilizing impact:
- Systematic Violence: The group notes that M23 utilizes systematic violence and intimidation against local populations, specifically targeting individuals based on suspected affiliations with rival groups or government forces.
- Regional Instability: The analysis emphasizes the detrimental impact of M23’s violent strategies on regional stability, noting that Rwanda’s support for the militia undermines efforts to resolve conflicts in the Great Lakes Region.

Overwhelming Evidence of Non-Compliance

The evidence provided by the U.S. Department of State, the UN Group of Experts, human rights organizations, and media outlets overwhelmingly demonstrates Rwanda’s non-compliance with AGOA requirements. Key points include:

Complicity in Atrocities: Rwanda’s support for M23 enables the militia to commit gross violations of internationally recognized human rights, including extrajudicial killings, sexual violence, and forced displacement.
Undermining Regional Stability: Rwanda’s actions destabilize the DRC and the broader Great Lakes Region, undermining U.S. national security and foreign policy interests.
Failure to Cooperate: Rwanda’s refusal to cease its involvement with M23 or cooperate with international efforts to address human rights violations violates AGOA’s criteria for eligibility.

By leveraging this evidence, the U.S. government can justify taking decisive action, including suspending Rwanda’s AGOA benefits and imposing targeted sanctions, to uphold the integrity of the legislation and promote accountability.

Detailed Explanation of the Conclusion and Recommendations

The conclusion and recommendations provide a roadmap for addressing Rwanda’s violations of the African Growth and Opportunity Act (AGOA) Section 104 Subsections (A)(2) and (A)(3). Based on the overwhelming evidence of Rwanda’s support for the M23 militia—a group implicated in gross human rights abuses and activities that undermine U.S. national security and foreign policy interests—it is clear that Rwanda fails to meet the statutory requirements for AGOA eligibility. Below is an expanded explanation of the conclusion and the recommended steps:

Conclusion: Rwanda’s Violation of AGOA Criteria

Failure to Meet AGOA Requirements

Section 104(A)(2): Rwanda’s actions undermine U.S. national security and foreign policy interests by destabilizing the Democratic Republic of the Congo (DRC) and the broader Great Lakes Region. The DRC’s strategic importance, particularly its mineral wealth, makes regional instability a direct threat to U.S. economic and geopolitical interests.
- Rwanda’s sponsorship of M23 has fueled violence, displacement, and humanitarian crises, including the seizure of Goma in January 2025, which resulted in nearly 3,000 civilian deaths and displaced over 500,000 people .
- This destabilization also undermines multilateral efforts, such as those led by the United Nations, to promote peace and stability in the region.
Section 104(A)(3): Rwanda facilitates gross violations of internationally recognized human rights through its support for M23. The militia has committed widespread atrocities, including:
- Extrajudicial killings, such as the summary execution of at least 12 civilians during its offensive in Goma.
- Systematic sexual violence targeting women and girls.
- Forced recruitment of child soldiers and deliberate attacks on civilian populations.
- These actions align with definitions of war crimes and crimes against humanity under international law.
Complicity Under International Law: Rwanda exercises “de facto control” over M23 operations, making it legally accountable for the militia’s crimes. Its failure to cooperate with international efforts to address these abuses further violates AGOA’s criteria.

Impact on AGOA Integrity

Allowing Rwanda to remain a beneficiary of AGOA despite its violations undermines the integrity of the legislation. AGOA is designed to reward countries that demonstrate progress in areas such as human rights, good governance, and economic development. By failing to hold Rwanda accountable, the U.S. risks sending a message that AGOA benefits can be retained regardless of non-compliance.

Recommendations: Steps to Address Rwanda’s Non-Compliance

To uphold the principles of AGOA and promote accountability, the Biden-Harris Administration should take the following decisive actions:

1. Reevaluate Rwanda’s AGOA Eligibility

Conduct a Formal Review: The U.S. Trade Representative (USTR) should initiate a formal review of Rwanda’s compliance with AGOA criteria, focusing on its violations of Sections 104(A)(2) and (A)(3).
- This review should involve consultations with relevant stakeholders, including human rights organizations, regional experts, and international bodies like the UN and the African Union (AU).
Suspend Benefits if Necessary: If Rwanda is found to be non-compliant, the U.S. should suspend its AGOA eligibility. This step would send a strong signal that trade preferences are contingent upon adherence to human rights and foreign policy standards.

2. Impose Targeted Sanctions

Sanction Rwandan Officials and Entities: The U.S. Department of the Treasury should impose targeted sanctions on Rwandan officials and entities involved in supporting M23. Measures could include:
- Asset freezes and travel bans for individuals directly responsible for facilitating M23’s operations.
- Restrictions on financial transactions and arms transfers linked to M23’s activities.
Expand Sanctions Regime: Work with international partners to expand the sanctions regime, ensuring that Rwanda faces coordinated pressure to cease its involvement with M23.

3. Strengthen Diplomatic Pressure

Engage Regional Partners: The U.S. should collaborate with African nations, the AU, and the International Conference on the Great Lakes Region (ICGLR) to demand Rwanda’s immediate cessation of support for M23.
- This includes leveraging diplomatic channels to isolate Rwanda within regional forums if it continues to defy calls for accountability.
Public Statements and Condemnation: Issue public statements condemning Rwanda’s actions and calling for transparency and cooperation. Public pressure can amplify diplomatic efforts and encourage Rwanda to change course.

4. Support Accountability Mechanisms

Advocate for Investigations: The U.S. should support investigations into M23’s atrocities through mechanisms such as the International Criminal Court (ICC) or hybrid tribunals. These investigations should focus on holding perpetrators accountable, including Rwandan officials complicit in the crimes.
Provide Funding for Justice Initiatives: Allocate resources to support transitional justice initiatives in the DRC, including programs aimed at documenting human rights abuses, supporting survivors, and promoting reconciliation.
Strengthen Multilateral Efforts: Work with the UN and other international actors to strengthen peacekeeping missions and humanitarian operations in eastern DRC, ensuring that affected populations receive adequate protection and assistance.

Expected Outcomes of Recommended Actions

Promoting Accountability

Taking decisive action against Rwanda will demonstrate the U.S.’s commitment to upholding human rights and accountability. It will also set a precedent that AGOA benefits are not immune to scrutiny and must be earned through genuine adherence to the legislation’s principles.

Restoring Regional Stability

Pressuring Rwanda to cease its support for M23 can help de-escalate violence in the DRC and the Great Lakes Region. This, in turn, will reduce displacement, alleviate humanitarian suffering, and create conditions conducive to sustainable development.

Reaffirming U.S. Leadership

By addressing Rwanda’s violations, the U.S. can reaffirm its leadership role in promoting peace, stability, and respect for human rights in Africa. This aligns with broader U.S. strategic objectives, including countering the influence of adversarial powers in the region.

Final Answer: Why Action is Necessary

Rwanda’s continued support for M23 constitutes a clear violation of AGOA Section 104 Subsections (A)(2) and (A)(3). By engaging in activities that undermine U.S. national security and foreign policy interests while facilitating gross human rights violations, Rwanda fails to meet the statutory requirements for AGOA eligibility. To uphold the integrity of AGOA and promote accountability, the Donald Trump Administration must take decisive action, including reevaluating Rwanda’s eligibility, imposing targeted sanctions, strengthening diplomatic pressure, and supporting accountability mechanisms.

Final Answer: {Rwanda has violated Section 104 Subsections (A)(2) and (A)(3) of AGOA through its support for M23, which engages in activities undermining U.S. interests and commits gross human rights violations. Immediate action is necessary to ensure compliance with AGOA criteria and promote accountability.}

Joram Jojo