1
Rwanda withdraws its troops from eastern Congo
Unlikely
Resolves by Q2 2027
Discussed by: The US Treasury and Congo's foreign ministry, which both tie the sanctions to a withdrawal
The designations are meant to make continued deployment costly for Kigali by cutting its military off from dollar financing. Compliance would require Rwanda to pull troops back across the border and for M23 to leave Goma and Bukavu. Rwanda says it will implement the accords once Congo neutralizes the FDLR, so a withdrawal depends on a joint security mechanism neither side has set up.
2
Washington extends sanctions to Rwandan mineral exporters
Possible
Resolves by Q1 2027
Discussed by: Human Rights Watch, which argues designations should be paired with measures against the mineral trade
Treasury has escalated in steps: army, then refinery and mining companies, then the defence ministry. The next rung is the exporters and trading houses that Treasury says absorb minerals from M23-held territory. That step would hit a larger share of Rwanda's formal economy, which is why it carries more diplomatic risk than targeting the security services.
3
Fighting continues and the Washington Accords lapse
Likely
Resolves by Q2 2027
Discussed by: The EU's Great Lakes envoy and Ugandan President Yoweri Museveni, who have both raised alarm over stalled talks
The accords set out security and trade commitments but no enforcement body. If M23 keeps Goma and Bukavu and no joint monitoring mechanism convenes, the deal becomes a document both sides cite against each other. That is close to the current state: Congo says Rwanda violates it, Rwanda says Congo does.
4
Sanctions lifted after a verified withdrawal
Unlikely
Resolves by End of 2027
Discussed by: Rwanda's government, which says it remains ready to implement the accords in full
OFAC can delist targets that change behavior, and Kigali has said it will honor the accords if Congo does. Lifting the designations would require the US to certify a withdrawal and an end to financing for M23. No such certification process has been announced, and Treasury has escalated rather than eased in each round so far.
5
Rwanda and Congo sign a new agreement in November
Uncertain
Resolves by Nov 30, 2026
Discussed by: People briefed on the talks, as reported by AFP
Reports say a deal could be signed as early as November. No agreement has been formally announced, and the terms are not public.
6
The US trade suspension takes effect and cuts Rwandan exports
Likely
Resolves by Jan 31, 2027
Discussed by: BBC News, which reported the move on November 2
Trump's decision to remove Rwanda from a US trade deal would end preferential access for Rwandan goods if it is carried out. The report did not say when the change takes effect or which products it covers. Rwanda's mineral and agricultural exports are the likely targets, and the timing puts trade pressure alongside the financial sanctions on the defence ministry and Zigama.
