On July 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 2 (“GL 2”) under the Democratic Republic of the Congo Sanctions Regulations (the “DRCSR”) as the eastern Democratic Republic of the Congo (“DRC”) continues to face significant humanitarian challenges, including an Ebola outbreak in the region. GL 2 goes beyond the existing general license found in section 547.513 of the DRCSR, which is limited to quantities of agricultural commodities, medicine, and medical devices that are consistent with personal, non-commercial use.
GL 2 authorizes US persons to engage in transactions and activities otherwise prohibited by the DRCSR that are ordinarily incident and necessary to: (i) the export or reexport of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates for medical devices to the DRC or the Republic of Rwanda (“Rwanda”)—including to persons in third countries purchasing such items specifically for resale or provision to those countries; (ii) the prevention, diagnosis, or treatment of any disease or medical condition in those countries, including transactions ordinarily incident to the provision of medical care and the operation of medical clinics or facilities; and (iii) the conduct of clinical trials and other medical research activities in those countries. GL 2 has no expiration date.
GL 2 does not authorize the export or reexport of items subject to the Export Administration Regulations that are controlled to the DRC or Rwanda. Such authorization, if required, must come separately from the US Department of Commerce’s Bureau of Industry and Security.
The practical impact is that GL 2 may authorize certain transactions involving Specially Designated Nationals (“SDNs”) designated under the DRCSR. There have been a number of SDN designations under the DRCSR this year, which were intended to ensure that the DRC and Rwanda uphold their obligations under the Washington Accords for Peace and Prosperity entered into in December 2025. This includes the Rwanda Defense Force, which is the military of Rwanda, which was designated as an SDN on March 2, 2026 for supporting, training, and fighting with the March 23 Movement (M23), a US- and UN-sanctioned armed group, in the eastern DRC. (A wind-down general license, General License 1, was issued at the time and has since expired.) This also includes OFAC’s April 30, 2026 designation of former DRC President Joseph Kabange Kabila and multiple June 2026 designations targeting individuals and entities tied to M23 and the Democratic Forces for the Liberation of Rwanda (FDLR) and a Rwanda-based conflict minerals network. To the extent these or other parties designated under the DRCSR (and not under any other sanctions programs) are involved in transactions within the scope of GL 2, GL 2 may authorize those transactions. In light of the risks, we recommend a compliance assessment of any such transaction.
The authors acknowledge the assistance of Eliezer Elliott in the preparation of this post.
