- Why Washington targeted a Kigali gold refinery and left the rest of the supply chain untouched?
On Thursday, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Gasabo Gold Refinery Ltd, its chairman Jean Malic Kalima, general manager Bosco Kayobotsi, and three companies controlled by Kalima, Bugambira Mines Ltd, Wolfram Mining and Processing Ltd, and Rwinkwavu Mining Corporation Ltd for their alleged role in laundering conflict gold from the Democratic Republic of Congo. The announcement was swift, the language unsparing.:”The United States will not allow rogue groups to profit from the illicit mineral trade and destabilize the region,” said Treasury Secretary Scott Bessent. (U.S. Department of the Treasury)
Peace & prosperity or just political interests?
There is a key question Washington refuses to answer and does not explain: why Gasabo Gold, and not the buyers waiting at the other end of the pipeline?
Artisanally mined gold from the DRC, South Sudan, and CAR is mainly smuggled or exported to one of six neighboring countries: Uganda, Rwanda, Cameroon, Kenya, Chad, or Burundi before being exported to Dubai. An estimated 95% of gold from East and Central Africa reaches the UAE as its final destination.
Neighbors will always be Neighbors:
The architecture of this trade has been documented exhaustively. Uganda, Rwanda, and Burundi are the main TRANSIT routes of gold smuggled from eastern DRC to Dubai. In one documented case, Burundian government statistics showed exports of 601.7 kg of gold to Dubai in 2018, while UAE import data for the same period showed traders in Dubai received more than 2,130 kg from Burundi. Uganda has run this playbook even longer. Uganda’s gold exports reached $1.25 billion in 2019, more than double the previous year, and up from less than $10 million a decade earlier, with most of it destined for Dubai. Uganda now has seven registered gold refineries, far exceeding the country’s actual production needs, raising serious questions about the provenance of gold being refined there.
Why Rwanda alone?Â
The Geopolitical scaffolding: the answer is not forensic. It is political. The OFAC action is supposed to be enforcing the Washington Accords for Peace and Prosperity, a peace framework brokered by President Donald Trump and signed by the leaders of the DRC and Rwanda on December 4, 2025.
The accords mandate transparent, traceable, and fully licit mineral supply chains through a Regional Economic Integration Framework. But Uganda and Burundi, by contrast, continue to trade gold smoothly. Their gold laundering activities are structurally established. That distinction has to be investigated and an enormous work in determining who gets sanctioned is needed.
The Dubai Problem: A terminus left untouched:
The most glaring omission in the sanctions architecture is the final destination. Due diligence efforts by UAE refiners are primarily focused on stopping direct supplies of mined gold from DRC and known transit countries, but little has been done to set up traceable supply chains that extend back to mine sites. Weak chain of custody procedures in Uganda, Kenya, Burundi, and DRC allow exporters to deliberately disguise or fail to disclose the origin of their exported gold.
OFAC is not unaware of the Dubai nexus. In a 2022 action, Treasury designated the African Gold Refinery Limited in Entebbe, Uganda, and its beneficial owner Alain Goetz, a Belgian-Turkish national residing in Dubai along with associated entities including AGOR DMCC, registered in Dubai’s Jumeirah Lake Towers free trade zone. That action showed OFAC can follow the supply chain into the Gulf when it chooses to.
The fact that it has not done so more systematically in the DRC- neighbors-UAE corridor reflects a structural reality: Dubai-based gold trading entities have benefited from the DMCC’s voluntary due diligence guidelines rather than mandatory regulatory standards, a gap that UN sanctions monitors have for years urged Emirati authorities to act.
The “node, not network” :
As one analysis noted following the March 2025 EU sanctions, targeting one node in a network does not shut the network down, it redirects it. The EU sanctioned Gasabo Gold and one official in a system involving multiple companies, transit routes, and international buyers including traders operating out of Luxembourg, Dubai, and beyond.
That critique applies with equal force to Thursday’s OFAC action. Designating Gasabo Gold, Bugambira Mines, Wolfram Mining and Processing, and Rwinkwavu Mining won’t solve the issue.
It does not extinguish the underlying demand for laundered Great Lakes gold in Dubai’s souk or in the refineries supplying European and Asian jewelry markets.
Even sanctioning the refinery in Kigali would not resolve the structural incentive for gold to move from eastern DRC toward the Gulf through whatever corridor remains open.
What comprehensive enforcement would look like?
Serious supply chain interdiction as opposed to diplomatically-convenient designation would require at minimum: parallel designation of UAE-based traders and refineries with documented receipt of conflict gold from Great Lakes transit corridors.
OFAC has the authority under E.O. 13413; it has simply declined to exercise it comprehensively.
Mandatory enforcement of Dodd-Frank Section 1502 conflict minerals due diligence requirements on U.S. downstream importers of gold that transits the DRC-Rwanda-Uganda-Burundi-UAE corridor requirements that have been applied inconsistently.
Coordination with the DMCC and UAE financial regulators to impose mandatory, not voluntary, chain-of-custody requirements on gold imports from the six primary East African transit jurisdictions is well documented.
Designation of Burundian and Ugandan refinery networks engaging in the same structural arbitrage as Gasabo Gold shouldn’t be ignored.
A surgical strike on a one node creates more problems. Rwanda has been made to bear the full weight of a sanctions campaign that, for reasons of geopolitical convenience, stops at the UAE’s border and declines to reach back into Uganda or Burundi’s parallel infrastructure.
The gold moves. The demand is in Dubai. The laundering happens across six transit jurisdictions simultaneously. Until enforcement follows the metal all the way to its terminus and holds the buyers as accountable as the refiners, these designations will remain what they have always been: politically timed pressure instruments dressed in the language of supply chain integrity.
Redaction
