A license arrived before the notice: OFAC’s DRC General License 2 and exporters to Rwanda and the Congo.
OFAC issued the humanitarian license on July 10. The Federal Register caught up on September 23. What it covers, what it does not, and why the gap matters.
Sanctions · 25 Sep 2026
OFAC issued Democratic Republic of the Congo (DRC) General License 2 on July 10, 2026, and published its text in the Federal Register on September 23. The 75-day interval matters for a company that relies on one source for sanctions updates. The license addresses specified agricultural, medical, and research transactions involving the DRC or Rwanda that would otherwise be prohibited by the DRC sanctions regulations. It does not grant general permission for all trade with either country.
What happened
On July 10, 2026, OFAC issued Democratic Republic of the Congo-related General License No. 2 under the Democratic Republic of the Congo Sanctions Regulations, 31 C.F.R. pt. 547 (the DRCSR). On September 23, 2026, OFAC published the text as 91 Fed. Reg. 60,303 (Sept. 23, 2026) (FR Doc. 2026-19423). The notice describes itself as publishing a license "previously made available on OFAC's website" and gives the issue date as July 10.
GL 2 authorizes transactions prohibited by the DRCSR that are ordinarily incident and necessary to three things:
- exporting or reexporting agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to the DRC or to the Republic of Rwanda, or to persons in third countries buying specifically for provision to either;
- preventing, diagnosing or treating any disease or medical condition in the DRC or Rwanda; and
- conducting clinical trials and other medical research in the DRC or Rwanda.
A note to the license extends the authorization to all transactions ordinarily incident to providing medical care and operating medical clinics or facilities.
Rwanda and the license's scope
The license expressly names Rwanda as well as the DRC. Its text and OFAC's July 10 announcement do not explain why Rwanda was included. OFAC designated the Rwanda Defence Force and four officers under the DRC sanctions program on March 2, 2026, but the designation alone does not establish OFAC's reason for writing GL 2 as it did. A company should apply the actual license text and screen the specific parties and ownership interests in its transaction rather than infer a general country exemption.
The DRC sanctions program blocks designated persons and certain entities they own; it is not a countrywide embargo. GL 2 is relevant only where a transaction is otherwise prohibited under that program and fits the stated humanitarian or research activity.
What the license does not do
Four limits come straight from the text.
It is narrow in subject matter. "Medicine" and "medical device" carry the definitions of "drug" and "device" in section 201 of the Federal Food, Drug, and Cosmetic Act, 21 U.S.C. § 321. "Agricultural commodities" means products within section 102 of the Agricultural Trade Act of 1978, 7 U.S.C. § 5602, and only when intended for food, animal feed, seeds for food crops, fertilizers, or reproductive materials for food animals. Items outside those definitions, such as vehicles or telecommunications equipment, are not export items under paragraph (a)(1). Whether a particular purchase is ordinarily incident to operating a clinic under Note 2 is a separate question, answered on its facts.
It authorizes nothing else under the [DRCSR](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-547). Paragraph (c) says so expressly. A joint venture or a commercial loan involving an RDF-owned entity does not become a GL 2 transaction merely because the business involves medical goods. Whether a longer-term distribution arrangement is "ordinarily incident and necessary" to the exports is a judgment the text does not resolve.
It does not displace other law. Note 1 provides that nothing in GL 2 relieves anyone of compliance with other federal laws or other agencies' requirements. Export licensing administered by another agency is the obvious example; GL 2 is not an export license.
It reaches only the [DRCSR](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-547). GL 2 is issued under part 547. If a counterparty is also blocked under a different program, GL 2 is silent on that program's prohibitions.
The text of GL 2 carries no stated expiration date. It does not repeat the express blocked-account payment condition in GL 1; that omission alone does not resolve other payment-handling duties under part 547. As checked on September 24, 2026, OFAC's DRC program page still lists the July 10 GL 2; parties should confirm its current status before relying on it.
What this means for you
Check your monitoring source. A compliance function that tracked only Federal Register publication would have seen this license 75 days after OFAC issued it. That timing could affect decisions about transactions otherwise within its scope. In this case OFAC's Recent Actions page carried the license on July 10; the Federal Register followed on September 23.
Map your Rwanda and DRC flows now. Identify relevant distributors, hospitals, ministries, clinics, and research partners. Check whether any party is blocked and whether ownership by blocked persons brings an entity within OFAC's 50 Percent Rule. Confirm the current rule and party status for the actual transaction.
Match the product to the definition before relying on the license. Classify each item against the FDCA and Agricultural Trade Act definitions the license adopts. A general license covers what its words cover. Where a product sits at the edge, escalate for a documented legal assessment before relying on GL 2.
Document reliance at the transaction level. When a transaction depends on GL 2, the file should show which paragraph applies, why the item fits the definition, and who checked. A general license needs no application, but it still needs evidence that it applied.
Watch the contract terms. GL 2 authorizes transactions within its stated scope. It does not automatically authorize every term in a continuing commercial relationship with a blocked entity. Keep payment terms, exclusivity and service arrangements inside what "ordinarily incident and necessary" can bear.
Building the program you can actually stand behind
A useful control links the license's exact terms to the item, parties, ownership, destination, and payment path in each transaction. Monitoring should include OFAC's Recent Actions page as well as later Federal Register publication, and the file should show which version of the license was checked.
Contact Zimmermann Law to discuss company-side U.S. sanctions questions about general-license scope and transaction records.
Sources: Federal Register publication, 91 Fed. Reg. 60,303–60,304 (Sept. 23, 2026); OFAC issuance notice (July 10, 2026); OFAC DRC program page (checked Sept. 24, 2026); OFAC March 2 designation notice.
This post is for general information and is not legal advice.
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