On Tuesday, October 17th, the Rwandan Minister of State in Charge of Mining, Hon. Evode Imena testified before the U.S. House Financial Services Committee, addressing the impact that Dodd-Frank has had on Rwanda.
Section 1502 of the Dodd-Frank, which covers the Democratic Republic of the Congo (DRC) and 10 other countries that share internationally recognized borders with DRC, including Rwanda, mandates that the US Securities Exchange Commission (SEC) issue regulations requiring publicly traded companies filing annual and other reports with the SEC to disclose annually the origins of conflict minerals necessary to its operations if the minerals originate from the Democratic Republic of the Congo (DRC) or an adjoining country (Rwanda included).
This hearing focused on what is commonly addressed as the 3T minerals, Tin, Tungsten, and Tantalum, which, all together, account for 90 % of Rwanda’s mineral production. Hon. Imena’s role in this hearing was to highlight how section 1502 has negatively impacted the case of Rwanda.
Hon. Imena argued that while the ten countries covered by section 1502 have some similarities, they also significantly differ from economic development to their capacities in border control. Moreover, The Minister as well as other members of the panel agreed that a system that subjects all ten countries to the same rule, without consideration of their starkly varying differences is inefficient and puts the concerned States in unnecessary “de facto embargo”.
Hon. Imena informed the House Financial Committee that prior to the enactment of Dodd-Frank in 2010, Rwanda had already put into place several systems to ensure traceability, taxation, transparency, and worker’s rights. To mention a few initiatives and efforts, this was done through the Certified Trading Chains (CTC), in collaboration with the German Mineral Resources Agency (BGR), and through programs such as the ITRI Supply Chain Initiative (iTSCI).
Despite being the country with the best mineral traceability system in the Kibaran Belt, with 100% of 3T minerals traceable from the mine site to the export point, Hon. Imena said that Rwanda suffered the subjection to being lumped together with nine other countries, without consideration of the efforts and the successes of its mining industry.
He stated that the heaviest burden that the Rwandan mining sector has suffered is the cost resulting from the conflict mineral due diligence framework. Currently, more money is spent in complying with the conflict mineral requirement than money paid for government taxes. The situation has impacted the livelihood of miners and their families.

“The concern”, Minister Imena said “is that Rwanda’s minerals have already been labeled conflict minerals, even before extraction. Rwandan minerals should be considered conflict-free, because Rwanda is conflict-free. There are no illegal mines.” In order to redress this situation, Hon. Imena urged the chairman and members of congress who were present to work with the U.S government and U.S. companies to come up with a system that supports Rwanda’s commitment to traceability and transparency in the mining sector, without harming the country’s booming economy. He also gave an open invitation to all who were present to visit Rwanda and see how the sector is run from the bottom up.