The timeline is illustrative and might raise a few eyebrows.
May-June 2012: The Leaks
Calling themselves the M23, members of the Congolese army (FARDC) mutinied in April 2012 because of claims of poor treatment and lack of food and pay. They demanded that the Congolese government honor the Goma Peace Accord of March 23, 2009, which was signed following the arrest of their former leader, General Laurent Nkunda. Part of the peace accord involved integration of Nkunda's National Congress for the Defense of the People (CNDP) troops into FARDC.
In May and June, international media including the BBC and the New York Times began reporting a "leaked" memo from the U.N. Stabilization Mission in the Congo (MONUSCO). The memo claimed that Rwanda was secretly supporting the M23 rebel movement. From that point on leaks from the United Nations Group of Experts (GoE) Report flowed faster that the River Nile amid vehement denials from Rwanda. Rwandan foreign minister Louise Mushikiwabo rejected the accusations and claimed the expert panel had been "hijacked" by the political biases of its coordinator, Stephen Hege.
Rwanda hired a law firm to compile a rebuttal and you can read it here.
The Disputed Report
Some consider the GoE findings the Gospel truth, while others have criticized the report as sloppy and riddled with demonstrated bias by its chief author, Hege.
The most egregious charge against the document is that its principal coordinator authored a paper in which he demonstrated clear bias in favor of the perpetrators of the Rwandan genocide (FDLR).
Eventually a global narrative evolved that pinned the blame for the failure of the Congo state on neighboring nations. Cuts in foreign aid to Rwanda by the UK and the United States followed with no challenge from the international press, which accepted the GoE findings with no independent analysis.
Even before the emergence of M23, the UK government was having to justify its foreign aid policy in the wake of severe austerity cuts. The British press continues to rail against aid to developing countries when so many Britons are seeing their public services and welfare benefits slashed.
In the US, the GoE findings became a potent political weapon against Susan Rice during speculation that Obama would name her as his next Secretary of State.
In Dr. Clark's op-ed, Rice, Bill Clinton, Andrew Mitchell, David Cameron and Tony Blair became "lightning rods" for criticism in the wake of the GoE report.
When asked directly in email and phone conversations during the preparation of this article about proof beyond the GoE Report that M23 has engaged in atrocities, a spokesman for Terrorism and Financial Intelligence in The Department of the Treasury cited "an abundance of evidence" against M23 and the FDLR that "has been vetted extensively." Obama's Executive Order gives Treasury the authority to impose sanctions while following consults with interagency partners such as the State Department.
In this case, "M23 combatants Baudoin Ngaruye and Innocent Kaina are being designated for their involvement in the recruitment and use of child soldiers in the conflict in the DRC and for being leaders of a group that is impeding the disarmament, repatriation, or resettlement of combatants," the spokeman said in an email.
A State Department Press Officer offered the partial statement that "The Democratic Forces for the Liberation of Rwanda (FDLR) and M23 are being sanctioned for serious violations of international law, including the targeting of children in situations of armed conflict, killing and maiming of children and civilians, sexual violence, abductions, and forced recruitment."
Neither agency offered specifics beyond the GoE Report, but they were helpful in explaining the process. Nor would either agency comment of the possibility of illegal lobbying by the NGO.