Key Takeaways
- • President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 on September 18, following House passage (262-159) on September 16 and Senate passage (86-11) on August 7, establishing novel tariff authority over third-country imports alongside reinforced Russia sanctions.
- • The Act mandates up to 100% tariffs on all goods from countries among the top five importers of Russian crude oil or natural gas, or top five facilitators of Russian oil sanctions evasion, with tariffs stacking on top of existing duties under Sections 122, 201, 301, 232, and 338 of prior trade legislation.
- • Russian-origin goods face mandatory tariffs up to 500%, with the President required to impose secondary tariffs within 30 days of enactment and reassess country designations every 180 days, creating material supply chain exposure for importers connected to China, India, and potentially Azerbaijan, Hungary, Kazakhstan, Kyrgyzstan, Singapore, Slovakia, Turkey, and the UAE.
- • The Act's sanctions provisions largely codify existing authorities under Executive Order 14024 and CAATSA, reinforcing the current framework rather than expanding it fundamentally, but by statute the sanctions become harder to lift without congressional action, creating political pressure on the administration.
- • The President retains broad discretion through national interest waivers, OFAC general licenses, and the ability to decline mandatory determinations, mirroring CAATSA's structure; the Act includes a five-year sunset and extends Iran Sanctions Act through 2031.
Summary
The Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 represents the most significant expansion of U.S. Russia-related tariff authority in decades, while simultaneously codifying existing sanctions frameworks into statute. Signed into law on September 18, 2026, the legislation passed the Senate by 86-11 on August 7 and the House by 262-159 on September 16, following sustained debate over its tariff provisions—the primary source of Democratic opposition and the last obstacle to securing the Trump administration's support.
The Act's most consequential feature is its novel tariff authority. Section 112 mandates that the President impose tariffs up to 500% on all Russian-origin goods, with explicit coverage of petroleum, natural gas, and coal products. More broadly, Section 113 authorizes secondary tariffs up to 100% ad valorem on all goods imported from countries identified as either among the top five importers of Russian crude oil or natural gas during the preceding 12 months, or among the top five "countries facilitating Russian oil sanctions evasion"—defined to include jurisdictions where foreign persons provide significant financial or logistical support for sanctioned Russian energy transactions or shadow fleet vessel operations. Critically, these tariffs stack on top of all existing duties, including those under Sections 122, 201, and 301 of the Trade Act of 1974, Section 232 of the Trade Expansion Act of 1962, Section 338 of the Trade Act of 1930, and antidumping and countervailing duties. The President must impose these tariffs within 30 days of enactment and reassess country designations every 180 days in consultation with the State Department and Department of Energy.
Trade data and legislative history suggest China and India are most likely to face secondary tariffs as major Russian energy importers, with proponents also citing Azerbaijan, Hungary, Kazakhstan, Kyrgyzstan, Singapore, Slovakia, Turkey, and the United Arab Emirates as potential targets. However, the Act grants the President significant discretion in identifying these countries, specifying no particular data sources or quantification methodology for "facilitating" sanctions evasion—creating material ambiguity about implementation scope. A natural gas exemption permits the President to forgo tariffs on countries whose Russian gas imports fall below 15% of Russia's total exports and that take "significant steps" to reduce purchases; no comparable exemption exists for crude oil buyers. The President may adjust rates based on changed behavior and may terminate duties if Russia and Ukraine reach a peace agreement or the subject country ceases the triggering conduct, but termination is discretionary rather than mandatory. A broad national interest waiver applies to both tariffs and sanctions.
The Act's sanctions provisions, while expansive in statutory language, largely reinforce existing authorities under Executive Order 14024 and the Countering American Adversaries Through Sanctions Act of 2017 (CAATSA). Mandatory secondary sanctions target third-country persons and vessels engaged in defense-industrial transactions with Russia, activities contrary to Ukrainian security, sanctions evasion facilitation, energy product transport, and certain financial institution transactions—conduct largely sanctionable under existing discretionary authorities. Primary sanctions on Russian persons similarly track established frameworks. Critically, despite mandatory statutory language requiring the President to impose sanctions, actual implementation remains conditioned on affirmative Presidential determinations, meaning the administration can decline to make those determinations and avoid triggering any sanctions obligation, a precedent established under both the Biden and Trump administrations under CAATSA. The Act preserves broad national interest waiver authority and maintains OFAC's existing power to issue general licenses without congressional review. By codifying pre-existing sanctions into statute and requiring congressional acquiescence for formal termination, the Act creates political friction against future sanction relief while reinforcing rather than fundamentally reshaping the current sanctions landscape.
The legislation includes a five-year sunset for tariff and sanctions provisions, extends the Iran Sanctions Act through 2031, and establishes congressional reporting requirements for tariff rate adjustments. Implementation will depend critically on guidance from the Office of the U.S. Trade Representative and OFAC in the coming weeks—particularly clarification on country identification methodologies, tariff rate selection, and sanctions determination criteria.
The Act's most consequential feature is its novel tariff authority. Section 112 mandates that the President impose tariffs up to 500% on all Russian-origin goods, with explicit coverage of petroleum, natural gas, and coal products. More broadly, Section 113 authorizes secondary tariffs up to 100% ad valorem on all goods imported from countries identified as either among the top five importers of Russian crude oil or natural gas during the preceding 12 months, or among the top five "countries facilitating Russian oil sanctions evasion"—defined to include jurisdictions where foreign persons provide significant financial or logistical support for sanctioned Russian energy transactions or shadow fleet vessel operations. Critically, these tariffs stack on top of all existing duties, including those under Sections 122, 201, and 301 of the Trade Act of 1974, Section 232 of the Trade Expansion Act of 1962, Section 338 of the Trade Act of 1930, and antidumping and countervailing duties. The President must impose these tariffs within 30 days of enactment and reassess country designations every 180 days in consultation with the State Department and Department of Energy.
Trade data and legislative history suggest China and India are most likely to face secondary tariffs as major Russian energy importers, with proponents also citing Azerbaijan, Hungary, Kazakhstan, Kyrgyzstan, Singapore, Slovakia, Turkey, and the United Arab Emirates as potential targets. However, the Act grants the President significant discretion in identifying these countries, specifying no particular data sources or quantification methodology for "facilitating" sanctions evasion—creating material ambiguity about implementation scope. A natural gas exemption permits the President to forgo tariffs on countries whose Russian gas imports fall below 15% of Russia's total exports and that take "significant steps" to reduce purchases; no comparable exemption exists for crude oil buyers. The President may adjust rates based on changed behavior and may terminate duties if Russia and Ukraine reach a peace agreement or the subject country ceases the triggering conduct, but termination is discretionary rather than mandatory. A broad national interest waiver applies to both tariffs and sanctions.
The Act's sanctions provisions, while expansive in statutory language, largely reinforce existing authorities under Executive Order 14024 and the Countering American Adversaries Through Sanctions Act of 2017 (CAATSA). Mandatory secondary sanctions target third-country persons and vessels engaged in defense-industrial transactions with Russia, activities contrary to Ukrainian security, sanctions evasion facilitation, energy product transport, and certain financial institution transactions—conduct largely sanctionable under existing discretionary authorities. Primary sanctions on Russian persons similarly track established frameworks. Critically, despite mandatory statutory language requiring the President to impose sanctions, actual implementation remains conditioned on affirmative Presidential determinations, meaning the administration can decline to make those determinations and avoid triggering any sanctions obligation, a precedent established under both the Biden and Trump administrations under CAATSA. The Act preserves broad national interest waiver authority and maintains OFAC's existing power to issue general licenses without congressional review. By codifying pre-existing sanctions into statute and requiring congressional acquiescence for formal termination, the Act creates political friction against future sanction relief while reinforcing rather than fundamentally reshaping the current sanctions landscape.
The legislation includes a five-year sunset for tariff and sanctions provisions, extends the Iran Sanctions Act through 2031, and establishes congressional reporting requirements for tariff rate adjustments. Implementation will depend critically on guidance from the Office of the U.S. Trade Representative and OFAC in the coming weeks—particularly clarification on country identification methodologies, tariff rate selection, and sanctions determination criteria.
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