Overview
On September 18, 2026, President Donald Trump signed into law the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (Act), a significant package of sanctions, trade restrictions and related measures directed principally at Russia and certain Russia-related persons, entities and activities. The Act also extends the Iran Sanctions Act of 1996 through 2031.
As discussed in our last blog post concerning the bill on August 20, the legislation passed the Senate in August. With the president’s signature, the legislation has now become law, and several of its provisions require implementation or other action by the president and relevant U.S. authorities within 30 days of enactment.
Overall, the Act significantly expands and codifies aspects of the U.S. sanctions framework targeting Russia. In addition to restrictions directed at Russian government officials, state-affiliated entities and financial institutions, the Act includes provisions targeting certain non-U.S. persons supporting Russia’s defense and energy sectors or facilitating sanctions evasion, as well as new tariff measures relating to Russian-origin goods and certain countries purchasing Russian-origin energy products or facilitating Russian oil sanctions evasion.
Although many provisions are framed in mandatory terms, we note their practical impact will depend significantly on determinations and implementing actions by the U.S. administration. The Act also provides the president with broad authority to waive sanctions, restrictions and duties where the president certifies to Congress that doing so is in the national interests of the United States. We are closely monitoring further updates and action taken pursuant to that authority.
Key features of the Act
The Act introduces a broad range of Russia-related sanctions, prohibitions and trade measures, many of which are required to be implemented, or reviewed for implementation, within 30 days of enactment. We note key provisions below:
The Act requires the president to review specified categories of persons and to impose blocking and, where applicable, visa sanctions on persons determined to meet the relevant statutory criteria. These include certain foreign persons supporting Russia’s defense industrial base or conducting significant transactions with the Russian Armed Forces; certain Russian oligarchs; certain senior persons associated with Russian defense, energy or transportation activities; and persons involved in specified sanctions-evasion and other activities.
The Act requires the president to impose sanctions on the Central Bank of Russia and specified Russian financial institutions, including Sberbank, VTB Bank and Gazprombank, as well as other Russian financial institutions owned in whole or in part by the Russian government and relevant subsidiaries and successor entities. It also provides for sanctions against foreign financial institutions that engage in significant transactions with specified Russian financial institutions, although the president is not required to impose those sanctions where the secretary of the treasury determines that doing so would not be consistent with U.S. economic or foreign policy interests. We note that the Act separately requires blocking sanctions against entities determined to be controlled by, majority-owned by or otherwise affiliated with the Russian government.
Effective 30 days after enactment, the Act prohibits new investment in Russia by U.S. persons and the export, reexport, sale or supply to persons located in Russia of categories of services identified by the secretary of the treasury, as well as related approval, financing, facilitation or guarantees by U.S. persons. The Act also restricts certain transfers of funds involving the Russian government or Russian government officials, requires the Securities and Exchange Commission to prohibit the trading on U.S. national securities exchanges of securities issued by specified Russian government-affiliated issuers, and prohibits U.S. persons from purchasing Russian sovereign debt.
Effective 30 days after enactment, the Act prohibits new investment by U.S. persons in Russia’s energy sector and the export, reexport or in-country transfer to or in Russia of U.S.-produced energy or energy products. The Act also requires blocking of and visa sanctions against foreign persons determined knowingly to provide specified goods, services, technology or other support facilitating the maintenance or expansion of certain Russian energy production for persons subject to sanctions under specified provisions of the Act. Separately, we also note that the Act establishes sanctions targeting certain foreign vessels used to circumvent sanctions, as well as specified vessel owners, operators, managers, insurers, crew leadership and foreign port operators associated with covered vessels.
On the tariff and duties front, within 30 days of enactment, the Act requires the president to increase the rate of duty on all goods imported into the United States from Russia to a rate of up to 500% ad valorem. These duties are to apply in addition to other applicable duties, fees, taxes and charges. The applicable rate within that statutory ceiling will therefore depend on implementation by the president. Within 30 days of enactment, the Act also requires the president to impose duties of up to 100% ad valorem on goods imported from countries meeting specified statutory criteria. Those criteria cover countries that both make new purchases of Russia-origin crude oil or natural gas following the 30-day period after enactment and were among the five largest importers by volume of such products during the preceding 12-month period, as well as countries among the five largest facilitators of Russian oil sanctions evasion during that period. The Act also provides for subsequent determinations by the Office of the U.S. Trade Representative and adjustments to applicable tariff rates and contains a limited exception relating to certain countries’ imports of Russian-origin natural gas.
In terms of exclusions and exceptions, we note that the Act contains a number of exceptions relevant to the scope of these restrictions, including for specified humanitarian, agricultural, food and medical activities; certain intelligence and law-enforcement activities; certain official U.S. government and United Nations business; certain civilian nuclear cooperation; certain imports of low-enriched uranium and medical isotopes covered by existing statutory waivers; and non-Russian oil that transits Russian territory. The Act also preserves the ability of U.S. persons to operate under Treasury general licenses issued before enactment and expressly preserves Treasury’s authority to extend existing general licenses or issue new ones.
Most notably, the Act provides a 270-day exception from sanctions under the Act for specified activities relating to the wind-down or divestiture of certain operations in Russia. This includes certain ongoing operational support by U.S. persons engaged in good-faith efforts to wind down or divest operations of entities in Russia that they own or control.
Further, the Act gives the president authority to waive sanctions, restrictions and duties, subject to a certification to Congress that the waiver is in the interests of the United States and a report explaining the basis for that certification. Separately, the Act establishes conditions for the termination of sanctions, restrictions and duties, together with a congressional review mechanism. For measures relating to Russia or Russian persons, termination generally requires the president to certify that Russia has signed a peace agreement accepted by the government of Ukraine and has ceased military hostilities against, and specified activities directed at subverting, the Ukrainian government. Finally, the Act extends the Iran Sanctions Act of 1996 through 2031. The remainder of Division A of the legislation is scheduled to terminate five years after enactment.
Key takeaways
The enactment of the Act marks a significant development in the U.S. sanctions framework relating to Russia. Businesses should now focus on the implementation of the Act and the determinations, regulations and other actions that may follow, particularly given the 30-day timetable applicable to many of its provisions.
The Act may be particularly relevant for businesses with direct or indirect exposure to Russia; Russian state-affiliated entities or financial institutions; Russia-related energy projects or commodities, shipping and maritime activities; or cross-border financial transactions involving Russian counterparties. We note that non-U.S. companies and financial institutions should also assess the Act carefully, as several provisions contemplate sanctions against foreign persons based on specified dealings with Russian counterparties, support for targeted Russian sectors or involvement in sanctions-evasion activity.
From our view, the tariff provisions may have particularly significant implications beyond businesses dealing directly with Russia. Companies with supply chains or operations in countries that purchase substantial volumes of Russian crude oil or natural gas, or that may be determined to facilitate Russian oil sanctions evasion, should monitor the administration’s initial country determinations and the tariff rates imposed under the Act.
Ultimately, the precise commercial impact of the Act will depend significantly on implementation. Companies currently relying on Treasury general licenses or considering a wind-down or divestiture of Russian operations should also assess carefully how the Act and its exceptions apply to those arrangements. We will continue to follow these developments and provide further updates as appropriate.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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