President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act into law on September 18, 2026, following bipartisan passage in both chambers. Among its most commercially significant provisions is a sweeping new tariff framework targeting Russia and countries that continue to buy Russian energy.
The Tariffs
The Act creates two mandatory tariff tracks, both with a hard deadline of October 18, 2026:
- Russian goods: Duties of up to 500% ad valorem on all goods imported from Russia.
- Secondary tariffs on third countries: Duties of up to 100% ad valorem on all goods imported from countries that are either (1) among the top 5 importers of Russian crude oil or natural gas by volume, or (2) among the top 5 countries facilitating Russian oil sanctions evasion.
Critically, all duties stack on top of existing tariffs — meaning countries already subject to Section 301 or Section 232 duties face potentially severe cumulative exposure.
Who Is Targeted?
The most likely third-country targets are China, India, and Turkey, which appear across multiple qualifying tracks as major buyers of Russian energy and facilitators of sanctions evasion. Slovakia, Hungary, and the UAE are also at elevated risk. The EU is not treated as a single country — individual member states are assessed separately.
The Escape Valves
The Act provides several mechanisms through which countries or businesses may seek relief — but none are straightforward.
Natural gas exception. A country identified as a top importer of Russian natural gas may avoid secondary tariffs if its imports represented less than 15% of Russia’s total annual gas exports during the relevant 12-month period and it has taken “significant steps” to reduce those imports. This exception does not apply to crude oil importers or sanctions evasion facilitators, and the undefined phrase “significant steps” gives the Administration broad discretion over who qualifies.
Presidential waiver. The President may waive any duty under the Act on national interest grounds. However, this requires a formal, unclassified written certification to Congress explaining the basis for the waiver — making it a politically visible act rather than a quiet administrative tool. The waiver mechanism is best understood as a safety valve for exceptional diplomatic circumstances, not a general opt-out from mandatory tariff obligations.
Termination. Tariffs can be terminated entirely, but only upon certification that Russia has signed a peace agreement with Ukraine and ceased all relevant military hostilities. Any termination is subject to a 30 to 60 day congressional review window during which Congress may pass a joint resolution to block it.
Winddown period. Entities engaged in genuine winddown or divestiture of Russian operations have a 270-day grace period from enactment — expiring June 15, 2027 — during which the Act’s measures do not apply to their winddown activities.
The overall picture is one of mandatory tariffs with narrow, carefully conditioned relief. The Administration retains some flexibility through rate-setting (duties can be set anywhere between greater than zero and the statutory ceiling) and national interest waivers, and may use these tools as leverage in bilateral negotiations with affected countries. But there is no general executive discretion simply to decline to impose the tariffs — the “shall” language and “notwithstanding any other provision of law” clause make non-compliance without formal justification legally untenable.
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