On Friday, September 18, 2026, President Trump signed into law H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (the “Act”). After receiving broad bipartisan support in Congress, the legislation significantly expands U.S. sanctions targeting Russia, including Russia’s financial and energy sectors, and establishes new tariff authorities targeting Russian-origin goods and imports from certain countries that purchase Russian energy or facilitate Russian oil sanctions evasion. The Act also extends the Iran Sanctions Act of 1996 through 2031.

The Act generally requires the President to implement the sanctions, tariffs, and other restrictions described in the legislation within 30 days of enactment (by October 18, 2026), subject to the Act’s exceptions and waiver provisions. In particular, the Act permits the President to waive these measures upon certifying to Congress that the waiver is in the national interest and explaining the basis for the waiver. As a result, although many of the Act’s provisions are mandatory, the scope and timing of their implementation will depend in part on actions taken by the Administration.

Key Takeaways

• Expanded Russia sanctions. The Act codifies and expands Russia-related sanctions, including blocking sanctions targeting Russian government officials and entities, Russian financial institutions, persons supporting Russia’s defense industrial base, Russian energy projects, vessels involved in Russian energy trade, and foreign persons that facilitate sanctions circumvention.

• New restrictions on Russia’s energy sector. The Act imposes new restrictions targeting Russia’s energy sector, including prohibitions on new U.S. investment in the Russian energy sector and exports of U.S.-origin energy products to Russia. The Act also provides for sanctions on foreign persons that knowingly provide goods, services, technology, or other support that facilitates the production of certain Russian energy products for use by sanctioned persons.

• New tariffs on Russian-origin goods. The Act directs the President to impose tariffs of up to 500 percent on goods imported from Russia, in addition to other applicable duties. The Act does not establish a minimum tariff rate.

• Secondary tariffs on certain countries. The Act also provides for tariffs of up to 100 percent on goods imported from certain countries that purchase Russian crude oil or natural gas or facilitate Russian oil sanctions evasion. The Administration will determine which countries are subject to these tariffs.

• Iran sanctions extended. Separately, the Act extends the Iran Sanctions Act of 1996 through 2031, preserving statutory authorities concerning existing sanctions that target Iran’s energy sector and Iran’s efforts to acquire or develop specified weapons capabilities.

Russia-Related Sanctions and Restrictions

The Act codifies many existing Russia-related sanctions and adds several new categories of persons that will be targeted by U.S. blocking sanctions. The Act requires blocking sanctions against certain Russian government officials and entities, persons supporting Russia’s defense industrial base, and persons involved in specified Russian energy projects or sanctions evasion activities.

The Act particularly targets Russia’s energy trade and efforts to circumvent sanctions. It provides for sanctions on certain vessels used to transport Russian crude oil, natural gas, LNG, petroleum products, and other goods for the purpose of circumventing U.S. sanctions, as well as on certain owners, operators, managers, insurers, and other persons that support those vessels.

The Act also codifies and expands financial restrictions on Russia. It requires blocking sanctions on major Russian financial institutions, including Sberbank, VTB Bank, and Gazprombank, as well as on certain other Russian government-owned financial institutions. Moreover, foreign financial institutions that engage in significant transactions with these institutions may also be sanctioned.

Finally, the Act places additional restrictions on U.S. financial and investment activity involving Russia, including the prohibition on any new investment in Russia by U.S. persons, certain transfers of funds involving the Russian government, the listing or trading of securities issued by specified Russian government-affiliated persons and entities on U.S. national securities exchanges, and purchases of Russian sovereign debt by a U.S. person.

Tariffs on Russian-Origin Goods

The Act establishes a new statutory basis for substantially higher tariffs on imports from Russia.  Specifically, the Act directs the President to increase the rate of duty on all goods imported from Russia to a rate of up to 500 percent ad valorem. The provision expressly covers energy products, including crude oil, natural gas, LNG, petroleum and petroleum products, petrochemical products, coal, and coal products. The new duties are in addition to other applicable duties, fees, taxes, or charges.

The 500 percent rate is a ceiling, not a mandatory tariff rate. Because the Act does not establish a minimum rate, the actual tariff rate will depend on the Administration’s implementation of the new authority.

Notably, the Act does not eliminate existing prohibitions on the importation of certain Russian energy products. In particular, Executive Order 14066 separately prohibits the importation of Russian crude oil, petroleum, petroleum fuels, oils and products of their distillation, LNG, coal, and coal products. Accordingly, the new tariff regime does not by itself make those products importable into the United States.

For companies importing Russian-origin goods that are not otherwise prohibited, the new tariff authority could substantially increase the landed cost of those goods.

Tariffs on Countries Purchasing Russian Energy or Facilitating Sanctions Evasion

The Act also establishes secondary tariffs targeting countries that continue to purchase Russian energy or facilitate Russian oil sanctions evasion.  In particular, the President is directed to impose duties of up to 100 percent ad valorem on goods imported from countries that:

1. knowingly made new purchases of Russian-origin crude oil or natural gas within 30 days after enactment of the Act and were among the five largest importers of Russian-origin crude oil or natural gas during the preceding 12-month period; or
2. were among the five countries most responsible for facilitating Russian oil sanctions evasion during the preceding 12-month period.

Although most reporting indicates that China, India, and Türkiye likely comprise the top purchasers of Russian oil, the Act does not permanently designate countries that are subject to these tariffs. Every 180 days, the United States Trade Representative must reassess the five largest importers of Russian crude oil and natural gas using data from the latest 12-month period. In addition, a limited exception applies if a country’s imports represented less than 15 percent of Russia’s total natural gas exports during that period and the country took significant steps to reduce them.

Accordingly, the secondary tariff provisions may impact companies far beyond those directly purchasing Russian oil or gas. U.S. importers sourcing goods from countries that become subject to these tariffs could face materially higher duties even where the imported merchandise itself has no Russian content or other connection to Russia.

Iran

Although the principal focus of the legislation is Russia, the Act also addresses Iran. In particular, the legislation extends the Iran Sanctions Act of 1996 through 2031, preserving statutory authorities concerning existing sanctions that target Iran’s energy sector and Iran’s efforts to acquire or develop specified weapons capabilities.

Practical Considerations

• Review Russia-related operations, transactions, and supply chains for potential sanctions and tariff exposure.
• Assess the impact of potential tariffs on Russian-origin imports and consider alternative sourcing strategies where appropriate.
• Monitor whether key supplier countries become subject to secondary tariffs under the Act.
• Conduct enhanced due diligence on counterparties, financial institutions, vessels, and logistics providers involved in Russia-related trade.
• Review contractual provisions addressing tariffs, sanctions, change-in-law risks, and regulatory compliance.
• Closely monitor Administration guidance and implementation measures, including any use of the Act’s waiver authorities.

Should you have questions, please contact our International Trade team, Paul Luther, Jason Wilcox, and Alexander Reinert.

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