6 minute read | September.24.2026
On September 18, 2026, President Donald Trump signed into law the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (the Act), establishing important new sanctions authorities, requiring the imposition of sanctions on various Russia-related parties.
It also introduces substantial new tariffs on Russian goods and restrictions on fund transfers to or from the Russian government. In addition, the Act imposes restrictions on certain securities trading and financial messaging, authorizes broader secondary sanctions, includes anti-facilitation provisions and codifies several existing executive order restrictions.
Most provisions take effect on October 18, 2026. A prohibition on the purchase of Russian sovereign-debt by U.S. persons, which codifies an existing executive order, took effect immediately on September 18.
Businesses with Russia exposure – including financial institutions, energy companies, commodity traders, manufacturers and companies with supply chains tied to Russian energy – should assess the implications of the new sanctions and tariff measures.
The statute directs the president to review and impose sanctions, including blocking sanctions, on persons he determines to be affiliated with or supporting the Russian government. These sanctions cover a broad range of targets, from senior Russian officials and military commanders to foreign persons supplying Russia’s defense industrial base, persons conducting significant transactions with the Russian armed forces, persons whose activities undermine Ukraine, leaders and principal shareholders of entities operating in the Russian defense industrial base, energy or transportation sectors, Russian oligarchs who do not oppose Russia’s war against Ukraine or who benefit from association with the Russian government, and persons engaged in certain malign activities on behalf of or for the benefit of the Russian government. Vessels used to transport Russian-origin energy products or circumvent sanctions, as well as their owners, operators, insurers and associated port operators used to circumvent sanctions are also covered.
In addition, the Act requires the president to impose sanctions on the Central Bank of Russia, Sberbank, VTB Bank and Gazprombank (which are already sanctioned), as well as Russian financial institutions owned in whole or in part by the Russian government and foreign financial institutions that engage in significant transactions with any of these financial institutions. Sanctions are also to be imposed on leaders, officers, directors and controlling shareholders of these institutions.
The Act imposes tariffs of up to 500% on goods imported from Russia and up to 100% on goods from certain third countries that purchase Russian energy or facilitate sanctions evasion. The duties are in addition to other applicable duties, fees, taxes, exactions and charges. The third-country tariffs target countries determined by the president to be among the five largest importers of Russian crude oil or natural gas during the preceding 12 months and that knowingly make new purchases after the Act’s effective date, or that are among the top five facilitators of Russian oil sanctions evasion.
A limited exception applies where a country’s Russian natural gas imports are below 15% of Russia’s annual natural-gas exports, and the country has taken significant steps to reduce those imports.
The statute instructs the president to impose sanctions on any foreign person that the president determines knowingly sells, supplies, transfers, markets or otherwise provides goods, services, technology or other support that facilitates the maintenance or expansion of the production of oil, uranium, natural gas, liquefied natural gas, petroleum, petroleum products, petrochemical products, coal or coal products for use by any person subject to sanctions under the Act’s designation authorities.
The Act authorizes sanctions against any entity that:
The Act also authorizes sanctions against leaders, senior executive officers, directors and principal shareholders with a controlling or majority interest in any such entity.
The Act bars depository institutions and SEC-registered broker-dealers from processing fund transfers to or from the Russian government.
The Act prohibits the listing or trading on U.S. national securities exchanges of securities issued by Russian government officials or affiliates, or by entities where the Russian government holds a controlling or majority ownership interest.
Prior to the Act, executive order restrictions already prohibited new U.S. investment in Russia’s energy sector but did not bar the export of U.S.-produced energy or energy products to Russia. The Act closes that gap by prohibiting the export, re-export, or in-country transfer of any U.S.-produced energy or energy product to or within Russia.
U.S. persons are prohibited from approving, financing, facilitating or guaranteeing any transaction by a foreign person that would be prohibited by the Act if performed by a U.S. person or within the United States.
The Act codifies a range of pre-existing executive order restrictions, including:
There is a 270-day wind-down period for entities operating in Russia to wind down or divest their operations prohibited under the new sanctions, including qualifying non-Russian-owned entities already operating in Russia and U.S.-owned entities engaged in good-faith divestiture efforts.
The principal significance of these codifications is durability. Elevating the restrictions from executive action to statute makes the restrictions more difficult to reverse unilaterally, even though most do not substantively expand the scope of existing sanctions.
The Act extends the Iran Sanctions Act of 1996, which was scheduled to expire on December 31, 2026, through 2031.
The Act exempts several categories of activity from its restrictions, including, among others:
The president may waive any sanction, restriction or duty under the Act by certifying to Congress that the waiver is in the national interest and providing a report.
Sanctions against Russia imposed under the Act may be terminated only after the president certifies that Russia has signed a peace agreement accepted by the government of Ukraine and has ceased hostilities and efforts to undermine Ukraine’s government.
Sanctions imposed under the Act on other persons or countries may end after the president certifies that the relevant conduct has stopped and reliable assurances have been provided. Any termination is subject to a congressional review period and a joint resolution of disapproval requiring a three-fifths vote in the Senate.
Except for the provision that extends the Iran Sanctions Act, the Act will sunset five years after enactment. Congress may, of course, renew the remaining provisions.