Updated 18 September 2026.
In brief
On 18 September Donald Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, one of the broadest packages of sanctions and tariff powers Congress has passed in the course of the war. The Senate carried it 86 to 11, the House 262 to 159. Yet the heart of the 61-page statute is not the sanctions lists. It is the tariffs — and they are aimed at buyers rather than at Moscow.
For four years pressure on Russia ran through the US Treasury: OFAC designations, the oil price cap, banks cut off from settlement, tankers detained. The new law moves the centre of gravity into trade policy. Its operative provision is Section 113: the president is required to impose duties of up to 100% on all goods from the five largest importers of Russian crude, the five largest importers of Russian gas, and five countries identified as the main hubs for evading oil sanctions. The importer lists are then redrawn every 180 days not by Treasury but by the US Trade Representative.
Changing the agency changes both the target and the price. A sanction on a Russian bank hits a Russian bank. A tariff on a buyer of Russian crude hits China, India and Turkey — and the American importer who actually pays the duty. Decisions about using the law will therefore be taken in the logic of trade negotiation rather than the logic of the war: six days after signing, Trump receives Xi Jinping at the White House, and the trade agreement with India has been stalled since February. Reuters has reported that US officials pressed for swift passage precisely to gain extra leverage in the talks with Beijing.
What was actually signed
The statute falls into two unequal parts.
The first is conventional sanctions, and it largely codifies authorities the administration already had. It covers Vladimir Putin, a broad list of senior officials, oligarchs defined by statutory criteria, foreign persons supporting the defence sector, banks and financial institutions, energy-sector entities and the tanker "shadow fleet". A separate section obliges the president, every 180 days, to review and cut off international financial messaging systems used to circumvent sanctions on Russian banks. The sanctions title runs for five years. Separately, the law extends the US Iran Sanctions Act of 1996, pushing its expiry from 2026 to 2031.
The second part is the tariff title, and this is genuinely new. Section 112 requires that, within 30 days, duties on all goods from Russia — crude, gas, LNG, refined products, coal and petrochemicals — be raised to as much as 500%. Its practical weight is limited: the 2022 ban on imports of Russian energy remains in force, so for the most part there is nothing left to tax. The substance sits in Section 113.
That section creates secondary tariffs on third countries. The first trigger: a country ranked among the five largest importers of Russian crude or gas in the 12 months before enactment and has knowingly made a fresh purchase since. The second: a country ranks among the five leading jurisdictions where entities help evade oil sanctions — here the conduct of private firms is enough, no state involvement is required. Gas has an escape route: if a country's purchases amounted to less than 15% of Russia's total gas exports and it has taken "significant steps" to cut them, no duty applies. For crude there is no such exemption at all.
The calendar, and a drafting collision
The law took effect on signature. The 30 days are not a switch-on date but the deadline given to the administration to impose the primary and secondary duties. Ten days before imposing or adjusting a rate, the administration must send the relevant congressional committees a written justification setting out its methodology. After that, the lists of the largest crude and gas importers are redrawn every 180 days on a rolling 12-month window. For the five countries designated as sanctions-evasion hubs there is no periodic review mechanism at all — an omission the Congressional Research Service has flagged.
The tariff section also contains a timing collision. Subsection (a) requires secondary duties to be imposed no later than 30 days after enactment. Subsection (c) makes a country liable only if it knowingly buys Russian crude or gas on or after the 30th day following enactment. Read literally, as the Congressional Research Service notes, the two windows overlap by at most a single day. Resolving that is left to the administration.
The two off-ramps are asymmetric. The president may suspend any measure by certifying to Congress that doing so is in the national interest and filing an explanatory report. Full termination differs by target: lifting measures against Russia and Russian persons requires certifying that Moscow has signed a peace agreement accepted by the government of Ukraine and ceased hostilities, while lifting a secondary measure against a third country requires only a finding that it has stopped the conduct that triggered the measure and given reliable assurances it will not resume. Either way termination takes effect after 30 days unless Congress passes a joint resolution of disapproval — which must itself become law. Legislators kept a lever against lifting sanctions; they built none that would compel the administration to apply them.
Analysts at the Cato Institute point to a third feature: within the ordinary adjustment mechanism, the ratchet turns one way. Once a country is designated under Section 113, the Trade Representative may move the rate only within a band above zero and up to 100%, even if purchases cease the following day. Taking it to zero requires the separate suspension or termination route.
Who is on the list, and why the list is contested
Here the statute becomes awkward. It names no country and specifies no data source.
The bill's sponsors and the Foundation for Defense of Democracies have named the five largest buyers of Russian crude as China, India, Slovakia, Hungary and Azerbaijan; Reuters reported the same list in July. Independent work points elsewhere. S&P Global, the Centre for Research on Energy and Clean Air and the Kyiv School of Economics all place Turkey third among importers of Russian crude — and Turkey is absent from the sponsors' list. The plausible explanation is the UN customs database: Turkish customs data does not disclose the origin of crude, although the national energy regulator publishes it.
The measurement problem deepens from there. Kyiv School of Economics tracking found that in June 40% of shadow-fleet voyages had no disclosed final destination. Pipeline gas never crosses a customs post at all. Russia stopped publishing customs statistics in March 2022, so there is nothing to check against. And the commodity code the law uses for natural gas also captures propane and butane.
The practical consequence: the administration draws up the list of targets, the law does not require the methodology to be published, and it gives Congress no mechanism to reject that methodology before a duty is imposed. That makes the statute a convenient bargaining instrument — and exposes it to charges of arbitrariness. Representative Don Beyer called the definition of a sanctions-evasion facilitator a loophole allowing almost any country to be designated, with no guardrails and no expiry. Gregory Meeks, the senior Democrat on the House Foreign Affairs Committee, objected that the drafting privileges presidential tariff powers over binding sanctions obligations.
The European question is unresolved. Hungary and Slovakia have no exemption on crude at all; Turkey is exposed on both fuels. EU decisions already require member states to end purchases of Russian oil and gas by the close of 2027, but until then the formal grounds for tariffs remain live.
Why the timing is difficult
The law arrives in the worst oil market in decades, and that sharply narrows the room to use it.
In its September report the International Energy Agency put Brent at around $105 a barrel at the time of writing, roughly 45% above pre-war levels, and forecast world oil supply averaging 100.7 million barrels a day across 2026 — 5.7 million below 2025 (August's actual figure was 100.1 million). Exports from the Gulf fell to about 13 million barrels a day in August, close to half their pre-war level. The squeeze is tightest in refined products: US diesel passed $200 a barrel in early September, roughly double pre-war prices. Combined net diesel and gasoil exports from the Gulf and Russia in August ran 1.6 million barrels a day below February.
Russia's own refining base has been knocked out — the Council on Foreign Relations estimates Ukrainian strikes have taken down as much as 40% of refining capacity. The paradox is that this makes Russian crude more, not less, necessary: there is nothing to replace it with. Removing an Indian or Chinese barrel from the market means pushing up the price at which American voters fill their tanks. Catherine Wolfram, a former US Treasury official, described tariffs-as-sanctions in January as an untested tool and warned that Russia and India might simply call Washington's bluff.
What it means for the Russian budget
Less than the headlines suggest, at least in the coming months. The new law does not appear in the current figures at all.
Russian finance ministry data show oil and gas revenues down 16.7% year on year for January to August 2026; in the first half they fell 22.7%, to 3.661 trillion roubles. August brought in 424 billion roubles, 2.2 times less than July. The ministry attributes the decline chiefly to oil prices in earlier periods, and the sharp August drop additionally to the tax calendar — no excess profits tax payment fell due that month, while payments to oil companies under the damper and reverse excise mechanisms rose. The federal deficit for January to July reached a preliminary 6.455 trillion roubles, above both the original annual target of 3.786 trillion and the raised government estimate of roughly 4.83 trillion that appeared over the summer.
Strikes on refineries exert separate pressure, through lower throughput and reduced product exports, but they do not directly explain August's receipts. As for the American statute, its effect materialises only if the administration actually imposes duties and buyers actually cut purchases rather than rerouting them through undisclosed destinations. Neither condition has been met.
The cost on the other side
For Kyiv the law is above all a political signal. The war is in its fifth year, the front in the east and south is largely static, and Russia holds roughly a fifth of Ukrainian territory. Russian strikes on the power system over the winter of 2025-26 brought the grid close to collapse more than once: in January residents of Kyiv spent an average of half of each day without electricity. Volodymyr Zelenskyy lobbied for the bill in person, travelling to Graham's funeral in July and meeting senators; in his framing its value lies not only in money but in the signal to Europe and to Ukrainians. Kyiv is now preparing for another winter, which Zelenskyy himself calls the most likely scenario.
Moscow's argument runs the other way. Dmitry Peskov called the law an unfriendly act and said fresh restrictions would complicate the search for a settlement. The point is not empty: the US-brokered negotiating track keeps stalling and restarting, and added pressure gives the Kremlin a pretext to step away without losing face. Whether this coerces Russia towards talks or derails them can only be judged after the fact.
For third countries the cost is more measurable. India — already hit in 2025 with an extra 25% tariff over Russian oil, lifted only under the February trade framework — responded carefully: the foreign ministry restated its commitment to energy security and its readiness to take all necessary measures to protect its trade interests. China's foreign ministry spokesman Guo Jiakun repeated Beijing's rejection of long-arm jurisdiction and unilateral sanctions lacking a basis in international law or a UN Security Council mandate. Turkey, Hungary and Slovakia face tariff exposure with no clear protective mechanism.
What could disprove this reading
First. The administration imposes duties quickly and at the maximum rate on at least one major economy. The instrument would then be real pressure rather than a bargaining chip, and the assessment would need revising.
Second. The ramp-down mechanism works. Section 113 allows rates to be adjusted when a country reduces its purchases of Russian fuel. Daniel Fried, a former State Department sanctions coordinator, notes that a comparable approach was used in 2013 to cut Chinese and Indian purchases of Iranian oil. An agreed schedule of reductions with Delhi and Beijing would dent Russian revenues without a single duty taking effect.
Third. The reverse scenario: the administration never really uses the law, relying on national-interest certifications. Fried names this as his own principal concern. In that case the premise of trade leverage fails too — there would be no leverage.
Fourth. The US-Iran war ends and the Strait of Hormuz reopens. Gulf barrels returning to the market would remove the constraint that makes using the law expensive today, and the cost of acting would fall sharply.
Fifth. The courts. The statute gives these duties a direct legislative basis, which makes them harder to challenge than the administration's earlier tariffs. But the review powers sit with the Trade Representative, whose actions — unlike the president's — are subject to judicial review under the Administrative Procedure Act. The first cases may define the limits of these powers.
Conclusions
What is established. The law was signed on 18 September 2026 and took effect on signature; 30 days is the deadline for the administration's initial measures. It obliges the president to impose duties of up to 100% on the five largest buyers of Russian crude, the five largest buyers of gas, and five countries designated as sanctions-evasion hubs. The importer lists are redrawn every 180 days; for the evasion hubs no such procedure exists. The sanctions title runs five years; the Iran sanctions extension runs to 2031. The sanctions measures against Putin, officials, banks and the shadow fleet largely codify existing authorities. The statute names no countries, specifies no data source, and gives Congress no way to reject the methodology before duties bite.
What remains hypothesis. That the law will be used in full. That tariffs will reduce purchases of Russian crude rather than push them into undisclosed routes. That economic pressure will move Moscow towards negotiations rather than away from them. That the cost to the American consumer, in the middle of a fuel crisis, will look acceptable to the White House.
If current trends hold — a tight oil market and unfinished trade negotiations with Beijing and Delhi — the toughest sanctions statute of the war will most likely remain what it became at the moment of signing: an argument in somebody else's bargaining. The first test comes in mid-October, when the administration's 30-day deadline expires.
Sources: Reuters, Bloomberg, Associated Press, NPR, CBS News, NBC News, Al Jazeera, South China Morning Post, congress.gov (texts of H.R. 5334 and S. 5025), Congressional Research Service (LSB11474), Atlantic Council, Cato Institute, International Energy Agency, Council on Foreign Relations, Centre for Research on Energy and Clean Air, Kyiv School of Economics, Russian finance ministry, RIA Novosti. Estimates of Russian crude import volumes differ between sources; data from Russian agencies and statements by officials of either party to the conflict are not independently verified. This article reflects the situation as of 18 September 2026.