Graham Sanctions Act Signed: Statutory Russia/Iran Sanctions, Tariffs Up to 500%
Signed September 18, 2026, the Act makes many Russia sanctions mandatory, adds oligarch, shadow-fleet and messaging-facilitator mandates, authorizes tariffs up to 500% on Russian goods, and extends the Iran Sanctions Act.
President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 on September 18, 2026, moving much of the US Russia sanctions framework from executive order into statute and making many designations mandatory, with an initial presidential review due within 30 days (on or before October 18, 2026). New mandatory measures cover Russian government-owned or affiliated entities, "oligarchs" who have not opposed the war, transferees of their assets, vessel providers, shadow-fleet owners, insurers, servicers and permissive foreign ports, and messaging entities used to circumvent sanctions. The Act also codifies investment, services and sovereign-debt restrictions, directs the SEC to delist Russian government-affiliated issuers, mandates the Russian uranium import ban and Rosatom leadership sanctions, and extends the Iran Sanctions Act five years.
For counsel, note that pre-enactment general licenses survive (§ 114(h)), but reliance must be tested against each designation authority, and the president retains broad § 115 waiver power on national-interest certification.
Two exposures now sit outside classic Russia risk: tariffs up to 500% on Russian goods and up to 100% on goods from specified top buyers of Russian energy or top evasion facilitators. Next: refresh counterparty, vessel, insurer and port screening, and track OFAC's expected 31 CFR Part 587 amendments and FAQs.