Graham Act Codifies Russia Sanctions; Presidential Waiver Defers Most Risk
A new U.S. statute pulls much of the Russia sanctions program out of executive orders and into law, but a presidential waiver defers most of the resulting client exposure.
The Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (P.L. 119-111), signed into law on September 18, 2026, seeks to codify the existing executive order-based Russia sanctions program — a structural shift for compliance teams that have long tracked OFAC's evolving directives. Per a Holland & Knight analysis published October 23, 2026, however, a presidential waiver defers most of the practical exposure the statute creates, making near-term risk largely prospective rather than immediate.
Sophisticated counsel should read the waiver's scope and conditions closely: statutory codification could narrow future policy-shifting discretion in some respects while expanding mandatory designations or penalties beyond the executive order baseline in others. Russia-facing trade, energy, shipping and banking clients should map which obligations are self-executing under the Act and which remain contingent on the waiver, and calendar any expiration, review or modification conditions. The evidence here is a single published analysis; the waiver's operative text, the Iran-related provisions and any implementing guidance should be confirmed against the statute before reliance.