President Trump signed the much-anticipated Russia (and Iran) sanctions bill into law on Friday, September 18, 2026. The final text of H.R. 5334 is available here.
In Brief
It has been a long journey since Senator Lindsey Graham introduced an earlier version of the bill in the Senate in April 2025. After Senator Graham passed away in July, a new Russia sanctions bill was introduced bearing his name, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (the “Act”). The new bill had broad bipartisan support and at first it seemed as though it would quickly sail through Congress. However, questions arose after President Trump pushed to add Iran sanctions provisions to the bill and when some legislators raised concerns about giving President Trump new tariff authorities. Ultimately, the bill passed in the House on September 16 with a vote of 262-159 after passing in the Senate on August 7 with a resounding 86-11 vote. The final House vote included 58 Democrats voting in favor of the bill and only 7 Republicans voting against it.
Other than extending certain Iran sanctions authorities, the bulk of the Act focuses on Russia. The Act provides the President with the authority to impose tariffs on goods imported from countries that are top purchasers of Russian energy products or that enable evasion of Russian sanctions. The Act also authorizes and even requires sanctions against various parties supporting Russia’s war against Ukraine and engaged in certain business activities in Russia, with a particular focus on the Russian financial sector. Some of these parties and activities were already subject to sanctions imposed under Executive Order or other authorities – the Act codifies these sanctions to make them more difficult to relax later.
The Act provides that most of its measures are to be imposed within 30 days of enactment, i.e., by October 18, 2026. The Act frames many of its measures as mandatory, meaning that the President must implement the measures where the circumstances described in the Act are determined to be present. That said, this involves fact-finding and interpretation; moreover, the Act gives the President the authority to waive any measures that are determined to be in the national interest of the United States. This means that we will need to see how the Act is implemented and enforced in practice.
We break this down in more detail below.
In Detail
- Iran Sanctions Act Extension
The Act extends the 1996 Iran Sanctions Act (P.L. 104-172) through 2031. That law authorizes so-called secondary sanctions in the form of banking restrictions, visa restrictions, asset freezes, and other sanctions against foreign entities that invest in Iran’s petroleum sector or provide goods or services to Iran’s military. Those sanctions were scheduled to expire on December 31, 2026.
Iran continues to be subject to long-standing comprehensive US sanctions prohibiting US persons from engaging in virtually all transactions involving Iran unless exempt or authorized by a general or specific license issued by the Office of Foreign Assets Control (“OFAC”) in the US Treasury Department. The Act does not change that framework. However, OFAC has recently imposed more sanctions against Iran under its new Operation Economic Outcast. We have a blog post in the works on those developments, which will be published soon.
2. Russia-Related Tariff Increases
- Goods Imported from Russia
Within 30 days of enactment, the Act requires the President to raise duties on all goods of Russian origin imported into the United States up to 500% of their value, in addition to any other duty or fee imposed under US law.
- Countries Purchasing Russian Energy or Facilitating Sanctions Evasion
Within 30 days of enactment, the Act requires the President to impose targeted tariff increases of up to 100% on goods from the five largest importers of Russian crude oil and natural gas during the prior 12 months, as well as the five countries determined to have helped Russia evade sanctions on oil exports. The US Trade Representative will be required to adjust those tariff rates based on whether a country has significantly increased or reduced its purchases of Russian oil and natural gas. The restriction will not apply to a country whose Russian natural gas imports account for less than 15% of Russia’s total gas exports, provided the country is taking significant steps to reduce those imports.
3. Primary and Secondary Sanctions Against Russia
A. Parties Affiliated with or Supporting the Russian Government
- Government Officials and Individuals Benefitting from Ties to the Russian Government
The Act requires the President to impose sanctions on Russian President Vladimir Putin, Prime Minister Mikhail Mishustin, other Russian cabinet ministers, senior government officials, and military leaders. These sanctions include freezing any US-based assets, revoking US visas, and denying entry into the United States. The Act provides that any existing sanctions on these individuals would have to remain in place. The Act also extends these sanctions to (i) Russian oligarchs who benefit from their ties to the Russian government; (ii) senior executives and principal shareholders of Russian Arctic energy projects; and (iii) senior executives of Russian defense contractors and other companies that support Russia’s military.
- State-Controlled Entities
The Act requires the President to freeze the assets of any entity determined to be controlled by, majority-owned by, or otherwise affiliated with the Russian government. The President is required to conduct an initial review to identify entities subject to sanctions noted above within 30 days of enactment, followed by reviews every 180 days.
- Non-Russian Foreign Entities
The Act directs the President to sanction non-Russian foreign entities that knowingly engage in certain targeted activities, including:
- selling or supplying military-use products or other export-restricted items to Russian defense contractors;
- using deceptive transactions to facilitate the sale of restricted military items and components to Russia;
- conducting significant transactions with the Russian military;
- undermining Ukraine’s government, military readiness, democratic institutions, or critical infrastructure;
- carrying out assassinations, corruption, money laundering, or other crimes on behalf of the Russian government; or
- using deceptive transactions, including digital currencies, to evade US sanctions.
B. Energy and Trade Restrictions
- Shipping
The Act requires the President to identify and sanction foreign-flagged “shadow fleet” vessels used by Russia to transport crude oil or petroleum products in violation of international price caps within 30 days of enactment. The sanctions also will apply to vessels transporting Russian petrochemicals, natural gas, uranium, coal, arms, or other goods in violation of existing US sanctions, as well as foreign vessels involved in ship-to-ship transfers of sanctioned goods to help Russia evade sanctions. Covered vessels will be designated as “blocked property,” subjecting them and their operators to asset freezes and limiting their access to maritime insurance and other financial services.
Additional sanctions, including visa restrictions and personal asset freezes, will apply to:
- owners and operators of covered vessels;
- captains and senior officers of covered vessels;
- insurers of sanctioned vessels; and
- foreign port operators that permit sanctioned vessels to dock.
The Act states that these restrictions will not apply to measures necessary to protect vessel crews, safeguard human life, or prevent environmental harm.
- Energy
The Act broadly prohibits US persons from engaging in new investments in Russia’s energy sector and bars the export or transfer to Russia of US-produced energy products. The Act also imposes asset freezes and visa restrictions on foreign persons that sell, supply, or otherwise support the maintenance or expansion of Russian oil, natural gas, coal, petrochemical, or uranium production.
- Uranium
The Act requires asset freezes and visa restrictions on senior executives and leaders of Rosatom, Russia’s state-owned atomic energy corporation. It also directs the President to implement the 2024 Prohibiting Russian Uranium Imports Act (P.L. 118-62), which bars imports of low-enriched uranium from Russia or through Rosatom. The Department of Energy can waive the import ban for certain Russian low-enriched uranium if it determines that no viable alternative sources are available to sustain US nuclear reactors and that the waiver is in the US national interest.
C. Investments and Services
The Act bars US persons from investing in Russia. It also prohibits them from providing services designated by OFAC to Russian individuals or companies, or from financing or facilitating foreign investments in Russia.
D. Financial Markets
- Financial Institutions
The Act requires the President to sanction Russia’s central bank and other state-controlled Russian financial institutions. US entities will be barred from transactions with covered Russian institutions and their subsidiaries. Sanctioned banks also will be prohibited from opening accounts at US institutions, denied US financing under the 2017 Countering America’s Adversaries Through Sanctions Act (P.L. 115-44), and subject to other US investment restrictions. Senior executives and majority shareholders of sanctioned financial institutions will face visa restrictions and personal asset freezes. The Act also authorizes the imposition of secondary sanctions on foreign banks that conduct significant transactions with covered Russian financial institutions, unless the President waives the requirement after Treasury determines that doing so is in the US interest. The President is required to periodically review the sanctions to ensure they remain in effect.
- Transfers of Funds
The Act generally bars US depository institutions and registered securities brokers from processing monetary transactions involving the Russian government, government-controlled entities, or Russian officials unless any such transfer is authorized by a general or specific license issued by the US Government.
- Securities Markets
The Act requires the Securities and Exchange Commission to bar securities issued by Russian government-controlled entities or Russian government officials from trading on US securities exchanges.
- Sovereign Debt
The Act bars US persons from buying Russian sovereign debt.
- Financial Messaging Systems
The Act requires the President to impose financial sanctions (including asset freezes and restrictions on transactions with US institutions) on firms that provide payment messaging services knowingly used to evade US sanctions on Russian financial institutions. In 2022, the United States and its allies cut off certain Russian banks from SWIFT, the global messaging network large financial institutions primarily use to process international payments and transfers.
4. Other Provisions
- Exceptions
The Act provides that sanctions will not apply to certain categories of transactions, including those involving humanitarian aid, agricultural commodities, food, medicine or medical devices; US intelligence, law enforcement, or national security activities; compliance with international obligations; diplomats traveling to UN headquarters in New York; or official US government business.
The Act also provides that its prohibitions will not apply to transactions conducted under general licenses issued by OFAC prior to the enactment of the Act and will not impact the terms of existing general licenses or OFAC’s ability to extend or issue new general licenses. For example, US-based healthcare companies may rely on multiple general licenses issued by OFAC in the last four years to continue to support local operations of their owned or controlled entities in Russia. The Act does not impact the continued availability or the scope of these general licenses.
Where the prohibitions in the Act apply, the Act provides for a 270-day exception after enactment for US and foreign companies winding down business operations in Russia.
- Waivers
The President can waive sanctions required by the Act by certifying to Congress that the waiver is in the US national interest and explaining the basis for that determination.
- Penalties
The Act subjects sanctions violators to civil and criminal penalties, including fines and imprisonment, available under the International Emergency Economic Powers Act.
- Termination and Congressional Review
The President can terminate sanctions, duties, or restrictions imposed under the Act after certifying to Congress that Russia has signed a peace agreement with Ukraine and ended efforts to overthrow or subvert the Ukrainian government. For sanctions on non-Russian entities, the President will have to certify that the foreign person or country is no longer engaged in covered activity and has provided reasonable assurances that it will not knowingly resume that activity. Any termination of sanctions or tariffs will be delayed for 30 days to allow congressional review. During that period, Congress can pass a joint resolution blocking the proposed action, and the Act will provide expedited procedures in both chambers for considering such resolutions.
- Sunset
The Act (other than the Iran sanctions extension) will terminate five years from enactment.
