New U.S. Sanctions Targeting Russia And Iran And U.S. Tariffs Targeting Third Countries Buying Russian Energy

] The U.S. adds to its Russian sanctions and Iranian capabilities with the "Lindsey O. Graham Sanctioning Russia and Iran Act of 2026. In a long-awaited move by many, on Friday, 18 September 2026, President Donald Trump signed the "Lindsey O. Graham Sanctioning Russia and Iran Act of 2026" ("the Act") into law.

While the real effects of the Act remain to be seen, it further broadens the authority of the President to impose sanctions against actors that deal with Russia and Iran. It also places substantial elements of the Russia sanctions framework on a statutory footing, making it more difficult for the President to revoke these in the future. Furthermore, it establishes new tariffs of up to 500% on Russian imports and up to 100% on goods imported from certain countries that purchase significant amounts of Russian crude oil or natural gas, or that have facilitated Russian oil sanctions evasion. Note however that the Act also preserves significant presidential discretion in how it is implemented.

Mandatory sanctions on certain persons affiliated with or supporting Russia

The legislation provides for the "mandatory" imposition of sanctions against certain persons within 30 days of the Act being passed, i.e. on or before October 18, 2026. Note however that the President has broad discretion in determining which persons are caught by the Act and whether the applicable statutory criteria are satisfied, meaning these sanctions are not automatically imposed. Therefore, although the Act indicates that designations are "mandatory", this will to some extent be part of the discretionary assessment made by the administration on who to actually designate under the Act. Of most significance are the following areas:

• The Act imposes mandatory sanctions on foreign vessels that knowingly transport certain Russian-origin energy commodities as it requires sanctions on any foreign vessel that either "transports crude oil, uranium, natural gas, liquefied natural gas, petroleum, petroleum products, petrochemical products, coal, or coal products that originated in the Russian Federation" as well as any vessel that "engages in a ship-to-ship transfer involving crude oil, uranium, natural gas, liquefied natural gas, petroleum, petroleum products, petrochemical products, coal, or coal products that originated in the Russian Federation with a vessel that is subject to sanctions imposed by the United States."
• Mandatory sanctions on foreign persons who supply Russian persons with vessels for transporting certain energy commodities, i.e. any foreign person that knowingly transfers to Russia, or makes available for use by a Russian person, any vessel designed to transport crude oil, uranium, natural gas, liquefied natural gas, petroleum, petroleum products, petrochemical products, coal, or coal products.
• Mandatory sanctions on Russian government-owned or affiliated entities as well as certain Russian oligarchs.
• Mandatory sanctions targeting transferees of sanctioned persons’ assets.
• The Act creates a mandatory sanctions regime aimed at shadow fleet vessels that the Russian government or Russian persons use to move Russian-origin energy commodities and other goods in order to evade sanctions, including vessels engaged in unsafe or nonstandard maritime practices, lacking adequate maritime insurance, or evading applicable oil price caps. This provision also targets persons who own, operate, manage, insure, or provide services to such vessels, as well as foreign port owners or operators who allow sanctioned vessels supporting Russia to dock or receive services.
• Mandatory sanctions against certain financial institutions that knowingly circumvent sanctions – both Russian and non-Russian.

Again, while these sections are "mandatory", they are not automatic and still require a presidential determination. However, in light of the Act, businesses should reassess their Russia-related sanctions exposure. 

In addition to this, the Act imposes U.S. primary restrictions on transfers involving Russian government or government-owned entities, trading of securities of Russian-affiliated issuers on U.S. exchanges, and new investment restrictions.

New Tariffs

Beyond the sanctions regime, the Act creates substantial new tariff powers aimed at Russia itself and at third countries that keep buying Russian energy. These tariffs stack on top of whatever other duties, taxes, fees, or charges already apply:

• Tariffs on Russian-origin goods: The President must raise tariffs on all imports from Russia, with a ceiling of 500%. This power sweeps broadly across Russian-origin goods generally and is not confined to energy products.
• Countries that keep buying Russian crude oil or natural gas face tariffs of between just above 0% and 100% on their exports to the United States. This applies specifically to countries ranking among the five largest purchasers, by volume, of Russian crude oil or natural gas, where the purchases continue knowingly past the statutory deadline.
• Crucially, once a country is caught by this provision, the tariff reaches all of its goods entering the United States, not just its Russian energy purchases. A carve-out exists for any country importing less than 15% of Russia's total annual gas exports that is also demonstrably working to cut that figure further.
• A parallel tariff, also set between just above 0% and 100% ad valorem, applies to goods from countries ranked among the top five facilitators of evasion of sanctions on Russian oil.

As mentioned above, the extent of the measures the President may take under the Act are still uncertain. Furthermore, the Act contains a broad waiver authority of the President wherein he may waive most of the provisions of the Act if it is in the national interests of the United States.

This Act comes around the same time that Secretary of Treasury Scott Bessent announced last week that the U.S. and China have extended their bilateral trade truce to January 10, 2027, pushing back the expiration date on a one-year suspension of Section 301 port surcharges on Chinese-built and Chinese-operated ships. A formal USTR Federal Register notice has not been published, meaning Bessent's announcement has not yet been given legal effect.