The Lindsey O. Graham Sanctioning Russia and Iran Act of 2026: What trade compliance teams need to know

Background

Key provisions

Direct tariffs on Russia
. The bill directs the President to impose tariffs of up to 500 percent on all Russian goods, a baseline economic penalty on Russian-origin merchandise.
Secondary tariffs on energy buyers
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the headline risk.
The bill directs the President to increase the rate of duty to a rate greater than zero and up to 100 percent on all goods from countries that knowingly purchase crude oil or natural gas that originated in Russia on or after the date of enactment and on countries that were among the five largest importers of those products from Russia during the most recent 12-month period. A parallel provision directs the President to increase the rate of duty to a rate greater than zero and up to 100 percent on all goods from countries that were among the top five countries facilitating Russian oil sanctions evasion during the most recent 12-month period. Critically, additional countries may be added to the list of countries subject to these secondary sanctions upon reevaluation by the U.S. Trade Representative every 180 days - meaning the target list is not static.
A narrow carve-out.
The measure includes an exemption for nations importing under 15 per cent of Russian natural gas exports that have implemented substantial measures to curtail those purchases.
Who's in the crosshairs
? China and India are the most prominent potential targets because both have continued buying large volumes of Russian crude. However, the language could also apply to other countries, including U.S. allies, depending on how the administration defines major consumption and evaluates energy dependence.
Discretionary, not automatic.
Importantly, the bill gives the president new authority; it does not automatically impose a 100% tariff on Indian, Chinese, or other imports the moment it becomes law.
Sanctions architecture
. Beyond tariffs, the broad package expands penalties against top Russian leadership, financial institutions, banking authorities, and the "shadow fleet" of oil tankers used to skirt existing Western price caps. The bill also allows the President to treat UK, EU, G7, or Five Eyes vessel designations as prima facie evidence of sanctions-evasion activity when identifying tankers moving Russian crude, uranium, natural gas, LNG, or petrochemical products. It also incorporates a five-year extension of existing sanctions against Iran, a key provision demanded by the White House.
Sunset and oversight
. The Russia-related titles sunset five years after enactment (Iran provisions excepted), and Congress retains a disapproval mechanism if the President moves to terminate specific sanctions.

What companies should monitor

the timing of presidential signature and any accompanying executive orders;
USTR's initial designation list and its 180-day reevaluation cycle, since additional trading partners could be added;
how "knowingly purchase" and "facilitating evasion" are defined in implementing regulations;
whether key sourcing countries qualify for the 15% natural gas exemption; and
vessel-level due diligence, given the shadow-fleet and flagging provisions tied to UK/EU/G7 designations.

Why this matters