Trump orders implementation of Graham sanctions law on Russia and Iran
The White House issued an order titled "Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026" on October 16, 2026.
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Trump and states it was issued under the Constitution and laws of the United States, including the Graham Act and section 301 of title 3, United States Code. The order says the President signed the Lindsey O.
Graham Sanctioning Russia and Iran Act of 2026 into law on September 18, 2026. It says the statute provides for sanctions against foreign persons, restrictions on persons, and duties on goods imported into the United States from the Russian Federation and certain other countries.
The text says section 115 of the Graham Act authorizes the President to waive any sanctions provision, restriction, or duty under the law if the President submits a written certification to Congress stating that the waiver is in the national interests of the United States, along with a report explaining the basis for that certification. In the order, the President says he is waiving the application of sanctions, restrictions, and duties provided for in the Graham Act.
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The order says a certification has been submitted to Congress that the waiver is in the national interests of the United States. The order increases the rate of duty on goods from the Russian Federation by 500 percent ad valorem, subject to exceptions in section 114 of the Graham Act and the waivers issued in the order.
It says the increase applies in addition to any other duty, fee, tax, exaction, or charge that may already apply to the good. The order also sets a 100 percent ad valorem duty on goods from the largest five importers of crude oil and natural gas that originated in the Russian Federation if the country knowingly makes new purchases of Russian-origin crude oil or natural gas on or after October 18, 2026.
The same section says this is also subject to the exceptions in section 114 and the waivers in the order. A separate duty increase is imposed on the top five facilitators of Russian oil sanctions evasion.
The order says goods from those countries will face a 100 percent ad valorem duty, again subject to the Graham Act exceptions and the waivers in the order. The United States Trade Representative is tasked, in consultation with the Secretaries of State, the Treasury, and Energy and any other appropriate senior official, with monitoring imports and purchases of Russian-origin crude oil and natural gas.
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The Trade Representative must regularly inform the President about such activity and provide recommendations for further action. The same monitoring structure applies to countries facilitating Russian sanctions evasion.
The order says the Trade Representative will report to the President on which countries are among the top five facilitators. The order also directs the Trade Representative to promptly inform the President of any circumstance that might indicate the need for further action, including action related to the waivers.
It says the waivers will remain in effect until the President or the Secretary of State, in consultation with the Secretary of the Treasury and the Trade Representative as appropriate, determine that further action is appropriate. The President separately waives duties provided for in sections 112 and 113 of the Graham Act.
He also waives the sanctions provision in section 102(d) with respect to foreign persons and the restrictions in section 102(d) with respect to persons. The order states that nothing in it affects any sanctions or other measures provided for under any Executive Order issued to address the national emergency that was continued on March 24, 2026, with respect to specified harmful foreign activities of the Government of the Russian Federation, including sanctions on all persons covered by that Executive Order.
It also waives the application of sections 102(a), 102(e), 103, 104, 105, 106, 107, 108, 109, 110, 111, and 117 of the Graham Act with respect to foreign persons and persons. The order delegates Graham Act authorities across the administration.
It assigns specific functions to the Secretary of State, the Secretary of the Treasury, the Secretary of Energy, the Trade Representative, and related consultations among those officials. It also says executive departments and agencies shall take all appropriate measures within their authority to carry out the order, and that the order's publication costs will be borne by the Department of State.
