The Graham Russia Sanctions Act was signed into law on September 18, 2026. It carries the name of Senator Lindsey Graham, who died on July 12, 2026, and did not live to see it enacted. For anyone already on the Specially Designated Nationals (SDN) List maintained by the Office of Foreign Assets Control (OFAC), or at risk of being added to it, the 500 percent tariff headlines are not the point. Three things are: the new mandatory grounds for designation, the deadlines attached to them, and a route out of sanctions that works nothing like the old one.

What the act actually does

The President signed H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026. The sanctions sit in Division A: Title I deals with Russia, and Title II extends the Iran Sanctions Act through 2031. The House agreed to the Senate text on September 16 by a vote of 262 to 159. No public law number had been assigned when this article was written, so the act is cited here by bill number.

The Graham Russia sanctions act does not replace the existing Russia sanctions program. For sections 102 through 111, it draws on the International Emergency Economic Powers Act (IEEPA), and section 102(d) expressly preserves measures taken under the executive orders in force, including designations already made. The old regime stays as the foundation, with a statutory layer on top: Congress has fixed who the President must review and designate, and how measures under the new act may end.

For practitioners, that distinction carries the weight. A designation grounded in a statute behaves differently from one grounded only in an executive order, and the difference shows up most sharply when a client seeks delisting. The Russia program has carried statutory constraints before, but the new act expands their role and adds risks that were not there previously.

Mandatory designations: 30 days, then every 180 days

Section 102 of the Graham Russia Sanctions Act sets up a recurring mechanism. Not later than 30 days after enactment, and every 180 days thereafter, the President must review persons and vessels that may meet the criteria and impose measures on those that do. The first deadline falls due around October 18, 2026.

The range of sanctionable categories is broad. It encompasses senior Russian government officials, military commanders, and intelligence officials. The Act also specifically identifies foreign persons who knowingly supply goods or services related to Russia’s defense-industrial base, including computer numerically controlled machine tools, nitrocellulose, military-grade fiber optics, advanced sensors, and other items. The criteria also cover persons who engage in significant transactions with the Russian armed forces or undermine Ukraine’s defense capabilities, government institutions, critical infrastructure, or cybersecurity.

For Russia’s senior leadership, however, the Act does not stop at general criteria. It expressly identifies the offices whose holders are to be subject to sanctions. The list begins with the President and Prime Minister of Russia and goes on to name the Minister of Defense, the Chief of the General Staff, the Minister of Foreign Affairs, several other federal ministers, and the heads of the Foreign Intelligence Service (SVR), the Federal Security Service (FSB), the National Guard (Rosgvardiya), and other security agencies. Thus, the country’s senior political and military leadership is expressly included by Congress within the class of persons subject to the sanctions mechanism established by Section 102.

The same section reaches executives and controlling shareholders in the Russian defense, energy, and transportation sectors where the company supports the armed forces, the leadership of the Yamal LNG and Arctic LNG 1, 2 and 3 projects, and shadow fleet vessels with their owners, operators, insurers and certain crew members. It covers owners of foreign ports that allow sanctioned vessels to be serviced, and recipients of property transferred to evade sanctions.

Much of this is addressed to companies and individuals in third countries: suppliers, intermediaries, carriers, traders and financial institutions. A company in the United Arab Emirates, India, Turkey or Hong Kong can come into view through shipments, payments or shipping operations tied to the Russian defense and energy sector. The act defines “knowingly” broadly: actual knowledge is not required; it is enough that the person should have known of the conduct, the circumstance, or the result. A formal absence of intent is no defense. End-user screening, contractual restrictions, and documented compliance are what decide these cases.

The novelty is not the list, much of which echoes the executive orders already in force, but the duty to act. The President must return to the criteria every 180 days. Sanctions risk stops being a one-off decision and becomes a process with a calendar. A defensive position is worth assembling before the next review cycle, not after a name appears on the SDN List.

The oligarch test: what has to be rebutted

One of the section 102 categories is drafted unlike the rest. Sanctions must be imposed on a person who “is an oligarch in the Russian Federation” and who either has not demonstrated opposition to Russia’s war against Ukraine, or continues, after enactment, to benefit from an association with the Russian state.

The two limbs are joined by “or,” which matters more than it looks. Public disagreement with the war is not enough on its own: if the benefit from the association continues, the second limb operates by itself.

What makes the wording unusual is that it turns on evaluative elements that can, in principle, be contested with evidence. Unlike criteria built on an office held, an ownership percentage or a specific transaction, here there is room to argue about the person’s status, conduct and continuing benefit. In practice, that creates an informal burden of proof under the statute, and a strong reason to assemble rebuttal evidence in advance.

A separate question is who the act treats as an oligarch at all. There is no definition in the text. That leaves the administration wide latitude, but it also opens an independent line of defense: before arguing about attitudes to the war and ties to the state, one can contest whether the category applies at all.

Nor does the act explain what counts as demonstrated opposition: no threshold, no list of sufficient acts. The room for argument is wide, but a public statement will plainly fall short. Consistent and verifiable evidence is likely to be needed: corporate decisions, exits from assets and offices, the ending of state contracts and other economic benefits. In structure, this resembles the evidentiary package behind a delisting petition.

How sanctions come off now: Section 117

Section 117 is where the Graham Russia Sanctions Act changes the logic of removal for measures imposed under it. The distinction it draws is not simply between a state and an individual. It is also between a “Russian person” and every other foreign person.

The President must send Congress a report containing the required certification. A 30-day review period then begins, extended to 60 days if the report is submitted between July 10 and September 7. Sanctions may be lifted only if Congress does not pass a joint resolution of disapproval within that window.

For a “Russian person” or the Russian Federation, the President must certify that Russia has signed a peace agreement accepted by a free and independent government of Ukraine, and has ceased hostilities and activity aimed at overthrowing, dismantling, or undermining the Ukrainian government. The act defines “Russian person” broadly: a citizen or national of Russia, and any entity organized under Russian law or otherwise subject to Russian jurisdiction. On the literal text, even lifting sanctions on a single Russian national is tied to a peace agreement.

A different and far more attainable standard applies only to a foreign person or state that is not a “Russian person” or the Russian Federation. There, it is enough for the President to certify that the person has ceased the activity that gave rise to the measures, and has given reliable assurances against knowingly engaging in sanctionable activity in the future. That test is close to OFAC’s practice on changed circumstances, except that Russian nationals are expressly excluded from it.

Congressional control is heavier than ordinary notification, but the President keeps a strong hand. A resolution of disapproval may be introduced only by the majority or minority leader, or their designees in the Senate, where both the motion to proceed and passage require three-fifths of the full membership. The resolution must also become law, so a presidential veto would call for the constitutional two-thirds in both chambers. The practical effect of section 117 is publicity, delay, and a political price.

One question about overlapping grounds remains. Section 117 governs the termination of measures imposed under the new act, while many persons are already on the SDN List under Executive Order (EO) 14024 and may also fall within section 102. Section 102(d), moreover, preserves measures already taken under the executive orders. Ending one statutory ground will not necessarily unblock anything if an independent ground under an executive order survives, and the reverse is no simpler. How OFAC will reconcile section 117 with the administrative procedure under the Code of Federal Regulations (31 C.F.R. § 501.807) will become clear from future rules and individual cases.

Banks: designated institutions and foreign financial institutions

Section 103 requires sanctions within 30 days on the Central Bank of the Russian Federation, Sberbank, VTB, Gazprombank and other financial institutions organized under Russian law and owned in whole or in part by the state, together with their subsidiaries and successors. Most are designated already, so the list itself changes little. What changes is status: what rested on an executive order now rests on a statute.

The secondary measures matter more in practice. The full set of sanctions must be applied to any foreign financial institution conducting significant transactions with the Russian banks named, unless the Treasury Department determines that sanctions would not serve the economic or foreign policy interests of the United States. From 210 days after enactment, and every 180 days thereafter, the President must update the review of such institutions.

For clients whose funds move through foreign banks or are blocked by them, the consequence is concrete: banks will tighten their internal rules in advance. A payment may stop not because of sanctions against the client but because of the risk of correspondent restrictions, asset blocking or other measures against the intermediary bank. The wider the potential secondary sanctions, the more refusals rest on the bank’s own compliance rather than on any legal prohibition.

The practical conclusion is simple: do not wait for the refusal. If funds are already blocked or a payment has stopped, documents on the source of funds, the ownership structure, the banks on the route and the purpose of the transaction are better prepared now. After the first wave of designations, the load on compliance departments may grow and response times lengthen.

What US persons are prohibited from doing

Title I contains a number of flat prohibitions that apply whether or not anyone is designated.

• Section 105: transfers of funds to the Russian state and its officials.
• Section 106: trading in securities of Russian issuers on US exchanges.
• Section 107: new investment in Russia and the export of services identified by the Treasury Department.
• Section 108: new investment in the Russian energy sector and the export of US energy products to Russia.
• Section 109: purchasing Russian sovereign debt.
• Section 110: providing financial messaging services to sanctioned banks.
• Section 111: importing Russian uranium.

Section 107 deserves separate attention. Beyond prohibiting new investment and the export of Treasury-identified services to Russia, it bars US persons from approving, financing, facilitating or guaranteeing a transaction by a foreign person where that transaction would be prohibited for a US person. This approval-and-facilitation construction creates heightened exposure for US lawyers, accountants, directors, and advisers formally outside the deal’s perimeter.

Section 114 provides exceptions, among them intelligence activity, the performance of US obligations under international agreements, and certain humanitarian transactions.

Tariffs, the waiver and the five-year clock

The tariffs in the Graham Russia sanctions act drew most of the press attention. Section 112 requires duties on all goods from Russia to be raised within 30 days to a rate of “up to 500 percent” on top of other applicable charges. That does not mean an automatic flat rate of 500 percent: the act obliges the President to raise the tariff but leaves the choice of rate within the stated ceiling. For Russian energy, the practical effect is limited by import bans already in force, though the provision covers all Russian goods.

Section 113 allows a tariff of up to 100 percent on goods from countries among the largest purchasers of Russian oil or gas, or among the largest intermediaries in evading the oil sanctions. After the initial determination, the United States Trade Representative (USTR) reviews the lists every 180 days and may adjust the rate. A narrow exception applies to gas: the country’s purchases must be under 15 percent of total Russian gas exports over the relevant 12-month period, and the country must itself be taking substantial steps to reduce them.

Section 115 gives the President a broad waiver: he may decline to apply a sanctions provision, a restriction or a tariff, certifying to Congress in advance that this serves the national interests of the United States and explaining the basis. Unlike termination under section 117, there is no mandatory 30- or 60-day wait and no resolution of disapproval. The waiver, rather than final termination, may therefore become the main instrument of targeted exceptions and diplomatic compromise.

Finally, the clock. Division A expires five years after enactment, on September 18, 2031, unless Congress extends it. The Iran provision runs to 2031 regardless.

But the nearer date is the one that matters: around October 18, 2026, when the first mandatory wave of designations is due. That is what anyone who may fall within the section 102 criteria should be preparing for, by checking ownership structure, supply chains, shipping and banking routes, and the evidence that the risky activity has stopped.