President Donald Trump has signed an executive order implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, the sanctions law he signed on September 18, and has used it to waive the Act’s duties and sanctions provisions before they take effect.
The order first sets the rates the Act provides for. The duty on goods from Russia rises by 500 percent ad valorem. The duty on goods from the five largest importers of Russian crude oil and natural gas rises by 100 percent if a country knowingly makes new purchases of Russian crude or gas on or after October 18, 2026, and the duty on goods from the top five facilitators of Russian oil sanctions evasion rises by 100 percent. Each increase stacks on top of any other duty already in force.
The next operative section then removes them. Under section 115 of the Act, the order waives the application of any duties provided for in sections 112 and 113 of the Act or in the order itself. It also waives the sanctions provision in section 102(d), and the sanctions provisions and restrictions in sections 102(a), 102(e) and 103 through 111 and 117, covering the Act’s measures against foreign persons. The order states that the president has submitted to Congress a certification that the waivers are in the national interests of the United States, with a report explaining the basis, as the Act requires. The waivers remain in effect until the president, or the secretary of state in consultation with the Treasury and the Trade Representative, determines that further action is appropriate.
One limit is stated expressly. Nothing in the order affects sanctions or other measures under the earlier executive orders addressing Russia’s harmful foreign activities, continued on March 24, 2026, including every person already sanctioned under them. The pre-existing sanctions regime therefore stays in place. What is suspended is the new layer Congress added in September.
In place of the duties, the order sets up monitoring. The United States Trade Representative, consulting the secretaries of state, treasury and energy, is to watch imports and purchases of Russian crude oil and natural gas, track countries that facilitate Russian oil sanctions evasion, report regularly to the president, and promptly flag any circumstance that might indicate a need for further action, including with respect to the waivers.
The Act passed the Senate 86 to 11 on August 7 and the House 262 to 159 on September 16, and its October 18 deadline had become the next test of the administration’s Russia energy policy. Twelve senators wrote to the president on October 13 urging him to rescind the October 9 diesel deal with Moscow and to use the Graham Act’s pressure tools instead. European leaders meeting in Brussels on October 15 and 16 criticised the diesel arrangement, and Britain tightened its own sanctions on Russian oil on October 16. The waiver resolves the October 18 question in the opposite direction: the tariff threat over the largest buyers of Russian energy is now held in reserve, revocable at Washington’s discretion, rather than imposed by statute on a fixed date.