President Trump has implemented the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 in an executive order that builds the Act’s full tariff and sanctions apparatus and then waives almost all of it. Executive Order 14436, signed on October 16 and published in the Federal Register on October 21, is the primary document for this story and was read in full.
Section 2 of the order raises the rate of duty on goods from the Russian Federation by 500 percent ad valorem. It raises duties by 100 percent on goods from the five largest importers of Russian crude oil and natural gas if such a country knowingly makes new purchases of Russian origin oil or gas on or after October 18, 2026, and by 100 percent on goods from the top five facilitators of Russian oil sanctions evasion. The increases would apply on top of any other duties in force.
Section 4 then waives what Section 2 creates. The president waives the application of any duties provided for in sections 112 and 113 of the Act or in the order itself, waives the sanctions and restrictions in section 102(d), and waives the sanctions provisions of sections 102(a), 102(e) and 103 through 111 and 117. Each waiver rests on a certification to Congress, which the order says has been submitted, that the waiver is in the national interests of the United States. 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. Existing sanctions imposed under earlier executive orders on Russia’s harmful foreign activities are expressly unaffected.
What remains live is the monitoring and the delegation. The Trade Representative, consulting the secretaries of state, treasury and energy, must monitor purchases of Russian oil and gas and the facilitation of sanctions evasion, report regularly to the president, and flag circumstances that might require the waivers to be lifted. Implementation functions are delegated across the State Department, the Treasury, the Trade Representative and the Energy Department.
The distinction matters for anyone pricing Russian energy exposure. The headline rates, 500 percent on Russia and 100 percent on its largest oil and gas customers, are enacted law and issued orders, not proposals, but they are not in effect: the same instrument suspends them. The operative fact is the trigger, not the rate. A determination that a major importer has made new Russian purchases after October 18, or a decision in Washington to end the waiver, is what would convert this document from a warning into a tariff event.