On 18 September the President signed H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026. Two sections require tariffs: up to 500 per cent on everything imported from Russia, and up to 100 per cent on everything imported from a short list of countries the Act ties to Russian crude oil and natural gas — those that keep buying it and meet the Act's other tests, and those it counts as helping others evade the oil sanctions. Both deadlines fall on 18 October 2026, thirty days after enactment.
We read the enrolled text — the version that was signed — in full. The headline numbers are real, but they are ceilings. Both sections say “up to”. The Act names a floor exactly once: the subsection that allows the rate to be changed later sets it at greater than zero.
What the two tariff sections say
Section 112 covers goods from Russia:
“SEC. 112. (a) In General.—Not later than 30 days after the date of the enactment of this Act, the President shall, notwithstanding any other provision of law, increase the rate of duty for all goods, including oil, natural gas, liquefied natural gas, petroleum, petroleum products, petrochemical products, coal, and coal products, imported into the United States from the Russian Federation to a rate of up to 500 percent ad valorem.”
Section 113 covers goods from third countries. A country is caught if it did two things at once — bought new Russian crude or gas on or after the thirtieth day, and was already among the five largest importers of it:
“(c) Country Described.—A country described in this subsection is a foreign country that— (1)(A) knowingly made new purchases of crude oil or natural gas that originated in the Russian Federation on a date that is on or after 30 days after the date of the enactment of this Act; and (B) was among the 5 largest importers, by total volume, of crude oil or natural gas that originated in the Russian Federation during the most recent 12-month period preceding the date of the enactment of this Act”
A country is also covered, without buying anything, if it was among “the top 5 countries facilitating Russian oil sanctions evasion” over the same pre-enactment year.
Neither duty is the only one that applies. Both sections say the new rate sits on top of every existing duty, naming title VII of the Tariff Act of 1930, sections 122, 201 and 301 of the Trade Act of 1974, and section 232 of the Trade Expansion Act of 1962.
The rate can be changed without a waiver
Section 113(b) governs what the 100 per cent can become in practice:
“(b) Modification to Rate of Duty.—At any time after the initial imposition of duties under subsection (a) or (e), the United States Trade Representative shall modify or adjust any rate of duty imposed under subsection (a) or (e) to a rate greater than zero and up to 100 percent ad valorem upon submitting a written determination to the appropriate congressional committees that a country described in subsection (c) has taken significant steps— (1) to increase the importation, sale, supply, transfer, or purchase of crude oil or natural gas that originated in the Russian Federation; or (2) to decrease or cease engaging in the importation, sale, supply, transfer, or purchase of such crude oil or natural gas.”
Two things about that text. The band is open at the bottom — anything above zero satisfies it. And the trigger works in both directions: the same subsection is available whether a country buys more or buys less.
The Act then says explicitly that this adjustment is not a waiver and does not require the paperwork for one:
“(4) Applicability to modifications of certain duty rates.—The President is not required to submit a report under paragraph (1) for a modification or adjustment of a rate of duty pursuant to section 113(b). This paragraph does not modify or negate the requirement to submit a written determination required by section 113(b) or a report required by section 113(g)(1).”
What remains is the written determination itself and, under section 113(g)(1), a justification filed with Congress 10 days before the change, setting out the rationale and the methodology.
Three ways out, and they are not equally hard
The Act provides three distinct routes away from a duty once it exists. They impose different burdens.
Changing the rate, under section 113(b), as above: a written determination and a 10-day advance justification. No national-interest certification and no waiting period.
A waiver, under section 115: the President may waive “any sanctions provision with respect to a foreign person, any restriction with respect to a person, or any duty under this title” after sending Congress a written certification that the waiver is in the national interests of the United States, plus a report explaining the basis. Unclassified, with a classified annex permitted. The Act sets no expiry on a waiver and gives Congress no vote on it.
Termination, under section 117, is the only route subject to a congressional check, and its conditions are asymmetric. To end a measure against Russia, the President must certify that Russia has “signed a peace agreement that is accepted by the free and independent Government of Ukraine” and has “ceased all military hostilities against and any activities to overthrow, dismantle, and subvert the Government of Ukraine”. But for any other country — which is every country the 100 per cent duty can reach — the standard is much lower:
“(B) in the case of the termination of the application of a sanction, restriction, or duty with respect to any foreign person or foreign country (other than a Russian person or the Russian Federation)— (i) the foreign person or the government of the foreign country, as the case may be, is not engaging in the activity that was the basis for the sanctions or other measures being terminated; and (ii) the President has received reliable assurances that the foreign person or the government of the foreign country, as the case may be, will not knowingly engage in activity subject to sanctions or other measures under this title in the future”
Termination is also the one place where Congress gets a say: under section 117(b) the termination does not take effect for 30 calendar days, and within that window Congress may pass a joint resolution of disapproval. That review period stretches to 60 days for a report submitted between 10 July and 7 September.
So the friction runs backwards from the headline. The hardest exit — the one that needs a peace accepted by Ukraine — is the one guarded by a congressional vote. The easiest, which needs neither a certification nor a waiting period, is the one that sets the number the tariff actually is.
One provision took effect immediately
Most of the Act has a 30-day deadline. Section 109 does not:
“Upon the enactment of this Act, the purchase of sovereign debt of the Government of the Russian Federation by any United States person (including a United States financial institution) is prohibited.”
That took effect on 18 September, the day of signature. It closes a door that had been left formally open just as Minfin is relying more heavily on domestic issuance — the subject of our piece on the gap between what Russia's borrowing counts and what the budget receives.
What the Act does not decide yet
Who the five are. Section 113(e) requires the US Trade Representative, within 180 days of the first imposition and every 180 days after, to determine the five largest importers of Russian crude and the five largest importers of Russian gas, and to impose duties on them. No such list has been published. The Act does fix the classification: under section 113(g)(2) crude oil is Harmonized System code 2709 and natural gas is code 2711. Press reports circulating since the vote name likely candidates; those are journalists' lists, not determinations, and we are not adopting them.
There is also a question inside the text that we are not going to resolve here. The recurring review in section 113(e) works from “the most recent 12-month period preceding the determination”, while the entry condition in section 113(c) is anchored to the 12-month period preceding enactment, a period that never moves. Section 113(h) then says that nothing in the Act authorises duties on goods from any country “not expressly described in subsection (c)”. How a moving list and a fixed one are meant to fit together is a question for the first determination, not something we can settle by reading.
Whether the gas exception leaves anyone covered. Section 113(d) exempts a country from the duty for its gas purchases if its Russian gas imports were less than 15 per cent of Russia's total gas exports over the pre-enactment year and it has taken significant steps to reduce them. Applied together, the top-five test and the 15 per cent test may leave few countries covered on the gas side.
Section 114 carves out more: humanitarian trade, intelligence and law-enforcement activity, civil nuclear cooperation, NASA's launch procurement, existing Treasury general licences, and — relevant to oil flows — non-Russian oil that merely transits Russian territory. A 270-day window running to 15 June 2027 exempts winding down or divesting operations in Russia.
The Iran half, and the end date
The Act's title names Iran, and section 201 is the whole of it: the Iran Sanctions Act of 1996 has its expiry moved from 2026 to 2031.
Everything else expires first:
“SEC. 203. SUNSET.—This division (other than section 201) shall terminate on the date that is 5 years after the date of the enactment of this Act.”
“This division” is the unit that matters in that sentence. The Graham Act is Division A of what was signed; Division B of the same bill is an unrelated tax provision on the educator expense deduction, and the sunset does not touch it. Within Division A the sunset is general: it reaches both titles, and section 201 is the single carve-out.
Five years from 18 September 2026 is 18 September 2031. The tariffs, the sanctions and the sovereign-debt ban all stop there unless Congress acts again; the Iran extension outlives them.
What this changes in our model
Nothing today. The Act changes no number we track, and it cannot until duties are actually imposed and buyers actually respond.
Any eventual effect would reach oil and gas revenue, the second weakest of our eight indicators at 14 out of 100. The mechanism needs precision because it is easy to read backwards: section 113 does not tax Russia. It makes Russian oil costlier for the buyer by putting a tariff on that buyer's unrelated exports to the United States. If a buyer retreats, Russia's budget feels it through volume and discount — the price each barrel fetches and how many barrels sell — not through a tax rate set by Moscow. The two sections are also built differently: section 113 carries the machinery — a recurring determination, a list of countries, an adjustable band, a published methodology — while section 112 is one sentence and an instruction that its rate stacks on top of the existing ones. We did not measure what the United States still buys from Russia, so we are putting no size on what the 500 per cent would collect.
The strength index stands at 47.3 out of 100, in the stress zone, and no indicator moved today. Overdue receivables remain the weakest of the eight at 9. The live state of all eight is on the monitor.
What we do not know
Whether any of it will be applied. This is the whole question, and the Act does not answer it. Section 115 lets the President waive any duty under the title with one certification and no congressional vote. Nothing in the text obliges an administration to set the rate at the ceiling, or at any particular point above zero.
What rate will actually be set. Both sections say “up to”. Until a proclamation or a USTR notice exists there is no rate, only a range.
The vote counts from a primary source. The Senate and House tallies have been reported widely; congress.gov returned 403 to us on this bill, so we have not confirmed them against the official record and do not print them here.
What Russia will do. We found no Russian government response inside our window beyond remarks made before the signature.
The public law number. As of today no Public Law package for H.R. 5334 has appeared on govinfo, so this piece cites the enrolled bill. The signature date comes from the White House's own statement, published 18 September at 21:43 UTC, and from govinfo's date of issue for the enrolled text.