Bottom Line Up Front
On September 18, the President signed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (H.R. 5334) into law. This bill squeezes Russia’s war revenues from three directions. First, the law imposes mandatory sanctions on the officials, oligarchs, banks, and state entities behind the war on Ukraine. Second, it requires steep tariffs on Russian goods, as well as on the countries that keep buying Russian energy and help Moscow evade sanctions. Third, it cuts off U.S. economic ties across investment, energy, securities, and sovereign debt. Separately, the law also prevents the Iran Sanctions Act of 1996 from expiring by extending it through 2031.
Congress has important oversight work ahead to ensure the new law is effective. The deadlines it sets out are heavily front-loaded, starting this October. Nearly all its sanctions, mandates, and prohibitions take effect within 30 days of enactment, with the first required report to Congress due even sooner. Below, we have assembled a calendar of the bill’s key dates and deadlines for this fall to guide congressional oversight.
1. Mandatory Sanctions
The first prong is a mandatory sanctions scheme targeting the people, revenues, financial flows, and weapons that keep Russia’s war machine running. These sanctions are mandatory, and Congress has an important role in ensuring the administration follows through on time and in full, as the law requires. While that oversight starts this October, the administration will be required to review and update designations every 180 days. This establishes regular check-ins for Congress to ensure the law is fully implemented long-term.
Key Oversight Dates
- September 18, 2026 — The President must take all necessary steps to implement the ban on importing Russian uranium under the USEC Privatization Act (§111(a)). Although this ban has been applied since August 2024, this provision directs the full implementation of the ban. That includes its application to the leadership, subsidiaries, and successors of Russia’s state-run nuclear corporation, Rosatom (§111(b)).
- September 18, 2026 — Sanctions under the executive orders issued for the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR Part 587) are codified. Lifting these sanctions now requires a waiver or congressional review procedures (§102(d)).
- October 18, 2026 — The President must review and impose sanctions on the senior officials, oligarchs, and military figures described in the law. The President must also identify shadow fleet vessels as blocked property (§102(b) and (c)).
- October 18, 2026 — The President must impose at least two of the three sanctions listed on the Central Bank of Russia, its subsidiaries, and successors. The President must impose all of these on Sberbank, VTB, Gazprombank, and every other Russian state-owned financial institution, as well as their successors and subsidiaries. Those same sanctions must also be imposed on any foreign bank that conducts significant transactions with these sanctioned entities. The President must further designate the leadership of these banks and prohibit U.S. persons from transacting with them (§103(a)).
- October 18, 2026 — The President must review and impose sanctions on any entity majority owned or controlled by the Russian government, as well as any entity affiliated with the Russian government (§104).
- October 18, 2026 — The President must review and impose sanctions on international financial-messaging systems that knowingly help sanctioned Russian banks circumvent the law’s sanctions, with certain exemptions allowed. These sanctions would also apply to entities’ leadership (§110).
- October 18, 2026 — The President must sanction foreign persons who support oil, gas, uranium, or coal production for sanctioned Russian persons on and after September 18, 2026 (§108(b)).
- January 1, 2028 — The President must begin imposing sanctions on the leaders, officials, senior executives, board members, and controlling shareholders of Rosatom, its subsidiaries, and successors (§111(b)) (42 U.S.C. 2297h-10a(d)(2)(C)).
The first test of the administration’s sanctions follow-through will be the October 18 round of designations. Congress should request a briefing on who was designated and how the administration is identifying the shadow fleet. In particular, it should press on whether the designations included the Russian banks named in the law and the foreign banks doing business with them.
2. Tariffs on Russia and its Enablers
The second prong ramps up economic pressure on the countries that keep Russia’s war machine afloat through energy purchases and the facilitation of sanctions evasion. The law requires the President to hit those top buyers and the main sanctions-evasion hubs with tariffs of up to 100%. However, Russia’s top energy buyers will only be hit if they make new purchases after the law’s 30-day mark. It also allows the President to impose tariffs of up to 500% on Russian goods.
Key Oversight Dates
- By October 8, 2026 — The President, through the U.S. Trade Representative, must submit a written justification for the Sec. 113 tariffs to the appropriate congressional committees. This submission must include the rationale and the methodology used to identify the countries to be subject to tariffs (§113(g)). This justification is due at least 10 days before whenever the tariffs are imposed. If the administration uses the full 30-day window and imposes them by October 18, the justification is due around October 8.
- October 18, 2026 — The President must raise duties on all goods imported from Russia to a rate of up to 500% (§112).
- October 18, 2026 — The President must impose duties of up to 100% on goods from any of the five largest importers of Russian crude oil or natural gas still purchasing on or after this date (§113(a) and (c)). A gas importer is exempt if its imports accounted for under 15% of Russia’s gas exports over a 12-month period, and it has taken significant steps to reduce them (§113(d)).
- October 18, 2026 — The President must impose up to 100% duties on goods from any of the top five countries facilitating Russian oil sanctions evasion (§113(a) and (c)).
The tariff justification is the first test of this bill’s implementation. Congress should scrutinize which countries the administration identifies and pressure it if these deadlines are missed.
3. Prohibitions on U.S. Economic Ties with Russia
The third prong works the other side of the ledger, targeting U.S. economic ties with Russia. It shuts off new American investment in Russia, energy sales to Moscow, trading in Russian state-linked securities, and purchases of Russian sovereign debt. Because these are prohibitions on U.S. persons as opposed to sanctions designations, the oversight test will be implementation, from how Treasury and the Securities and Exchange Commission (SEC) write the rules to how they enforce them.
Key Oversight Dates
- September 18, 2026 — U.S. persons, including U.S. financial institutions, are barred from purchasing Russian sovereign debt (§109).
- October 18, 2026 — U.S. banks and brokerage firms may not process transfers of funds to or from the Russian government or its state-owned entities, or transfers for the benefit of Russian officials, with exceptions (§105).
- October 18, 2026 — The SEC must prohibit covered Russian issuers’ securities from trading on U.S. securities exchanges (§106).
- October 18, 2026 — New investment in Russia by U.S. persons is prohibited, as is the export of certain services. U.S. persons may also not approve, finance, or facilitate transactions by foreign parties involving Russia that they are prohibited from doing themselves (§107).
- October 18, 2026 — U.S. energy exports to Russia and new U.S. investment in Russia’s energy sector are prohibited (§108(a)).
These bans are only as strong as their implementation. Congress should ask Treasury and the SEC how they will apply and enforce each prohibition, while watching for the regulations and guidance that give them teeth.
Iran: Extension of the Iran Sanctions Act
Russia aside, H.R. 5334 also stopped the December 31 expiration of the Iran Sanctions Act (ISA) of 1996, the legal backbone of U.S. efforts to keep foreign firms out of Iran’s oil fields. Now, ISA is safe through December 31, 2031 (§201).
Even with the sunset pushed to 2031, ISA is only as effective as its enforcement. Congress should request briefings from Treasury’s Office of Foreign Assets Control and the State Department on enforcement actions taken under the ISA to keep investment in Iran’s energy sector risky.
About FDD Action
FDD Action is a non-profit, non-partisan 501(c)(4) organization established to advocate for effective policies to promote U.S. national security and defend free nations. FDD Action serves as a trusted resource for congressional offices and executive branch policymakers navigating complex national security challenges, leveraging a team with decades of experience on Capitol Hill and in the policy arena.