Bottom Line Up Front
Unless Congress acts, the statutory backbone of U.S. secondary sanctions on Iranian energy is set to expire on December 31, 2026. The Senate already did its part on August 7 when it passed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (H.R. 5334), which included a five-year extension of the sanctions law known as the Iran Sanctions Act (ISA) of 1996. As the House prepares to vote on the bill, it must consider that just three months remain until these critical sanctions authorities sunset. The window to prevent their expiration is closing.
Members of Congress should vote in favor of the Sanctioning Russia and Iran Act when it comes to the floor. Passing this bill will extend the authority the President has used against Iran’s energy sector since 1996. The House should also exercise oversight and request briefings from the administration to ensure the ISA and other sanctions authorities remain effective.
FDD Action Expert Analysis
“For nearly thirty years, the Iran Sanctions Act has been the legal foundation of America’s ability to keep foreign firms out of Iran’s oil fields. Letting it expire wouldn’t just create a gap in the law, it would tell Tehran and Moscow, at the worst possible moment, that Washington’s pressure campaign has an off switch. Congress has renewed this authority every time it has come up for decades. Iran’s behavior has not changed. If anything, its continued actions against the United States and closer kinetic partnership with Moscow only underscore the need for the House to act now and send this bill to the President’s desk before the authority lapses.”
– Alexandria Paolozzi Moore, Senior Director of Government Relations at FDD Action
What’s at Stake
A lapse would undercut the legal backbone of Iran energy sanctions for the first time in 30 years.
- No prior gap: Enacted in 1996 after passing the House 415-0, the ISA has never been allowed to expire. Congress renewed it in 2016 for a ten-year term via H.R. 6297, passing 419-1 in the House. These sweeping margins also demonstrate the long history of bipartisan support that the Iran Sanctions Act has enjoyed.
- Reduced secondary sanctions authority: The authority provided by the ISA is the primary lever used to isolate Tehran’s oil revenue from global markets. It creates massive risks for foreign firms that invest in Iran’s energy sector. Allowing the law to lapse would signal to private sector actors that the U.S. sanctions framework against Iran is eroding. That would directly undermine the goals of Operation Economic Outcast.
Tehran and Moscow are deepening a partnership that a lapse would only reward.
- Two birds, one bill: Russia and Iran face overlapping sanctions regimes and have cooperated on sanctions evasion, weapons transfers, and financial workarounds. That is why passing H.R. 5334 is essential. It extends the ISA and imposes new sanctions on Russian energy and financial institutions.
- Or two missed opportunities: Letting the ISA lapse, even briefly, will undercut a critical legal tool for pressuring the Iranian regime as the administration is trying to tighten the screws with Operation Economic Outcast. The vote also comes as the administration has renewed its attention to negotiating an end to Russia’s war on Ukraine. Passage would strengthen Washington’s hand in talks and help pressure Moscow to drop the maximalist preconditions it has set for ending the conflict.
What Congress Can Do
- Pass the Sanctioning Russia and Iran Act: Members of Congress should vote in favor of this one-two punch against the Axis of Aggressors. Pass H.R. 5334, and the sanctions architecture to squeeze Tehran and Moscow will be secured.
- Exercise oversight: Ask Treasury’s Office of Foreign Assets Control and the State Department for a briefing detailing enforcement actions taken under the ISA, among other authorities. Oversight will ensure the ISA remains an effective tool to limit the Iranian regime’s capabilities and keep investments in its energy infrastructure a risky business.
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.