Summary
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On 18 September 2026, the United States enacted H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026. The legislation establishes a framework for substantially higher customs duties, sanctions and prohibitions concerning Russia, including tariffs of up to 500% on Russian-origin goods. [whitehouse.gov], [congress.gov]
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The legislation also provides for tariffs of up to 100% on goods from countries identified as leading purchasers of Russian-origin crude oil or natural gas, or as major facilitators of Russian oil sanctions evasion. This creates potential customs exposure for trade flows that are not themselves of Russian origin. [congress.gov], [govtrack.us]
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Importers should assess Russian-origin products, suppliers and energy-related country exposure, while monitoring implementing measures, country designations, tariff rates, exceptions and possible waivers. Customs classification and origin remain important, but sanctions-related ownership, transactional and supply-chain information may also be required to evaluate the new risks accurately. [congress.gov], [govtrack.us]
Article
On 18 September 2026, the President of the United States signed H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 into law. The White House described the legislation as authorizing and expanding statutory sanctions, tariffs and prohibitions concerning Russia, while also extending existing sanctions relating to Iran. [whitehouse.gov]
From a customs perspective, one of the most significant provisions is the increase in duties applicable to goods imported from Russia. The enrolled legislation specifically contains provisions concerning increased duties on Russian goods and duties targeting countries that purchase Russian-origin crude oil or natural gas or facilitate sanctions evasion. The covered Russian imports expressly extend to major energy and industrial product categories, including oil, natural gas, liquefied natural gas, petroleum and petrochemical products, and coal. [congress.gov], [govtrack.us]
The Russian measure permits an ad valorem tariff of up to 500%, additional to other applicable customs duties, fees, taxes and charges. The legislation also provides for duties of up to 100% on goods originating in certain third countries. The latter mechanism targets countries that knowingly make qualifying new purchases of Russian-origin crude oil or natural gas and rank among the five largest importers during the relevant preceding 12-month period. It also addresses countries identified among the five largest facilitators of Russian oil sanctions evasion. [congress.gov], [govtrack.us]
This secondary tariff mechanism is commercially important because exposure may extend beyond direct trade with Russia. A company importing goods into the United States from a designated third country could face additional duty even where the imported merchandise contains no Russian material. The practical impact will therefore depend on the countries formally identified, the rates selected, the effective dates and the availability of statutory exceptions or presidential waivers. The legislation also requires periodic reassessment, meaning the geographic scope may change as energy-purchasing patterns and sanctions-evasion findings evolve. [congress.gov], [govtrack.us]
Businesses should promptly map imports of Russian origin and review sourcing from countries with significant Russian energy relationships. Customs, tax, sanctions, procurement and treasury teams should coordinate their assessments. Priority controls include validating non-preferential origin, reviewing contractual tariff-allocation clauses, identifying shipments that may arrive after implementation, testing landed-cost scenarios, and monitoring official country designations and customs instructions.
Particular care is required before treating the maximum rates as automatically applicable to every shipment. The Act creates the statutory tariff framework, but the actual liability for a particular import will depend on implementing action, the applicable country and product scope, entry timing, and any exception, exclusion, suspension or waiver. This update is therefore not a substitute for transaction-specific customs or sanctions advice.
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