On September 18, 2026, President Trump signed into law the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, (H.R. 5334, “The Act”). The bill, named for the late senator, imposes sanctions, tariffs and prohibitions related to Russia.
The Act uses tariffs to sanction Russia both directly and indirectly. Under the law, the president is instructed to impose tariffs of 500% on goods imported from Russia and up to 100% on goods imported from other countries that continue to certain types of trade with Russia. The Act also extended the Iran Sanctions Act of 1996.1
Tariff Details
Within 30 days from the date of passage, Section 112(a) of the Act directs the president to impose tariffs of 500% on goods imported from Russia to the U.S., including oil, natural gas, liquefied natural gas, petroleum, petroleum products, petrochemical products, coal and coal products.
Section 113 directs the president to impose tariffs of up to 100% on countries that:
- 1A. “[k]nowingly 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” September 18, 2026; and
- 1B. “was among the 5 largest importers, by total volume, of crude oil or natural gas that originated in the Russian Federation in the most recent 12-month period preceding” September 18, 2026; or
- 2. “was among the top 5 countries facilitating Russia oil sanctions evasion during the most recent 12-month period preceding” September 18, 2026.
Every 180 days the U.S. Trade Representative (USTR), in conjunction with the Secretary of State and Secretary of Energy, is directed to reevaluate, using a rolling 12-month view, which countries are among the top five importers of Russian crude oil and natural gas and impose tariffs on those countries, as appropriate.
Section 113 directs the USTR to modify the imposed tariff rate to something greater than zero up to 100% if at any time a given country has increased or decreased its importation of Russian crude oil and/or natural gas.
An exception does exist for any country that otherwise would fall within the section 113 100% tariff if their imports of Russian natural gas during the rolling 12-month period represented less than 15% of the total Russian natural gas exports during that same period, and they have taken significant steps to reduce those imports.
Currently, both India and China would fall within the parameters of section 113.
Your Guide Forward
Cherry Bekaert established a cross-functional team of professionals to help advise and support our clients with the downstream effects when tariffs and tariff refunds impact tax, accounting, audit and financial reporting functions.
If you have questions about preserving your rights or about any other legal or trade implications that may exist, we recommend reaching out to appropriate legal counsel.
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1 In addition to addressing Russia and Iran, the law modifies Internal Revenue Code section 62(d)(1) to extend a permitted tax deduction for certain unreimbursed expenses for kindergarten to 12th grade teachers to now include early childhood educators.
