On the evening of October 16, 2026, President Donald Trump signed an executive order implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 while immediately waiving its primary tariff and sanctions provisions under the Act’s national-interest exemption. The waiver suspends duties of up to 500 percent on Russian goods and up to 100 percent on goods from the largest importers of Russian oil and gas that would have applied from October 18. Existing sanctions under prior executive orders remain in force. Finance teams tracking energy costs, commodity exposure and trade compliance should note that the measures can be reimposed without new legislation.
President Trump used the statutory waiver authority in the Graham Act to suspend new Russia-related tariffs and most of the Act’s sanctions provisions two days before the October 18 implementation deadline. The move comes as the administration has pursued arrangements to increase Russian diesel supplies to the U.S. market in an effort to ease domestic energy prices ahead of midterm elections. Finance operators managing fuel hedges, freight costs, and sanctions screening should treat the waiver as reversible.
This is not legal, tax or sanctions advice. Operators should consult qualified counsel on specific compliance obligations.
- What changed: An October 16 executive order waives the Graham Act’s tariff powers (sections 112–113) and most of its sanctions provisions against Russian persons and entities.
- When: The order was signed late on October 16, two days before the Act’s measures were scheduled to take effect on October 18. The waivers have no fixed expiry and remain until the President or Secretary of State determines further action is appropriate.
- Who is affected: Importers of Russian goods, companies with exposure to Russian energy or banks, and buyers in countries that purchase Russian oil and gas (notably China and India).
- What to do this week: Review commodity hedges and freight budgets for potential diesel price relief; confirm that existing OFAC and prior EO sanctions screening remains fully operational; monitor congressional reaction and any subsequent administration statements on reimposition.
What did the October 16 executive order actually do?
The order, titled “Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026,” first sets out the tariff rates required by the statute—500 percent additional duties on Russian goods and 100 percent additional duties on goods from the five largest importers of Russian crude oil and natural gas (and top facilitators of sanctions evasion) that make new purchases on or after October 18. Section 4 then immediately waives those duties and the majority of the Act’s sanctions provisions (including sections 102(a), 102(d), 102(e), 103–111 and 117). Trump certified to Congress that the waiver is in the national interests of the United States, as the Act requires.
Which measures remain in force?
The waiver does not repeal the Graham Act, which remains on the books until 2031. It also leaves untouched the sanctions architecture established under earlier executive orders that address the national emergency with respect to Russia. Existing designations, blocked-property rules and secondary sanctions under those prior orders continue to apply. The order explicitly states that nothing in it affects those earlier measures.
Why did the administration act two days before the deadline?
Reporting from multiple outlets indicates the timing reflects the administration’s recent arrangement with Moscow to increase Russian diesel exports to the U.S. market in an effort to lower domestic energy prices. The Graham Act’s secondary tariff authority would have complicated that effort and risked friction with major buyers of Russian oil such as India and China. Zelenskyy publicly criticized the waiver as wrong and helpful only to Russia.
What should finance teams monitor next?
The waivers have no fixed end date; they remain effective until the President or the Secretary of State, in consultation with the Treasury Secretary and U.S. Trade Representative, determines that further action is appropriate. Bipartisan congressional letters had urged full implementation. Operators with energy or trade exposure should track oil and diesel price movements, any subsequent executive action restoring the tariffs, and updates from OFAC or the State Department. The October 18 date that would have triggered the new duties has passed without those duties taking effect.
How does this interact with prior Russia-related trade measures?
Earlier in October the administration had announced a diesel supply arrangement with Russia under an OFAC general license framework. The Graham Act waiver removes the near-term risk of 100 percent secondary tariffs on the largest buyers of Russian energy while leaving the pre-existing sanctions regime intact. Finance teams that had modeled potential tariff cost increases for Q4 should update those scenarios and reassess any contingency pricing or inventory decisions tied to the October 18 deadline.
- Did the Graham Act take effect on October 18? The statute remains law, but the executive order waived the principal new duties and sanctions provisions that were scheduled to become operative on that date.
- Can the tariffs be reimposed later? Yes. The waiver is revocable by the President or Secretary of State without new legislation.
- Are existing sanctions lifted? No. Prior executive-order sanctions and designations continue to apply.
- Which countries were most exposed to the secondary tariffs? The five largest importers of Russian crude and gas, widely reported to include China and India, would have faced the 100 percent additional duties on their exports to the United States.
- What is the practical effect on U.S. energy prices? The administration has framed the waiver as consistent with efforts to increase Russian diesel supply and ease U.S. prices; actual price impact will depend on volumes delivered and other market factors.
Last Updated: October 19, 2026. Related reading: US-Russia Diesel Supply Arrangement, October 9, 2026: Notes for Procurement and Finance hub.
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