News Desk · Sanctions evasion

White House order sets Graham Act tariffs, then waives them and a long list of the Act's sanctions

An order dated 16 October 2026 implements the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026. It sets tariff increases on Russia and on countries tied to Russian oil, but waives those duties and a long list of the Act's sanctions provisions.

Sanctions evasionUS16 Oct 20262 min read

The White House published an order titled "Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026", signed by President Donald J. Trump and dated 16 October 2026. According to the order, the President signed the Act into law on 18 September 2026, and Section 115 of the Act lets the President waive its sanctions, restrictions and duties by giving Congress a written certification that the waiver serves US national interests. The order says the President has sent that certification.

Section 2 of the order sets three tariff increases: 500 percent on goods from Russia; 100 percent on goods from the largest 5 importers of Russian-origin crude oil and natural gas if a country knowingly makes new purchases on or after 18 October 2026; and 100 percent on goods from the top 5 facilitators of Russian oil sanctions evasion. The order says these increases are subject to the exceptions in Section 114 of the Act and to the waivers in Section 4 of the order.

Section 4 then waives the duties in Sections 112 and 113 of the Act and in the order itself. It also waives the sanctions and restrictions in Sections 102(a), 102(d), 102(e), 103 through 111, and 117 of the Act. The order says nothing in it affects measures taken under executive orders on the Russia-related national emergency continued on 24 March 2026. The waivers stay in effect until the President, or the Secretary of State in consultation with the Treasury Secretary and the US Trade Representative as appropriate, decides further action is needed.

Under Section 3, the US Trade Representative will monitor purchases of Russian-origin crude oil and natural gas by countries, and the facilitation of Russian sanctions evasion by countries, and report regularly to the President.

Why it matters to AML professionals

Sanctions teams need to know which legal authorities are active, not only which laws have been passed. A statute can be enacted and then waived in part, while existing sanctions programmes continue unchanged. Screening and policy teams should track the official text of waivers and later changes before updating procedures.

Red flags in this case

If this landed in your queue

  1. Confirm which sanctions programme and legal authority applies to the counterparty before clearing an alert
  2. Check the official sanctions list and any current waivers or general licences on the date of the transaction
  3. Review trade documents for origin of goods, vessel details and the full chain of intermediaries
  4. Escalate to the sanctions advisory team if the activity involves Russian-origin oil or gas and the legal position is unclear

Key terms

Waiver
A formal decision not to apply a legal requirement, such as a sanction or a duty, for as long as the waiver lasts.
Sanctions evasion
Steps taken to get around sanctions, such as hiding who owns goods or money or where they came from.
Duty (tariff)
A tax charged on imported goods, usually set as a percentage of their value.

Interview angle

A new sanctions law is passed but many of its provisions are waived. How would you update your screening programme?

Explain that you would read the official text of the law and the waiver, confirm which existing programmes still apply, document the decision, and set up monitoring for any later change to the waiver.

Sources

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Every fact in AMLift News Desk stories comes from an official source: a regulator, court, government gazette or the company's own filing.