By Claire Grunewald and Naomi Maxwell
Congress is currently considering a revised version of the late Senator Lindsay Graham’s legislation, the Sanctioning Russia Act. The bill, which was first introduced in April 2025 and cleared an initial procedural vote in the Senate on July 29, 2026, is designed to “bring sweeping sanctions against the enablers of Russia’s war in Ukraine” and “hold major purchasers of Russian oil and gas accountable” for supporting the war by granting the President broad new tariff authority.
Whether or not the bill will become law is unclear, but with congressional leadership interest and bi-partisan support, enactment is possible. Congress has often played a role in sanctions on Russia, and the program has typically had support from both parties, with the House voting to approve new military aid for Ukraine just last month. For regulated industries that have managed the impact of multilateral Russia sanctions for years, the question becomes what this bill would actually change if enacted, or if it will merely be symbolic.
Russia Sanctions under Biden versus Trump
Financial sanctions have played a crucial role in the global response to Russia’s invasion of Ukraine in February 2022. The Biden Administration rolled out unprecedented sanctions against Russia in immediate response to the invasion, maintaining the pressure over time through tools like the oil price cap, the imposition of secondary sanctions risks for foreign financial institutions, and the designation of third-country actors involved in Russia’s key revenue-generating industries.
Under the Trump Administration, new Russia sanctions have come to a halt. Since the start of Trump’s second term, OFAC has issued a singular Russia action targeting Russia’s two largest oil companies, Rosneft and Lukoil. While significant, the impact of this action was reduced by OFAC’s issuance of multiple General Licenses, and expanded relief during the U.S.-Iran conflict that allowed Russia to sell its oil using sanctioned vessels. As the sanctions have slowed, Russia has only grown more and more adept at evading existing restrictions.
Sanctions Highlights from the Bill
The Sanctioning Russia Act would authorize the president to impose tariffs on purchasers of Russian oil and introduce new sanctions and prohibitions across a variety of sectors of the Russian economy, including financial institutions, maritime, defense, securities, sovereign debt, energy, uranium, and oil. The bill also maintains current secondary sanctions on Iran by extending the Iran Sanctions Act of 1996 through 2031, which was set to expire this year, in line with pressure from the White House to make the bill address Iran as well. For more on the tariffs, see the Further Reading section below.
With regards to sanctions, significant portions of the bill are largely duplicative of existing targeting authorities, especially under Executive Order 14024, as amended (EO 14024). Virtually all of the major players in Russia have some restrictions or have been fully blocked, including the largest financial institutions (Central Bank of Russia, Sberbank, VTB bank, Gazprombank) and Russia’s prominent state-owned and private oil majors (Rosneft, Lukoil, Gazprom Neft, Surgutneftegas). While many provisions of the bill appear “mandatory” for the Executive Branch to implement, the bill is full of exceptions and carve-outs, as well as a broad waiver authority for presidents (as almost certainly requested by the White House in exchange for not opposing the bill). All of the authorities sunset in five years unless renewed by Congress.
Vessel Targeting: Sec. 102 of the bill introduces what, on paper, appears to be a nuanced approach to vessel targeting. Under existing authorities, OFAC sanctions vessels or fleets of vessels by identifying ships as the blocked property of persons or entities. Under this bill, Congress is seeking to authorize the identification of foreign vessels as blocked property based on vessel-specific behavior or characteristics alone, such as lacking adequate marine insurance, similar to how the EU targets vessels in Russia’s “shadow fleet.” Further, the language in 102(b)(5) implies that any foreign vessel transporting Russian energy products (crude oil, uranium, natural gas, liquefied natural gas, petroleum, petroleum products, petrochemical products, coal, coal products) could be fair game for designation.
For vessel owners, operators, and charterers, carrying Russian oil already introduces significant risk that a vessel or entire fleet could be sanctioned under U.S., UK, or EU law. This new authority grants U.S. regulators the ability to more easily target vessels involved in Russia trade, solely for exhibiting “unsafe or nonstandard maritime behavior.” While undefined, such behavior is likely to match the various red flags set out in OFAC and Price Cap Coalition guidance documents, including vessel location irregularities, false flag states and/or frequent changes, inadequate insurance, and dark or sanctionable STS activity. Understanding the full profile of vessels and counterparties prior to vessel sales, management, or fixture and implementing strong contractual controls and warranties are increasingly important to protect commercial operations and reduce likelihood of regulatory interest.
The bill also specifically calls out captains and senior crew leadership of these vessels, and authorizes sanctions against such seafarers who have “known involvement” in voyages where vessels lack adequate insurance or evades compliance with the Price Cap. However, when it comes to Russian oil trade where permissibility has been a function of purchase price and adequate documentation, “evasion” of the Russian oil price cap may not be apparent for vessel masters and crews that are not subject to U.S., UK, or EU jurisdiction. This language increases direct liability for vessel masters and crew leadership, and builds on the increasing trend from regulators to shift liability onto those crewing shadow fleet vessels in addition to owners or ship managers.
Vessel Sales: The bill also authorizes sanctions against owners, operators, and managers of those same vessels, as well as those who “transfer” vessels to the Russian Federation or use by a Russian person.
Taking specific action to limit the sale and transfer of vessels to Russia or for use by Russia to sustain its available trading fleet would be new for the United States. While OFAC could currently identify major sellers of tankers to Russia for operating in the maritime sector of the Russian economy, this new authority spells out the risk for vessel owners and brokers, and aligns with the EU’s long standing prohibitions related to vessel sales to Russia.
Insurance: The bill also directly calls out insurance industry participants, authorizing sanctions against foreign persons that the President determines knowingly “provide underwriting services or insurance or reinsurance necessary for” vessels that are used by Russia or Russian persons to move such energy products to circumvent sanctions. This even includes instances where cover is provided to vessels whose owners, operators, or managers knowingly engaged in unsafe or “nonstandard maritime behavior,” lacks adequate maritime insurance, or evades compliance with the price cap.
For insurance industry participants, “knowingly” will vary widely depending on the type of insurance product and how current policies are written when it comes to providing. As foreign financial institutions, insurance companies already are at risk of secondary sanctions under EO 14024. However, this creates a particularly heightened risk for (re)insurers and protection and indemnity (P&I) clubs providing cover for voyages to and from Russia. Enhanced due diligence at the underwriting stage and review of declarations of Russian voyages under existing policies may be warranted.
Delistings: The bill also adds new challenges for delistings in the Russia program. The fight over flexibility between Congress and the executive branch is most apparent in Sec. 103(d), which has a provision essentially requiring all sanctions imposed under EO 14024 to “remain in effect.” Congress’s intent seems to be that Treasury could not lift any sanctions imposed under EO 14024, preventing the removal of any of the more than 6000 persons, entities, or vessels blocked under EO 14024. The President will likely seek to use the waiver in Sec 115 to set aside this limitation.
The bill also sets up Congressional review in Sec. 117 for any delistings of persons or entities designated under the bill, similar to the framework established in CAATSA. The provision requires the President to certify to Congress, specifically the Senate Banking and House Financial Services and Senate Foreign Relations and House Foreign Affairs committees, that the person being delisted is not engaging in the activity that was the basis for the designation for which they were designated and that the President has received assurances that they will not do so in the future. Congress has 30 days to review the President’s certification and can override the proposed delisting with a joint resolution of disapproval.
For designated persons, navigating the path off the U.S. sanctions list can already feel like a near impossible feat. While foreign policy is always a consideration for delistings, requiring Presidential sign off creates hurdles for OFAC’s ability to adjudicate petitions and make necessary administrative changes to designations.
Conclusion
If enacted, the President will receive new tariff authorities along with some rather duplicative sanctions authorities. At the same time, the Department of State and the Department of Treasury will receive significant obligations to begin reviewing targets and issuing designations, or issuing waivers for various sanctions provisions. For a practically dormant program, these are resource heavy tasks, all while Secretary Bessent is promising a “modernized sanctions architecture” with actions that are “aggressive and targeted, with defined timelines” to drive behavior change.
While this bill contemplates a return to “Biden-era” sanctions against Russia, it is important to note that the “escalatory pressure” and “stronger tools” necessary to implement aggressive, targeted and efficient actions against Russia exist under existing regulatory tools. Treasury and the President already have the authority to block specific vessels, apply pressure on key industries such as insurance, and target third-country buyers of Russian oil. The inactivity by the U.S. on Russia sanctions has not been a product of inability to impose new sanctions but a result of a foreign policy choice by the Trump Administration, and with the broad waiver provision, it is unlikely the passing of this bill alone will result in increased pressure from the White House on Putin.
Further Reading on Tariffs
What’s in Lindsey Graham’s Russia-Tariffs Bill? from The Wall Street Journal.
The Russia Sanctions Bill Would Give the President Permanent, Unnecessary, and Almost Unfettered Tariff Authority from Georgetown Law’s IIEL Policy Brief.
Potential roadblocks ahead for Graham-led Russia sanctions bill from Politico. See also statements from Neal & Wyden and Meeks.