Sep 16, 2026 · 4 min · 3 segments
Poised for imminent passage, the Russia and Iran Act of 2026 would create a new secondary tariff tool aimed at countries buying Russian energy or helping Russia evade sanctions. The bill could mark a…
Ned SteinerHost
For over the past year, we have seen the administration deploy new trade tools, including the Section 338 action against Canada with its import and federal procurement restrictions.

statutory authority for what are effectively secondary tariffs tied to Russia sanctions.

The legislation at issue is the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026.

The Senate already approved the bill by a decisive 86 to 11 vote, and the House is now moving forward toward final passage.

Just this week, the bill cleared a critical procedural hurdle in the House, the rule allowing floor consideration passed 214 to 211, thanks in part to two Democrats who crossed party lines to support the rule and allow the legislation to move forward.

What makes the bill especially important for the trade community is Section 113, its trade tariff mechanism for secondary tariffs.


Second, the bill targets countries that are found to be helping Russia evade sanctions through transactions, logistics networks, or other activities that facilitate continued access to global markets despite existing restrictions.

The key compliance point is that these are not tariffs on a narrow list of products.

The tariffs would apply to all products imported from a covered country, making this a countrywide trade measure rather than a sectoral action.

And unlike many existing trade authorities, the bill makes the impositions of tariffs mandatory once the statutory conditions are met.

Presidential discretion exists primarily in determining the tariff level, with legislation authorizing tariffs of up to 100% against covered countries.

The bill also contains a presidential waiver mechanism, giving the administration some flexibility in circumstances specified by the statute.


For over the past year, we have seen the administration deploy new trade tools, including the Section 338 action against Canada with its import and federal procurement restrictions.

statutory authority for what are effectively secondary tariffs tied to Russia sanctions.

The legislation at issue is the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026.

The Senate already approved the bill by a decisive 86 to 11 vote, and the House is now moving forward toward final passage.

Just this week, the bill cleared a critical procedural hurdle in the House, the rule allowing floor consideration passed 214 to 211, thanks in part to two Democrats who crossed party lines to support the rule and allow the legislation to move forward.

What makes the bill especially important for the trade community is Section 113, its trade tariff mechanism for secondary tariffs.


Second, the bill targets countries that are found to be helping Russia evade sanctions through transactions, logistics networks, or other activities that facilitate continued access to global markets despite existing restrictions.

The key compliance point is that these are not tariffs on a narrow list of products.

The tariffs would apply to all products imported from a covered country, making this a countrywide trade measure rather than a sectoral action.

And unlike many existing trade authorities, the bill makes the impositions of tariffs mandatory once the statutory conditions are met.

Presidential discretion exists primarily in determining the tariff level, with legislation authorizing tariffs of up to 100% against covered countries.

The bill also contains a presidential waiver mechanism, giving the administration some flexibility in circumstances specified by the statute.

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