Trump Faces Oct. 18 Deadline To Name Countries Hit With New Russia Tariffs

President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 into law on Sept. 18. Now the clock is running on his first real test of it.

Under Section 113 of the Act, Trump has 30 days from enactment, until Oct. 18, to identify which countries get hit with new tariffs for buying Russian oil and gas. This comes from a legal memo by Sullivan & Cromwell and a client alert from Barnes & Thornburg. The law requires duties of up to 100% on goods from any country among the top five global purchasers of Russian crude or natural gas, or among the top five jurisdictions facilitating Russian sanctions evasion.

As of today, those top five individual countries are China, India, Turkey, Brazil, and Azerbaijan, according to OilPrice.com. The European Union as a bloc would rank fourth if counted collectively, but the U.S. counts it as member states, not a single entity.

The Act goes further on Russia itself. It authorizes tariffs of up to 500% on all Russian goods imported directly into the U.S., according to the Epoch Times. It also codifies a chunk of existing executive-order sanctions into statute. Executive order sanctions can be lifted by any president with a signature. Statutory sanctions cannot. Barnes & Thornburg's memo lays out what it would actually take to unwind them: a signed peace agreement accepted by Ukraine, certification to Congress, and a 30-day congressional review period. Businesses should treat these restrictions as durable, not temporary, the firm advised.

How It Got Here

The bill passed the Senate 86-11 on Aug. 7 and the House 262-159 on Sept. 16, according to NPR. Fifty-eight House Democrats crossed over to support it alongside nearly all Republicans, while seven Republicans joined most Democrats in opposition, NPR reported, citing a growing fracture in the GOP caucus over Ukraine support. Reps. Jared Golden (D-Maine) and Marie Gluesenkamp Perez (D-Wash.) broke the other way, joining Republicans on a procedural rule vote, per the Epoch Times.

The bill carries the name of the late Sen. Lindsey Graham (R-S.C.), who first introduced it in April 2025 and died July 11, 2026. His sister, Sen. Darline Graham, was appointed to fill his seat and reintroduced a revised version with Sen. Richard Blumenthal (D-Conn.), according to the Epoch Times. Rep. Michael McCaul (R-Texas) carried it in the House, telling colleagues it was time to "put maximum pressure" on Vladimir Putin and "cripple the Russian war machine," per NPR.

The law also extends the Iran Sanctions Act of 1996 through 2031, five years beyond its scheduled year-end expiration, according to Sullivan & Cromwell.

The Loophole Argument

Democrats who opposed the bill raised a specific concern. Rep. Don Beyer (D-Va.) told NPR the law "has a loophole that would allow [Trump] to define basically any country as a facilitator of evading Russian sanctions," letting him hit them with tariffs up to 100% "with no guardrails or oversight, and no expiration."

The text doesn't fully bear that out. Barnes & Thornburg's memo notes the Act's sanctions provisions sunset five years after enactment unless Congress renews them, and the law includes waiver authority the Trump administration specifically pushed for during negotiations, according to the Epoch Times. Beyer's broader point—that the president alone decides which countries count as evaders with limited court review—is accurate as a description of how the statute is structured. Whether that amounts to a meaningful check or a rubber stamp is the actual fight, and it's one Congress chose to leave unresolved when it passed the bill.

Pressure From Both Sides

A bipartisan group of four House members, Reps. Marcy Kaptur (D-Ohio), Brian Fitzpatrick (R-Pa.), Mike Quigley (D-Ill.) and Joe Wilson (R-S.C.), sent a letter urging Trump not to ease sanctions in exchange for Russian political prisoner releases, a trade reportedly floated inside the administration. "Sanctions relief will embolden Russia and prolong the war," they wrote, pressing Trump to use the Oct. 18 deadline to roll out his "first round of new sanctions designations," according to Pravda.com.ua, which cited the letter as reported by European Pravda.

Trump himself has kept his options open. At the UN General Assembly on Sept. 22, he said the law gives him "enormous new tariff authorities" and that "if necessary, I will have to use them," adding he's working with both Moscow and Kyiv toward a deal "more quickly than people understand," according to Sullivan & Cromwell's summary of his remarks. He named no countries and no timetable.

Trump has a tool that could put 100% tariffs on India and China, two of America's largest trading partners, inside two weeks. Whether he pulls that trigger, waives it, or leaves the determinations vague remains unknown as of today, Oct. 5. The Oct. 18 deadline is the next concrete marker to watch, and it will show whether "tariff diplomacy" on Russia is a real lever or just UN-podium rhetoric.