Trump Executive Order 14436 on Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026
Executive Order 14436, signed by the President on September 18, 2026, implements sanctions against foreign persons and restrictions with respect to persons from Russia and other countries. The order increases duties on goods imported into the U.S. from these nations, except as waived under certain conditions, in response to national interests identified by the President.
Background
The Graham Act, signed into law on September 18, 2026, allows the President to waive certain sanctions, restrictions, and duties imposed by the act. Section 115 of the Graham Act permits the President to waive these provisions if they are deemed in the national interest after receiving a written certification from Congress explaining why such a waiver is necessary. In accordance with this authority, the President has waived the application of these measures provided for in the Graham Act and submitted a certification to Congress that the issuance of this waiver serves the nation’s interests.
Increases in Rate of Duty
The executive order increases duties on goods from the Russian Federation. Goods must be subject to a 500 percent ad valorem rate, except for exceptions in section 114 of the Graham Act and waivers issued in section 4 of this order. For the largest five crude oil and natural gas importers originating from Russia, if they purchase new supplies on or after October 18, 2026, their goods must be subject to a 100 percent ad valorem rate, also with exceptions in section 114 of the Graham Act. The United States Trade Representative will monitor these activities and report back to the President for further action. Additionally, the top five countries that facilitate Russian oil sanctions evasion will have their goods subjected to a 100 percent ad valorem duty rate, again subjecting them to exceptions in section 114 of the Graham Act.
Monitoring
The Trade Representative, along with other senior officials including the Secretary of State and Treasury, must monitor imports and purchases by foreign countries of crude oil and natural gas from Russia. They are also tasked with reporting to the President regularly on any circumstances that could indicate a need for additional action, such as potential sanctions evasion. The Trade Representative must inform the President immediately if they believe this is necessary.
Waiver
The executive order waives several duties and sanctions provisions under the Graham Act. It removes restrictions on foreign persons and individuals, as well as certain sanctions with respect to both foreign and domestic entities. This waiver is intended to be in the national interest of the United States, as certified by the president and reported to Congress. The waivers apply immediately and do not affect existing sanctions related to Russian activities.
Delegation of Authorities
The executive order delegates specific functions and authorities from the President to various government officials. For example, it assigns sections 102(a), 102(b), 102(c), 104(a), 108(b), 111(b), and 114(a)(2) of the Graham Act to the Secretary of State in consultation with the Secretary of the Treasury, and vice versa. Sections 115 and 117(a) regarding sanctions or duties are delegated to the Trade Representative, also in consultation with other officials like the Secretary of State and Treasury. The delegations apply to any future public laws that mirror these provisions, ensuring consistent authority distribution across different departments.
Executive Order 14436 was signed on October 16, 2026, and published in the Federal Register on October 21, 2026 (91 FR 66627).