The Executive Order, signed on October 16, formally brings the Graham Act into force. The order directs a 500% ad valorem duty on goods from the Russian Federation. It further imposes a 100% ad valorem duty on goods from the top five countries that knowingly import Russian crude oil or natural gas after October 18, 2026. A similar 100% tariff is directed at the top five countries found to be facilitating Russian oil sanctions evasion.
However, Section 4 of the same order waives every one of these duties and sanctions. The President submitted the required certification to Congress that the waivers are in the national interests of the United States, a step authorized by Section 115 of the Graham Act. The wide-ranging waiver covers the core sanctions provisions and the newly imposed tariffs.
The order delegates responsibility for monitoring the situation to the United States Trade Representative (USTR), in consultation with the State, Treasury, and Energy departments. The USTR is directed to monitor global purchases of Russian oil and the evasion of existing sanctions, and to recommend further action to the President if circumstances change. The waiver is structured to remain in effect until such time as the President or the Secretary of State determine that further action is appropriate.