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EO 14436Executive OrderTrump 47 · R Quiet signal

Executive Order 14436

Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026

TradeTradeDefense & SecurityDefense & SecurityEnergy & EnvironmentEnergy & EnvironmentEconomy & LaborEconomy & Labor

In simple terms

This executive order implements the Graham Act by imposing severe tariff increases on Russian goods (500% ad valorem) and on countries purchasing Russian oil/gas or facilitating sanctions evasion (100% ad valorem), but immediately waives all such duties and most sanctions through broad presidential waivers justified as in the national interest. The order delegates extensive authorities to the Secretary of State, Treasury Secretary, USTR, and Energy Secretary while maintaining monitoring requirements for potential future action.

Federal Register Open PDF 91 FR 66627

Record & deadlines

  1. Signed

    Signed by the President

  2. FR published

    Published in the Federal Register · 91 FR 66627

    Federal Register PDF
  3. 17d ago

    Date after which new purchases of Russian crude oil or natural gas trigger 100% duty increase (if waiver lifted)

Market exposure

Policy exposure mapping — not investment advice. Illustrative public companies are incomplete and not recommendations.

Sectors

Oil & gasSteel & aluminumChemicalsAgricultureShipping & logisticsBanking & finance

Mechanisms

TariffBan / prohibition

Role pressure

  • UncertainTrading-partner exporter — 500% Russian tariff and 100% conditional duties on oil/gas purchasers create severe potential exposure, but broad waiver suspends immediate impact; uncertainty persists based on monitoring outcomes and waiver duration
  • MixedImporter — US importers face formally increased duties but currently waived; risk of sudden reimposition creates planning uncertainty
  • UncertainDownstream manufacturer — Energy-intensive and commodity-dependent manufacturers face potential input cost volatility if waivers lapse and 500%/100% duties take effect
  • MixedDomestic producer — US energy producers could benefit from displaced Russian supply if waivers lapse, but current waiver status maintains status quo

Geographies

USCNINEUOTHER

Exposure dates

  • — Date after which new purchases of Russian crude oil or natural gas trigger 100% duty increase (if waiver lifted)

Illustrative public companies

Curated watchlist matches by sector/role — incomplete; not a recommendation.

MMM3MALBAlbemarleAAAlcoaADMArcher Daniels MidlandBACBank of AmericaBASFYBASFBLKBlackRockBGBungeCATCaterpillarCENXCentury AluminumLNGCheniere EnergyCVXChevronCLFCleveland-CliffsCOPConocoPhillipsCTVACortevaDACDanaosDOWDowDDDuPontXOMExxon MobilFDXFedExGEVGE VernovaGSGoldman SachsHSBCHSBCJPMJPMorgan Chase

Confidence: medium · Policy alerts

Key directives

  • Increase rate of duty on Russian Federation goods by 500% ad valorem
  • Increase rate of duty by 100% ad valorem on goods from largest 5 importers of Russian crude oil and natural gas making new purchases on or after October 18, 2026
  • Increase rate of duty by 100% ad valorem on goods from top 5 facilitators of Russian oil sanctions evasion
  • Waive all duties provided in sections 112 and 113 of Graham Act and this order
  • Waive sanctions provisions in sections 102(d), 102(a), 102(e), 103, 104, 105, 106, 107, 108, 109, 110, 111, and 117 of Graham Act
  • USTR to monitor circumstances related to importation and purchases of Russian oil and gas and report regularly to President
  • USTR to monitor activities of countries facilitating Russian oil sanctions evasion and report to President on top 5 facilitators
  • Delegate Graham Act authorities to Secretary of State, Secretary of Treasury, USTR, and Secretary of Energy with consultation requirements

Who is ordered

Related orders

  • referencesEO unspecified (March 24, 2026 nati

What to expect

Immediate

  • 500% tariff increase on Russian goods takes effect but is simultaneously waived
  • 100% conditional tariff increases on oil/gas purchasers and sanctions evasion facilitators take effect but are waived
  • Broad sanctions waivers issued under sections 102, 103, 104, 105, 106, 107, 108, 109, 110, 111, 117 of Graham Act
  • Congressional certification of national interest submitted

Near term (90d)

  • USTR monitoring of Russian oil/gas purchases and sanctions evasion begins
  • Regular reporting to President on country activities
  • Potential recommendations for further action based on monitoring

Long term

  • Waivers remain in effect until President or Secretary of State determines further action appropriate
  • Delegated authorities apply to future substantially similar legislation
  • Potential reimposition of waived duties/sanctions based on monitoring findings

Risks & tensions

  • Massive tariff authority (500% on Russia, 100% on third countries) paired with immediate waiver creates policy uncertainty and potential leverage tool rather than immediate economic weapon
  • Conditional duty on 'knowing' purchases creates evidentiary and diplomatic tensions around intent determination
  • Broad waiver of congressionally-mandated sanctions may generate separation-of-powers friction despite certification requirement
  • Monitoring framework without defined triggers for lifting waivers creates discretionary ambiguity
  • Oil/gas purchaser duty design could fragment global energy markets if waivers lapse
  • Reference to continued national emergency EO (March 24, 2026) preserves parallel sanctions architecture, creating dual-track complexity
Executive Order 14436: Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 · Executive Orders