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The Graham Act and U.S. sanctions that could hit Europe

On September 16, 2026, the U.S. House of Representatives passed, by a vote of 262 to 159, a bipartisan measure officially titled the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (H.R. 5334 / S. 5025). A month earlier, on August 7, 2026, the Senate approved the bill by an overwhelming 86–11 margin. Ukrainian President Volodymyr Zelenskyy was personally present in the Senate on July 28 during the procedural stage. After a year and a half in the legislative pipeline—introduced in April 2025 by Senator Lindsey Graham and Democrat Richard Blumenthal—the measure was finally signed by U.S. President Donald Trump.

For Capitol Hill, passage of the act became a symbolic fulfillment of the political will of Republican Senator Graham, who died on July 11, 2026. His Senate seat was taken by his sister, Darlene Graham, who co-sponsored the final version of the text. For Europe, however, the moment marks the start of a period of high economic uncertainty, turning an instrument of pressure on the Kremlin into a potential source of “friendly fire” against allies.

The law’s fundamental purpose is to destroy the sources of financing for Russia’s war machine through targeted and systemic restrictions. The document provides for mandatory primary sanctions against the Russian leadership, key systemic banks including Sberbank, VTB, and Gazprombank, oligarchs, Russia’s defense industry, and prospective liquefied natural gas projects such as Yamal LNG and Arctic LNG. A separate block imposes prohibitive tariffs of up to 500 percent on direct U.S. imports of Russian raw materials and uranium, as well as measures against the “shadow tanker fleet.” In the fight against illicit oil shipments, the United States officially gains the right to use the registries and sanctions lists of the European Union, the United Kingdom, and the G7 countries, thereby synchronizing transatlantic pressure. In addition, at the White House’s request, the law merged the Moscow and Tehran sanctions tracks and extended the Iran Sanctions Act through 2031.

The main geopolitical effect comes from Section 113 of the law, which contains a secondary-tariff mechanism. Graham and Blumenthal originally proposed 500 percent duties on any country buying Russian oil or gas. After protracted negotiations with the White House, the language was softened: the law now authorizes the U.S. president to impose secondary tariffs of up to 100 percent on any goods from countries among the five largest importers of Russian oil, natural gas, or uranium, as well as on states recognized as key participants in sanctions evasion. Because decisions on specific rates and timing are delegated to the head of state, President Donald Trump now holds an enormous lever of diplomatic and commercial influence.

It is this secondary-tariff battering ram that makes the American initiative extremely sensitive for Europe. According to the Centre for Research on Energy and Clean Air (CREA) and the International Energy Agency (IEA), among the largest importers of Russian hydrocarbons in 2026—alongside China and India—are individual EU states. In the oil segment, Hungary and Slovakia are most vulnerable, remaining highly dependent on supplies via the southern branch of the Druzhba pipeline. In the gas sphere, France, Belgium, and again Hungary periodically appear among the regular buyers of Russian LNG and pipeline gas. For Slovakia, whose exports to the United States in 2025 alone amounted to about $6.5 billion, or Belgium with $29.3 billion, hypothetical 100 percent tariffs on cars or industrial equipment could produce a severe economic shock.

To avoid an unintended blow to allies, a protective clause known as a “safe harbor” mechanism was inserted into the law. An importing country may claim exemption from secondary tariffs if its purchases amount to less than 15 percent of Russia’s total gas exports and its government is taking “significant steps” to reduce dependence. The formula was written with the European Union’s plan to end all imports of Russian fossil fuels by the end of 2027 in mind. The list of the top-five importers must be reviewed every 180 days, so every six months Budapest, Bratislava, and other European capitals will have to “prove” to Washington their progress on diversification.

Passage of the bill produced sharp political disagreements. Supporters in Congress called the document a decisive step toward depriving the Kremlin of war revenues. Critics in the Democratic Party, including Gregory Meeks and Hakeem Jeffries, argued that the law gives the White House uncontrolled authority to impose protectionist tariffs against European partners without guarantees of direct military aid to Ukraine.

In the expert community, particularly among analysts at the Atlantic Council and CEPA, two basic scenarios have taken shape. Under the constructive scenario, the law will act as an external catalyst: U.S. hard deadlines and the threat of tariffs will force hesitant EU members to accelerate their exit from Russian resources, and European Commission President Ursula von der Leyen—who had previously welcomed coordination of measures with Washington—will use American pressure to overcome internal vetoes inside the bloc. Under the negative scenario, Trump’s harsh application of tariffs against European producers will provoke a large-scale retaliatory crisis, forcing Brussels to activate the EU Anti-Coercion Instrument and producing a full-scale transatlantic trade war, soaring prices for energy-intensive industries, and a weakening of European solidarity.

In the end, the Lindsey Graham Act shifts the center of decision-making on European energy security to Washington. Depending on whether the U.S. administration uses its tariff powers as a real economic hammer or as an ultimatum lever in diplomatic bargaining, Europe will either make a final push toward decarbonization and cutting off Russian resources—or find itself at the epicenter of a new global confrontation.