Law report No. GLW-3091 · filed October 10, 2026
LegislationReported case
Trump Signs Russian and Iran Sanctions Act Into Law
President Trump has signed the Russian and Iran Sanctions Act, locking new Russia- and Iran-related sanctions measures into binding US federal law and putting compliance teams on notice.
By Grace Kim3 min read624 words
Holding
- President Donald Trump signed the Russian and Iran Sanctions Act into law.
- The act combines Russia-related and Iran-related sanctions measures in a single statute.
- The signing converts previously proposed sanctions measures into enforceable US federal law.
- The signing was reported by legal analysis platform Lexology.
President Donald Trump has signed the Russian and Iran Sanctions Act, converting into binding federal law a package of new sanctions measures aimed at Russia and Iran. The signing, confirmed by legal analysis platform Lexology, hands the US Treasury and its sanctions-enforcement arms a fresh statutory mandate that transactional lawyers, export-control teams and financial-institutions counsel will need to absorb quickly.
What did the president actually sign?
The Russian and Iran Sanctions Act is a combined piece of legislation. As its name indicates, it targets two distinct sanctions programmes — the measures directed at the Russian Federation and those directed at Iran — within a single statute. By signing the act rather than vetoing it, the president has given the measures the full force of US federal law.
For practitioners, the immediate practical point is straightforward: measures that previously existed only as bills are now enforceable obligations. Compliance departments should treat the date of signature as the operative trigger for reviewing client exposure, screening protocols and contract representations.
What does the new act change?
Because the act consolidates Russia- and Iran-related sanctions authority in one statute, it signals congressional intent to lock sanctions policy into legislation rather than leave it entirely to executive discretion. That structural choice matters for clients in three ways:
- Durability. Statutory sanctions are harder to unwind by executive action alone, which affects long-dated contracts and investment planning.
- Enforcement exposure. Violations of statutory sanctions regimes carry civil and criminal consequences, so screening obligations tighten immediately.
- Deal diligence. Transaction counsel should re-run sanctions representations, warranties and closing conditions against the new act's requirements.
Lawyers advising banks, exporters, energy companies and fund managers with Russia or Iran exposure should now map their client portfolios against the act's provisions and brief boards on the updated risk profile.
Who must pay attention?
The reach of US sanctions law extends well beyond US-domiciled entities. Secondary sanctions provisions — a hallmark of both the Russia and Iran programmes in prior legislation — can expose non-US persons and foreign financial institutions to penalties and loss of access to the US financial system.
That means the audience for this development is global:
- Non-US banks processing payments connected to sanctioned parties
- Multinationals with subsidiaries or supply chains touching Russian or Iranian counterparties
- Shipping, insurance and trade-finance providers
- Investors assessing representation and warranty insurance in affected deals
How should compliance teams respond?
Specialists at Lexology, which reported the signing, frame the act as a significant addition to the existing sanctions architecture. Practical first steps for affected organisations include:
- Updating watchlists and screening logic to reflect the new statutory measures
- Reviewing existing licences, general licences and exemptions for continued validity
- Re-papering sanctions clauses in loans, purchase agreements and distribution contracts
- Escalating Russia- and Iran-linked counterparty reviews to senior compliance sign-off
Counsel should also watch for implementing guidance. Statutes of this kind are typically operationalised through regulations, frequently issued by the Office of Foreign Assets Control (OFAC), which will supply the technical detail — definitions, thresholds and licensing procedures — that practitioners need for definitive advice.
What comes next?
Expect follow-on rulemaking, updated frequently-asked-question guidance and possibly designations of specific entities under the new authorities. Enforcement priorities under the act will become clearer as Treasury and other agencies allocate resources to it.
For now, the decisive fact is on the record: the president has signed, the act is law, and the compliance clock is running. Clients with any Russia- or Iran nexus should treat a legal review of the statute as an immediate priority rather than a scheduled item for the next periodic audit.
Global Law Wire will continue to track implementing regulations and enforcement actions under the act as they emerge.
via GN Lexology (Source)
More from Grace Kim
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Correspondent covering consumer brands and retail at Global Law Wire.
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