White House Waives New Russia Sanctions Under Graham Act

The Trump administration has waived the new Russia sanctions and tariffs created under the Graham Act, according to a report carried by Lexology. The move suspends the latest round of coercive economic measures aimed at Moscow. It does not repeal the underlying statute.

What is the Graham Act?

The Graham Act is the sanctions legislation associated with Senator Lindsey Graham, the South Carolina Republican who has pushed for years to impose steep economic costs on Russia. The law works through two classic Washington levers: sanctions (restrictions on dealings with designated persons) and tariffs (taxes on imported goods).

Sanctions of this type typically operate by designating entities or individuals, freezing them out of US dollar transactions, and exposing third parties to secondary sanctions (penalties on foreign banks or firms that keep doing business with the target). Tariffs work differently. They raise the price of specific imports at the border.

The Graham framework paired both tools. That combination is the mechanism now sitting on hold.

What did the administration actually decide?

The administration invoked a waiver. A waiver is a formal decision by the executive branch not to apply a legal requirement — here, the new sanctions and tariff measures — to specified persons or transactions.

Three points matter for practitioners.

• The waiver covers the new measures. It targets the freshly adopted Russia sanctions and tariffs, not necessarily the entire existing sanctions architecture.
• A waiver is discretionary. It can be narrowed, expanded or revoked. It does not amend the statute.
• The statutory framework remains on the books. Congress passed it. The executive has chosen, for now, not to use part of it.

Think of it like a speed limit that stays on the map while the police stand down enforcement on one stretch of road. The law is intact. The application has paused.

What does the waiver change in practice?

For compliance teams, the immediate question is scope. Firms that had begun adjusting contracts, screening protocols or supply chains to prepare for the new measures now face a moving target. The practical consequence: due diligence programs built around the Graham Act's new provisions cannot be dismantled, because a future administration decision — or congressional pressure — could restore them at any time.

Counsel advising exporters, banks and multinationals should treat the waiver as a compliance variable, not a compliance holiday. Screening lists may not grow as expected. But existing Russia-related restrictions from other authorities — the long-standing sanctions programmes administered by the Treasury Department's Office of Foreign Assets Control (OFAC, the US agency that enforces economic sanctions) — remain fully in force. The waiver addresses one recent layer, not the whole structure.

There is also a political dimension worth flagging for clients. The Graham legislation was designed as leverage. Waiving its newest measures signals a choice about negotiation posture toward Moscow. Practitioners tracking sanctions risk should therefore monitor not just the Federal Register and OFAC notices, but the congressional response. Lawmakers who authored the act may contest the waiver, seek to tighten its terms, or attach conditions to future legislation.

Why does the timing matter?

Sanctions waivers sit at the intersection of two powers. Congress writes the statute. The executive decides how hard to swing it. When the two branches disagree, the waiver becomes the fault line.

That is the dynamic to watch here. The waiver preserves the administration's flexibility while keeping the statutory threat in reserve — the diplomatic equivalent of keeping the tariff schedule in a drawer rather than tearing it up. If negotiations with Moscow shift, the drawer can be reopened.

For now, the new measures are suspended. The law is not. Clients with Russia exposure should assume the measures could return, and should keep the compliance infrastructure they built to meet them.

By Sophie Lindqvist