Section 113 of the Graham Sanctioning Russia and Iran Act of 2026 could impose secondary tariffs of up to 100 percent on major purchasers of Russian energy and countries facilitating sanctions evasion. The new tariff authority requires mandatory imposition of tariffs but the President retains significant discretion and options to creates waivers and special exceptions.

By: Edward Steiner

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J. Nicole Bivens Collinson
Managing Principal, Operating Committee; International Trade & Government Relations Practice Leader
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