The Russian news cycle continues to be dominated by reports of yet another US congressional bill imposing sanctions against Russia. This bill, introduced by the late Senator Lindsey Graham, was introduced in the Senate on April 1, 2025, and has periodically generated media attention. The primary focus was on the threat of tariffs of up to 500% on countries purchasing Russian oil and other raw materials. Following Senator Graham's death, the bill has resurfaced. Senator Darline Graham, Lindsey Graham's younger sister, has introduced a new version of the bill to the Senate. Its chances of passing can’t be entirely discounted, and analysing it is necessary for a proactive understanding of the potential risks. Let's take a step-by-step look.
Let's start by noting that not every sanctions bill becomes law. We're talking about a success rate of about 3-4%. Regarding Russia, China, Iran, and many other countries, such bills appear almost every day, but only a few become law. It's worth noting that a bill can wander from one version to another for years, only to disappear. Or it can slip into federal legislation as a separate part of a larger bill, such as the defence budget. Or it can be combined with other bills—a section on Iran or North Korea can easily be attached to a bill on Russia, as happened in 2017 with the well-known Countering America's Adversaries Through Sanctions Act (CAATSA). Sometimes a bill becomes law in the form in which it was introduced in one chamber. US federal legislation is constructed like Tetris or Lego. Various pieces and versions can be used.
What increases the chances of a bill passing? Among the factors is the presence of bipartisan consensus. This can be seen in the composition of the bill’s sponsors. The more sponsors, the greater the bill’s chances, especially if the sponsors are from both parties. However, this factor alone is hardly decisive. There are many bills with a large number of bipartisan sponsors. This hasn’t prevented them from being shelved. Presidential support is also unlikely to be decisive. Yes, he can veto it. But Congress will override it with a joint resolution. However, the approaches of the Administration and Congress often coincide, even if they publicly state otherwise. The aforementioned CAATSA law was positioned as a means of restraining Donald Trump in his relations with Moscow. But Donald Trump himself has never obstructed its implementation. Rather, one might speak of the US legislative process as self-organising chaos. Many bills undergo natural selection. Only a few survive, and in the most bizarre forms and against a backdrop of seemingly random factors. However, there’s a method behind the chaos and randomness. It’s impossible to accurately predict a project’s progress, but allowing individual parts or mechanisms to “resurface” in other projects requires serious consideration.
It's also important to note that federal (public) laws often leave the president quite broad discretion in their application. Moreover, the president has extensive powers in foreign policy, which he can implement without new legislation. For example, the very tariffs that have been so thoroughly discussed in connection with Lindsey Graham’s project and its subsequent revisions have long been imposed by Donald Trump based on his presidential authority. In 2025, he imposed tariffs on India for purchasing Russian oil without any legislative impetus from Congress. Presidential actions often outpace the rulemaking process in Congress. Furthermore, the president also has considerable discretion in implementing federal laws. He can go beyond them, or he can ignore them, sending Congress mere formal reports. Despite the growing importance of Congress in sanctions policy, the United States remains a presidential republic.
Let's return to Darline Graham's bill. It has a fairly large number of co-sponsors – 62 senators, including both Republicans and Democrats. Some of the sponsors have previously co-sponsored bills on sanctions against Russia. These include Senators Richard Blumenthal, James Lankford, Ted Cruz, Jeanne Shaheen, and others. US President Donald Trump has periodically expressed support for the bill, including suggesting that it include sanctions against Iran. No such revisions have been made yet. But technically, the issue is being resolved quickly. In its current form, Darline Graham's bill is quite detailed. It differs from many other sanctions bills, which are more chaotic. The level of preparation here is higher. Let's look at the main components.
Article 102 – financial and visa sanctions against senior Russian officials. Such sanctions have already been imposed by presidential decree. This section also includes sanctions against foreign entities supplying dual-use goods to Russia. The administration has been actively implementing them since the very beginning of the Special Military Operation. Sanctions against individuals undermining Ukraine's sovereignty and democracy have been imposed on a large scale since 2014 and especially since 2022. Sanctions against Russian ‘oligarchs’. The wording here, stating that one of the criteria for sanctions is a refusal to condemn the Russian authorities’ policies in Ukraine, is striking. However, in general, restrictions against Russian businessmen were imposed both before and after the start of the Special Military Operation based on presidential decrees. Sanctions against sea vessels transporting Russian oil, liquefied gas, uranium, coal, weapons, etc. have also been actively imposed by the Administration, including against shipowners. The EU and the UK have similar practices. Graham’s draft contains a provision stating that the imposition of sanctions by Brussels and London could in itself be grounds for their duplication in the United States.
Article 103. Sanctions against financial institutions associated with the Russian government. The US has imposed such sanctions for a long time. Moreover, both state-owned banks and numerous private banks are subject to sanctions. Article 104 also concerns sanctions against other state-owned companies. Again, the Trump Administration imposed such sanctions even before the Special Military Operation, and did so on a massive scale after it started. Article 105 also prohibits the transfer of funds associated with the Russian Federation. Such transfers are already virtually impossible due to the extensive blocking sanctions against the Russian financial sector. Article 106 also prohibits Russian state-owned companies from listing on US exchanges. However, they are already unable to do so, given that the vast majority of blue-chip companies, or entities associated with them, are subject to blocking sanctions. Article 107 also prohibits investment in Russia. Such bans were introduced by Joe Biden in March 2022. However, if enshrined in law, repealing such a ban would be more difficult.
Further components of the bill are also largely already reflected in the rulemaking and enforcement policies of both the Trump and Biden administrations. The ban on imports of Russian energy products (Article 108) was introduced by Biden in March 2022. The bill also proposes a ban on energy exports from the United States to Russia. However, Russia has no need for such goods from the United States. The ban on the purchase of Russian bonds (Article 109) was also introduced by Biden and the US Treasury Department at the beginning of the Special Military Operation.
Article 110 appears new. It establishes a sanctions mechanism for foreign providers of financial messaging services. It proposes blocking them if they provide services to persons subject to sanctions under Article 103. However, the largest provider (Belgian SWIFT) already avoids working with sanctioned Russian individuals. Furthermore, it is restricted by EU law, which explicitly prohibits the provision of such services to specified Russian banks (Article 5h of Council Regulation 833/2014). Chinese services are theoretically at risk. However, they are also exercising greater caution and are mindful of the legal risks posed by the United States.
Article 111 proposes a ban on the import of Russian uranium and sanctions against the management of Rosatom State Corporation. However, a similar legislative ban already exists in the form of the Prohibiting Russian Uranium Imports Act of May 13, 2024 (PL 118-62). The White House has already imposed sanctions on certain assets of the Russian nuclear industry, although the bill lays the groundwork for their escalation.
Article 112, which imposes 500% duties on imports from Russia, appears somewhat odd. It lists goods such as oil, gas, liquefied natural gas, coal, and others. However, their import into the US was banned by Joseph Biden in 2022. Furthermore, energy imports from Russia were halted by the Ending Importation of Russian Oil Act of April 8, 2022 (PL 117-109). This raises the question of how duties can be imposed on something that is prohibited from being supplied.
Article 113 expands on the well-known threat of tariffs on third countries for purchases of Russian oil or natural gas. This time, the tariff is capped at 100%. However, the criteria for imposing tariffs are more detailed. For example, they could be imposed on the five largest importers of Russian oil. This version of the draft could well cause concern among buyers of Russian oil. However, such tariffs and their elimination have been implemented before. Therefore, it's difficult to call this a new risk. Its legislative codification will not bring peace of mind to businesses. But it is no longer a black swan. Article 113 remains a key element of Senator Graham's draft.
The bill ties the lifting of sanctions to achieving peace in Ukraine. In this case, the president can lift sanctions previously imposed by law, but must justify this decision to Congress. Congress can then repeal the sanctions via a joint resolution. A similar mechanism was previously developed under CAATSA for sanctions imposed by Barack Obama's executive orders following the outbreak of the Ukrainian crisis in 2014.
Ultimately, the Trump Administration's main criticism of Senator Graham's bill will likely be its excessiveness, given that many of its provisions are either applied to or already contained in previously passed laws. This won't necessarily prevent its passage. The notorious Section 113 could simply resurface in other bills. Or the current draft could be supplemented with sanctions against Iran or other countries. The bill contains no ‘black swans’, but the risks it poses require unbiased analysis and attention.
