Russia Iran Sanctions Bill Targets China and India
One of the most important provisions allows the President to impose tariffs of up to 100% on goods imported into the United States from countries that are among the five largest importers of Russian crude oil or natural gas, or among the five countries helping Russia evade oil sanctions. China and India are specifically identified in the legislation’s broader tariff mechanism as countries that could face pressure because of their Russian energy purchases. The bill does not automatically impose a 100% tariff on either country. The relevant top-five lists would be reviewed every 180 days by the U.S. Trade Representative in consultation with the State and Energy Departments.
The legislation also allows duties of up to 500% on goods imported directly from Russia, including crude oil, natural gas, LNG, petroleum products, petrochemicals, coal and other Russian goods. New U.S. investment in Russia and certain U.S. services, financing and transactions involving Russia would be restricted. The bill also targets Russian government-affiliated financial institutions, state-owned companies, sovereign debt and securities of covered Russian government-affiliated issuers on U.S. national securities exchanges.
The measure requires the President to review and sanction senior Russian officials, including the Russian President, Prime Minister, Defense Minister, Foreign Minister, Finance, Energy, Transport, Industry and Agriculture ministers, the Chief of the General Staff, senior military commanders, intelligence chiefs and National Guard leadership. Foreign individuals and companies knowingly supporting Russia’s defense-industrial base can also face sanctions, including suppliers of CNC machinery, military-related software, propellant and munitions components, advanced sensors, fiber-optic technology and chemical coatings. The legislation also targets Russia’s energy sector, including oil, gas, uranium, coal and petroleum production.
The bill further targets Russia’s shadow fleet and the network supporting sanctions evasion. Potential targets include vessels, owners, operators, managers, insurers and reinsurers, captains and senior crew, ports, ship-to-ship transfers and companies transferring vessels to Russia. It also covers vessels involved in violating the Russian oil price-cap regime or evading the price cap established by the Price Cap Coalition or the United States. The measure also addresses Russian uranium and requires sanctions involving leaders, senior officials, executives, directors and controlling shareholders of Rosatom and its subsidiaries or successors.
Iran is a separate but important part of the legislation. The bill extends the Iran Sanctions Act of 1996 from 2026 to 2031, continuing restrictions on companies that invest in Iran’s energy sector. The legislation also includes a provision intended to prevent a lapse in sanctions authority restricting funding for Iran’s energy and weapons sectors. The Iran provision is separate from the broader Russia sanctions framework.
The bill includes humanitarian exemptions for food, agricultural commodities, medicine, medical devices and humanitarian assistance. Qualifying companies leaving Russia receive a 270-day wind-down period, while certain activities involving vessel safety, crew safety, protection of human life and avoiding environmental damage are exempted. The President can waive sanctions or tariffs after providing Congress with written certification that the waiver is in the U.S. national interest and a report explaining its basis.
The legislation also addresses immobilized Russian sovereign assets and protects certain loans to Ukraine serviced or repaid using proceeds from those assets. Russia-related sanctions generally require Russia to sign a peace agreement accepted by the free and independent government of Ukraine and cease military hostilities and activities aimed at overthrowing, dismantling or subverting the Ukrainian government. Congress would receive a review period and could challenge a termination through a joint resolution of disapproval. The Russia-related provisions generally sunset after five years, while the extension of the Iran Sanctions Act is specifically excluded from that sunset.
