The notice on the White House site says that on Friday 18 September 2026 the president signed H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, “which authorizes and expands statutory sanctions, tariffs, and prohibitions on Russia and extends existing sanctions on Iran.” No signing statement came with it. RFE/RL noted on Saturday that the signature came without a public statement.
The dates now follow from the text. Section 113 says the president “shall”, within 30 days of enactment, raise duties to as much as 100% on all goods from any country that was among the 5 largest importers of Russian crude oil or natural gas in the 12 months before enactment and that goes on buying from day 30. Day 30 is Sunday 18 October.
A written justification with the methodology has to reach 6 congressional committees at least 10 days before any duty is imposed: by Thursday 8 October if the duties arrive on the last permitted day. It will be the first document to show how the US Trade Representative counts.
One ranking for oil and gas together or one for each, tonnes or cubic metres, whose statistics: the law leaves all 3 open.
The count matters in Astana and Tashkent because of what has happened to their own gas. Kazakhstan's vice minister of energy, Kaiyrkhan Tutkyshbayev, said in Tyumen on 16 September that purchases from Gazprom rise from about 4 billion cubic metres last year to 11 billion this year. The IEA expects Uzbekistan to import just over 10 billion in 2026.
On CAW's count of the 12-month window, published on 18 September, each lands near 9 billion cubic metres: behind China, Turkey and Belarus, and ahead of France, Hungary and Japan by less than 1 billion.
Tokyo has already read itself out. Kyodo reported on Saturday, in a dispatch carried by Russian outlets including Vzglyad, that Japan expects to avoid the duties because the law exempts countries that are working to cut their purchases and take less than 15% of the resource from Russia. Japan buys about 10% of its LNG from Russia, Kyodo said, and the Sakhalin-2 project supplies about 3% of its electricity.
The exemption in the text is narrower than that reading. Section 113(d) measures a buyer's gas against 15% of Russia's total gas exports, and it sets a second condition beside the first: “significant steps to reduce” those imports, a phrase the law does not define. Kazakhstan and Uzbekistan meet the first condition, at about 7% of Russia's exports each on CAW's estimate. On their own officials' numbers they miss the second, because their imports rise as their output falls. The exemption Tokyo is counting on is one that Astana and Tashkent can only half use.
The second clock is for banks. Section 103 obliges the president, inside the same 30 days, to sanction any foreign financial institution that conducts significant transactions with Sberbank, VTB, Gazprombank or any other Russian state-owned bank, unless the Treasury secretary finds that doing so is against US interests. The list is updated within 210 days, by 16 April 2027, and every 180 days after that.
QazaqGaz pays Gazprom monthly, in roubles, under a contract signed in June. Which banks carry those payments, and Uzbekneftegaz's, has never been published.
The exemption Tokyo is counting on is one that Astana and Tashkent can only half use.
Moscow's answer was brief. RIA Novosti on Saturday quoted Dmitry Peskov, the Kremlin's spokesman, as saying of the law's effect on a settlement in Ukraine that it “definitely cannot have a positive influence”. No official comment from Astana or Tashkent had surfaced in Kazakh or Uzbek media by Monday morning.
Kazakhstan keeps one shield and carries the larger bill. Section 114(g) leaves oil of non-Russian origin that crosses Russia, and the companies that carry it, outside the law, which covers the CPC pipeline. A duty would fall on goods sold to the United States: about $95 million a month from Kazakhstan on this year's US Census figures, about $7 million a month from Uzbekistan.
The exits are written into the law too: a lower rate after a written finding of “significant steps”, a presidential waiver certified to Congress, a termination that Congress can block. Each is a negotiation. Its first date is 8 October at the latest.