CAW reported on the morning of 20 October that the Federal Register still held no trace of the order signed on Friday 16 October. The document, numbered 2026-21599, was filed at 11:15 that day and printed on 21 October at 91 FR 66627 to 66630 under the title “Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026”, the law of 18 September that wrote 500% and 100% duties on Russia and its energy buyers into the statute book.
The rates come in section 2. Goods from Russia carry an additional 500% ad valorem. Goods from “the largest 5 importers of crude oil and natural gas that originated in the Russian Federation” carry an additional 100% “if the country knowingly makes new purchases of crude oil or natural gas that originated in the Russian Federation on or after October 18, 2026”. A third 100% falls on the top five facilitators of Russian oil sanctions evasion. All three sit on top of any other duty in force, from anti-dumping to section 232, and all three are “subject to the exceptions set forth in section 114 of the Graham Act and the waivers issued in section 4 of this order”.
Neither the five importers nor the five facilitators are named in the four pages. The order gives the job to the United States Trade Representative, who is to monitor imports and purchases of Russian oil and gas “in consultation with the Secretary of State, the Secretary of the Treasury, the Secretary of Energy”, inform the President regularly and recommend further action, and to “report to the President on which countries are among the top 5 such facilitators”. No deadline attaches to either report. By CAW’s count of 14 October Kazakhstan and Uzbekistan ranked fourth and fifth among the buyers of Russian pipeline gas, and Reuters on 18 October quoted analysts naming Kazakhstan beside India among the countries the duties could reach. The order’s test counts crude oil and natural gas together, so a gas ranking alone does not place a country among the five.
The waiver is section 4. Under section 115(a) of the act the President waives “any duties provided for in sections 112 and 113 of the Graham Act or this order” and records that a certification of national interest has gone to Congress. He waives the sanctions and restrictions of section 102(d), and the sanctions on foreign persons under sections 102(a), 102(e), 103 to 111 and 117, which cover the act’s banking and secondary measures. One carve-out runs the other way: nothing in the order touches the sanctions already in force under the Russia national emergency continued on 24 March 2026, “including with respect to all persons sanctioned under any such Executive Order”.
Neither the five importers nor the five facilitators are named in the four pages.
The waivers “shall remain in effect until such time as the President or the Secretary of State, in consultation with the Secretary of the Treasury and the Trade Representative, as appropriate, determine that further action is appropriate”. There is no date, no review period and no condition in the text. Trump’s words of 19 October outside the White House about reimposing the duties, “I have the right to do that at any time, immediately”, now have a mechanism behind them: the switch is a determination by the President or the Secretary of State, and the monitoring that would prompt it belongs to the Trade Representative under section 3.
Section 5 hands out the act’s powers. Determinations under section 113(a), the buyers’ duty, go to the Trade Representative with State, Treasury and Energy, the bank sanctions of section 103 to the Treasury with State, and the waiver power of section 115 to the Secretary of State with Treasury and the Trade Representative. A final clause, 5(b), extends the same delegations to any future law “the same or substantially the same” as the Graham act.
For the region the operative line is the date. The waiver suspends the duties and leaves the test standing: a country’s knowing new purchase of Russian crude or gas on or after 18 October is what the Trade Representative is told to watch, and the text sets no other date, so by its wording the purchases that would count once the waiver is lifted are those made from 18 October onward, waiver or no waiver. The act’s section 114 exceptions are carried over by reference and not spelled out, the order does not define where oil originates, and the Caspian Pipeline Consortium, Kazakhstan’s export route through Novorossiysk, appears nowhere in it, nor does any country.
On the same 21 October the Office of Foreign Assets Control issued Russia-related General License 131K, “Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities”, with amended FAQs 1224 and 1225. Interfax reported the same evening that the licence for the sale of Lukoil’s foreign assets had been extended to 21 November.
What the register holds is the rates, the waiver and the delegations. What it lacks is a list of five, a deadline for producing one and an end date for the waiver, and those three rest on three desks: the Trade Representative’s for the names, the President’s and the Secretary of State’s for the switch.