The Graham Act names no ship and no person. Its 30-day clock runs out on 18 October

The Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 became law on 18 September (Public Law 119-111). Most of its Russia provisions start, or fall due, 30 days later: Sunday 18 October 2026. The Act says nothing about what a Sunday does to the deadline. We read the enrolled text, H.R. 5334, to find out what it does to a screening file.

There is less in it for a screening team than the headlines suggest. As targets it names five institutions: the Bank of Russia, Sberbank, VTB Bank, Gazprombank and Rosatom. It names four energy projects, Yamal LNG and Arctic LNG 1, 2 and 3, whose leaders and controlling shareholders become sanctionable. It names 24 government offices and bodies, from the President of Russia to the Federal Guard Service, and not one person who holds them. It names no ship. Section 102(d) keeps every existing Executive Order 14024 designation in place, so nothing comes off a list either.

The 24 offices are the nearest thing to a list. Whoever holds one on review day is described by the text. The rest is instructions to the President and Treasury, with a clock attached, and the names will be in whatever OFAC publishes.

Sections 112 and 113 are customs law. Section 112 tells the President to raise duties on all goods from Russia to a rate of up to 500 percent. Section 113 does the same, up to 100 percent, for goods from a covered country. A country is covered if it was a top-five importer of Russian crude oil or gas in the 12 months before enactment and buys again on or after 18 October, or if it is one of the top five facilitators of Russian oil sanctions evasion.

The Act names no such country. The duty falls on a country's goods, so there is no entry to match a customer against. If your firm ships to the United States, that question belongs to the people who file customs entries.

Sections 103 and 105 are where an EU or Polish institution can be affected.

The first detail is ownership. The President must impose every sanction in section 103(d) on Sberbank, VTB Bank, Gazprombank and "any other financial institution organized under the laws of the Russian Federation and owned in whole or in part by the Government of the Russian Federation". The Bank of Russia gets two or more of them. There is no 50 percent threshold in that wording. OFAC's 50 percent rule blocks a company when blocked parties own half or more; section 103 reaches a bank with any state stake.

The second is "significant". The Act also orders sanctions on any foreign financial institution that engages in significant transactions with Sberbank, VTB Bank, Gazprombank, another state-owned Russian bank or their subsidiaries. Dealings with the Bank of Russia are not in that trigger: clause (vi) points at clauses (i) to (v), and the central bank sits elsewhere. Section 101 has 11 numbered definitions, and "significant" is not among them. Section 103(c) says the President need not act if Treasury finds it inconsistent with US economic or foreign policy interests. The threshold, and who gets the exception, are left to Treasury.

The third is section 105. From 18 October a US depository institution or SEC-registered broker or dealer may not process transfers to or from the Russian government, including entities it owns, or for the direct or indirect benefit of its officials. The exception is a transfer that arises from a licensed transaction. Section 107(3) adds that a US person may not approve, finance, facilitate or guarantee a foreign person's transaction that the US person could not do itself. A bank outside the United States is not bound by those sentences, but its dollar payments pass through banks that are. The Act does not say correspondents will ask respondents anything new. We would expect the questions to start there.

Section 102 tells the President to identify as blocked property any foreign vessel used by the Russian government or Russian persons to move oil, gas, coal, uranium, arms or other goods in order to evade sanctions. It also reaches the people around the ship: owner, operator, manager, insurer, captain and senior crew, and the owner or operator of a foreign port that lets a sanctioned vessel dock.

Paragraph (b)(5) goes further and is easy to miss. It covers any foreign vessel the President determines knowingly carries Russian-origin crude, products, LNG, coal or uranium at all. It also covers any vessel that does a ship-to-ship transfer of such cargo with a US-sanctioned vessel, and any vessel that services either. There is no evasion element in that paragraph. A tanker lifting Russian crude under the price cap is inside its words; whether it is listed is the President's call.

Section 102(c) deals with ships other governments have already listed. A listing by the United Kingdom, the European Union, the G7 or a Five Eyes member is something the President "may use as prima facie evidence" that the vessel evades sanctions. An EU listing is not a US listing, but it is now written into US law as grounds for one. A vessel on the EU list that appears in your trade finance or chartering files is a likely next candidate. It is not a blocked one.

Section 114(h) says the Russia title does not apply to a US person operating under a general licence issued before enactment, and that nothing in it affects Treasury's power to extend or issue new general licences. Section 105(b) does the same for funds transfers backed by a specific or general licence.

Read it for the date. Paul Weiss reported on 29 September that OFAC had not said how the Act's wider prohibitions, such as the sovereign-debt ban, fit with its regulations. The only Russia licence on the first page of OFAC's Recent Actions, 10 entries from 23 September to 8 October, is General Licence 13S of 8 October. By its title, it authorises certain administrative transactions prohibited by Directive 4 under Executive Order 14024. It was issued after enactment, so section 114(h)'s carve-out for earlier licences does not reach it by its own words; section 105(b), which covers any licence, can. OFAC's notice for that day does not mention the Act.

Section 114(i) adds a 270-day wind-down period from enactment, to mid-June 2027, for divesting from Russia. It covers an entity in Russia that is not Russian-owned, and a US-owned one acting in good faith.

1. Do not diary 18 October as the day the lists change. The Act sets a deadline for the President's reviews, not a publication date. Re-screen on each day OFAC posts a Russia action, from now on, and store the list version with the result.
2. Add the vessel to the file, not just its owner, and flag every EU- or UK-listed ship you hold. Record the name and IMO number against each charterer, trader or financed party. Section 102(c) makes those ships the likeliest US candidates, and the Act gives no identifier, so the match will come from OFAC's entry.
3. Capture state ownership of Russian banks and counterparties at any size. Section 103 speaks of bank ownership "in whole or in part"; section 105 of "any entity owned by the Government" and of its "officials". The Act defines none of those.
4. Tag counterparties connected to Yamal LNG or Arctic LNG 1, 2 and 3. Their leaders, officers, board members and controlling shareholders are a named class under section 102(b)(2)(H), which also covers successor projects and Arctic projects started after enactment.
5. List the general licences your Russia exposure relies on, with the date each was issued and its expiry. Any issued after 18 September needs a second look, because section 114(h) speaks of licences issued before enactment.
6. Leave the tariffs to the customs desk. Tell them the first section 113 country list is the President's determination, and that the US Trade Representative takes over the 180-day updates.

Once OFAC publishes names, the work is a re-screen of the counterparty file against the new list version, by batch screening for a whole file or through the developer API inside onboarding. We have checked nothing under this Act against our data, because nothing has been published.

This is a reading of the enrolled text of H.R. 5334 and of the slip law (Public Law 119-111), both as published by the Government Publishing Office. It also draws on the first page of OFAC's Recent Actions, 23 September to 8 October, and on one law-firm alert for the state of OFAC guidance on 29 September. It is not legal advice and takes no position on the merits of the Act.

We read Division A. We did not read Division B, which concerns a tax deduction for early-childhood educators. Of the USEC Privatization Act we read only subsection (d) of section 3112A, for the date in section 111. We do not know which countries the President will name under section 113, or whether the written justification that section requires 10 days before a duty has gone to Congress. And we do not know whether any person or vessel will be listed on 18 October: the Act sets a deadline for reviews, not for results.