Jeremy Paner Analyzes the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026
The bill codifies existing Russia sanctions and targets Russia’s shadow fleet.
Highlights
The legislation codifies existing Russia sanctions into law.
Paner discussed provisions aimed at Russia-linked shadow fleet vessels and questioned the practical impact of the bill's “prima facie evidence” standard.
He noted that the sanctions authorities are duplicative of existing law but highlight upcoming targeting prioritization.
Speaking to Energy Intelligence, Jeremy Paner analyzed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, which recently passed the U.S. Senate with a likely House vote in September.
The bill includes provisions that would codify sanctions designations issued by executive order into law and mandate sanctions on Russia-linked tankers and entities transporting Russian oil and products outside the Western price cap regime.
Paner addressed a provision allowing the United States to use sanctions imposed by the EU, UK and other allied jurisdictions as “prima facie evidence” to impose sanctions on a Russian vessel.
“I don't read anything into the prima facie other than the drafters trying to cajole Ofac [the Office of Foreign Assets Control] into at least catching up to what the EU and UK have done,” he said.
He also discussed the bill's sanctions designation criteria, noting those generally mirror existing authorities available to the U.S. government.
“There's nothing in the bill that would give the US Treasury’s Office of Foreign Assets Control or the State Department authority to impose sanctions that the existing executive orders and laws wouldn't already give them,” Paner said. However, he said that the bill does spell out in greater detail specifics around the shadow fleet and other sectors of concern — so in effect, amounts to Congress signaling to entities engaged in certain activities that they can eventually “expect a knock on the door.”
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