Lindsey O. Graham Sanctioning Russia and Iran Act of 2026

Date issued: Sep. 18 2026

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TURBOFAC Commentary (1993 words)

Notes: 

(I)                Notable Procedural Provisions  

 

Because they influence the scope and operation of most of the discrete provisions described below, we begin with provisions concerning exemptions, licensing and termination.

 

·        Sec. 114(a) - Exceptions/Exemptions – section 114(a) provides that none of the sanctions authorities or prohibitions apply to “the conduct or facilitation of a transaction for the provision of agricultural commodities, food, medicine, medical devices, humanitarian assistance, or for humanitarian purposes,” or any related transactions. IEEPA exemptions for travel and informational materials also apply through section 116(h) “[t]he President may exercise all authorities provided under sections 203 and 205 of [IEEPA] to carry out [the substantive sanctions provisions of the SRA].”

 

·        Sec. 114(b) - Wind Down / Divestment – section 114(b) provides...