The Sanctioning Russia Act of 2025 (S.1241/H.R.2548) is currently under consideration in both the Senate and the House in response to Russia’s ongoing invasion of Ukraine. The Senate version, introduced on April 1, 2025, by Sens. Lindsey Graham (R-SC) and Richard Blumenthal (D-CT), has 80 bipartisan cosponsors, including 40 Democrats, 39 Republicans and 1 Independent, and has been referred to the Senate Committee on Banking, Housing and Urban Affairs. On the same date, the House version was introduced by Ukraine Caucus Co-Chairs Brian Fitzpatrick (R-PA), Mike Quigley (D-IL), Joe Wilson (R-SC) and Marcy Kaptur (D-OH), with 33 cosponsors and referred to the House Committee on Foreign Affairs for review. The bill proposes a comprehensive sanctions and tariff regime aimed at penalizing Russia for its military actions in Ukraine, including asset freezes, trade restrictions and secondary sanctions on foreign entities supporting Russia’s energy sector.
Overview of Legislation
The bill targets Russia’s financial institutions, state-owned entities and military apparatus, mandating asset freezes and transaction bans on senior Russian officials, military personnel, oligarchs and others supporting the military. It sanctions key banks like the Central Bank of Russia, Sberbank and Gazprombank, while prohibiting U.S. institutions from processing transactions with Russia and restricting Russian entities from listing securities on U.S. stock exchanges.
In addition, the bill bans U.S. exports of energy products to Russia and prohibits investments in Russian energy. It imposes secondary sanctions on foreign firms that support Russian energy production, including oil, gas and uranium sectors. Section 14 bans uranium imports from Russia or its affiliates and extends this ban to third countries involved in the trade.
In addition to these sanctions, the bill establishes significant trade restrictions, which have garnered significant attention from the media and potentially impacted nations. Section 15 imposes a 500% tariff on all Russian-origin goods and services, including energy products, which would be applied in addition to any existing tariffs. Section 17 extends secondary tariffs to countries that knowingly sell, supply, transfer or purchase Russian-origin oil, natural gas, uranium, petroleum products or petrochemicals, imposing a 500% ad valorem tariff on all goods and services imported into the United States from those countries.
The bill does provide for limited exemptions through national security waivers as determined by the president, though waivers are prohibited for state sponsors of terrorism. The bill mandates full enforcement of all applicable sanctions under the Countering America’s Adversaries Through Sanctions Act (CAATSA), reinforcing existing authorities and eliminating discretion over implementation. It also carves out exceptions for humanitarian assistance, authorized U.S. intelligence activities and obligations under international agreements such as the U.N. Headquarters Agreement and the Vienna Convention.
Implementation, Triggering and Reimposition Mechanisms
The measures would be triggered by a presidential determination that Russia has refused peace talks, violated agreements, initiated further military aggression or attempted to undermine Ukraine. This determination must occur within 15 days of the bill’s enactment and be reassessed every 90 days. Upon a determination, the president is required to implement the full range of sanctions outlined in the bill, including asset freezes, trade and investment restrictions and financial transaction prohibitions. Violations would carry civil and criminal penalties under the International Emergency Economic Powers Act (IEEPA). Sanctions may only be lifted if Russia verifiably ceases the specified activities and signs a peace agreement with Ukraine. Should Russia resume aggression, the sanctions would be immediately reimposed, along with any new measures authorized under the act.
Limited Waiver Authority for Tariff Relief on Russian Energy Trade
Of particular concern for businesses and foreign governments with commercial or energy ties to the Russian Federation are the secondary tariff provisions in Section 17, which impose a 500% duty on all imports into the United States from any country that continues to import Russian-origin energy products. The bill provides for a narrow national security waiver (Section 17(d)) that allows the president to exempt specific countries, goods or services from these tariffs if doing so is deemed in the U.S. national security interest. This waiver is limited in scope and may be granted only once per country, good or service, for a period not exceeding 180 days. However, the waiver applies only to tariffs under Section 17 and does not affect other provisions of the bill, such as restrictions on investment or access to the U.S. financial system.
Anticipated International Reactions
The proposed legislation is expected to draw mixed reactions from global stakeholders. While the European Union (EU) has moved in lockstep with the United States on sanctions against Russia since the start of the full-scale invasion, some member states, particularly Hungary and Slovakia, will likely raise concerns about the bill’s secondary sanctions on countries purchasing Russian energy. The EU is currently working on its 18th Russia-focused sanctions package and we expect it to include some complementary action while likely seeking exemptions for key industries. An even more cautious approach can be expected from Japan, given its Russian LNG imports. India would almost certainly argue that secondary sanctions for its purchase of Russian oil unfairly targets its economies and would further its efforts to develop an alternative payment mechanism to bypass U.S. financial restrictions.
Potential Compliance Considerations
The bill introduces significant compliance considerations for those with international exposure and for financial institutions. Foreign businesses that engage with Russian financial institutions risk being cut off from the U.S. financial system due to secondary sanctions, and companies would have to conduct enhanced due diligence to ensure compliance. Supply chain risk should also be considered; businesses reliant on Russian-origin extractives, including oil, gas and uranium, should reassess their sourcing to avoid penalties under Section 17’s 500% tariff provisions. Finally, the draft bill mandates enforcement of existing relevant sanctions provisions under CAATSA, the implementation of which are currently discretionary. Companies must therefore prepare for rapid regulatory shifts and potential enforcement actions of these and other aspects of the bill.
Congressional Dynamics
The Sanctioning Russia Act of 2025 is currently in committee in both the Senate and the House, with potential amendments or votes to advance. Should the committees fail to act, legislators can file a discharge petition in the House or request unanimous consent in the Senate to bypass obstruction. If favorably reported, the bill will proceed to floor debates and votes. Given its broad bipartisan support in the Senate, it is expected to pass the 60-vote filibuster threshold, though the House version faces more challenges due to fewer cosponsors.
Sen. Graham indicated on May 30, 2025, that the Senate would likely begin moving on the bill next week due to the lack of progress in Ukraine’s peace talks. He noted that there is growing momentum for action in the House, with members ready to move forward on the bill even without President Trump’s explicit endorsement. On June 2, Senate Majority Leader John Thune (R-SD) acknowledged the pressure to act, stating that the bill “very well could be something that we would take up in this work period,” although he did not provide a specific timeline. Speaker Mike Johnson (R-LA) also signaled support for the effort on June 2, contending that there are “many members of Congress that want us to sanction Russia as strongly as we can. And I’m an advocate of that.”
However, the bill’s path is complicated by President Trump’s stance on Russia. While expressing frustration with Putin after the May 25 drone attack, Trump has signaled he may delay new sanctions to use the threat of sanctions as leverage in peace talks. On May 28, Trump stated he would clarify his position in about two weeks, suggesting the bill’s progress is unlikely before this period. During this time, Trump will assess the situation and gauge whether Putin is serious about negotiating a ceasefire. Should hostilities in Ukraine escalate or if there are signs that Putin is unwilling to negotiate in good faith, congressional pressure to advance the legislation will likely intensify. After the two-week period, if there is no meaningful movement toward peace, the Senate is expected to face mounting pressure to begin moving the bill forward, as lawmakers seek to demonstrate resolve in the face of Russia’s aggression.
The Senate is unlikely to take up the bill for consideration until after the reconciliation package is completed. The procedural reconciliation process will allow President Trump to have his “two weeks” to determine whether Putin is actually moving toward some cessation of hostilities in Ukraine. However, this timing is secondary to the broader dynamics surrounding Trump’s decision and congressional momentum. Should the “two weeks,” which may ultimately be stretched longer due to Trump’s desire to allow for Putin to signal some steps toward a deal, go unheeded, President Trump may allow the Senate to start moving the bill forward to demonstrate to Putin that the United States will not allow him to delay. The House could be expected to follow suit, although support there remains uncertain due to the smaller number of cosponsors. Ultimately, while bipartisan support exists, the bill currently serves more as a signaling tool for leverage for President Trump rather than a catalyst for immediate sanctions from Congress. To date, President Trump has not indicated publicly his stance on the bill; we expect he will push House and Senate Republicans to give him time to negotiate with Putin. That said, the mood in Congress is increasingly wary of Putin’s intentions, and Trump may have a bipartisan fight on his hands with regard to this bill. The 500% sanctions on Russian goods and services, as well as potential tariffs of the same rate on other imports, could significantly impact U.S. consumers and partners, further underscoring that the bill may align more with broader messaging on Russia than substantive action.
Next Steps
Brownstein’s international practice is closely monitoring the Sanctioning Russia Act of 2025 and its potential impact on businesses and foreign entities. Should the bill progress, Brownstein is available to assist clients in engaging congressional leaders on potential amendments or with administration officials regarding necessary exemptions. Our team, including Samantha Carl-Yoder, Lauren Diekman and Tom Wotka, is well-positioned to provide strategic guidance on navigating the complexities of this legislation and its implications for clients. Brownstein will continue to monitor developments related to the bill and existing sanctions, offering support to clients seeking to understand or respond to these evolving legal and regulatory challenges.
