A Moscow reading of the "sanctions from hell": the new US law mostly codifies what already exists — Russian International Affairs Council (RIAC)

The Kremlin walls and Vodovzvodnaya Tower from the Moskva River embankment — The Moscow Kremlin from the Bolshoy Kamenny Bridge (June 2026)Photo: Юрий Д.К. / Wikimedia Commons · CC BY 4.0 · resized · Source

Institution: Russian International Affairs Council (RIAC)
Author: Ivan Timofeev
Country · language: Russia · English
Affiliation: Non-profit council co-founded by state

Summary

In his piece of 22 September, RIAC Director General Ivan Timofeev argues that the impact of the Russia law (H.R. 5334), adopted in the US after more than a year of debate and publicly dubbed the sanctions from hell, has been overstated. According to the author, the label would have been apt had the law been passed in early 2022. Examining its provisions one by one, Timofeev recalls that financial sanctions, restrictions on major banks and state companies, and bans on asset transfers, stock exchange listings and investment are already in force through presidential executive orders or earlier laws, and that the energy import ban was introduced in 2022 and the ban on Russian uranium in 2024.

The new elements the author identifies are limited: secondary sanctions on third-country financial messaging providers that facilitate sanctions evasion, customs duties of up to 500% on Russian goods, and secondary tariffs of up to 100% on countries buying Russian energy. Timofeev notes that US imports from Russia have fallen many times over since 2022, so very little volume remains for the 500% tariff to tax; as an example of a secondary tariff, he cites the duty imposed on India in 2025 and lifted in 2026. His conclusion: by anchoring executive-order-level restrictions in statute, the law makes them harder to lift, but it leaves future administrations broad discretion; if there is a will to normalise, it is not an insurmountable obstacle.

Blind spot

What the West misses: the West presents the law as a fresh blow to Russia; Moscow stresses that the Russian economy has priced in these restrictions for four years and that the real risk has shifted, via secondary tariffs, to buyers such as India. The weakness of this reading: it underestimates the law's codifying effect, which raises the political cost of future sanctions relief, and does not measure changes in third-country buyers' behaviour.

Talay assessment

Bottom line

Timofeev has a point on direct impact: US–Russia trade is already very small. But the law's main effect is aimed not at Russia but at third countries buying Russian oil. India's purchases of Russian crude falling to 1.9 million barrels a day in September indicate that the threat of secondary tariffs is affecting buyer behaviour even before the law is applied.

Likely effects

Russian oil exportsNegative1–6 months
The threat of secondary tariffs of up to 100% could lead major buyers such as India to reduce purchases of Russian crude and force Russia to sell at deeper discounts.
Türkiye's energy tradeNegative6 months+
The rule on secondary tariffs for countries buying Russian energy also stays on the table as a future risk item for Türkiye, which buys gas and petroleum products from Russia.
US–Russia normalisationNegative6 months+
Anchoring the restrictions in statute makes sanctions relief in any peace deal dependent on Congress, slowing the bargaining.

Possibilities, ranked

1
Selective enforcement55%
The administration uses the law's discretionary powers; secondary tariffs remain a threat and are applied only in a few targeted cases.
Watch: The first secondary tariff decision under the law by the US Treasury or USTR
2
Strict enforcement30%
A secondary tariff is imposed on a major economy buying Russian energy, and buyers rapidly cut their purchases.
Watch: An official secondary tariff notification targeting India or Türkiye
3
Suspension for normalisation15%
A ceasefire agreement in Ukraine leads to a partial suspension of sanctions under the law's discretionary provisions.
Watch: A US–Russia–Ukraine ceasefire text and a sanctions waiver notification submitted to Congress

Probabilities are calibrated judgement based on the sources, not measurement, and are revised as new information arrives. Not investment advice.

Original publication: russiancouncil.ru · 22 September 2026

This page summarises the institution's view and does not reflect the view of Talay Insight. No direct quotation is used.