Ecaterina MATOI*
1. Introducere
The “Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026” Executive Order (White House, 2026) -signed by US President Donald Trump on October 16, 2026, just two days before the legislative sanctions were set to take effect – provoked strong reactions from the Ukrainian government, allied countries, and American politicians.
Especially since President Trump signed the Law, the bipartisan consensus on imposing direct and secondary sanctions was expected to be implemented by the US Government. Although mass media employed different terms to assess outcomes of the Executive Order, such as “Exempting Russia From Sanctions Law” (Rappeport, 2026), it actually waived the set of envisioned sanctions until further action is considered by the administration, without repealing the Law or pausing the legally-imposed surveillance of developments.
This analysis will assess the context of the Law and mentioned Executive Order, the waiving of its otherwise consequential sanctions, alongside potential causes and outcomes. The analytical framework selected is structural realism (Mearsheimer, 2013), although in its power pursuit, the US is attempting to impose a renewed cooperation paradigm that would in theory contribute to an envisioned reformed international institutionalism. Furthermore, while attempting to maintain a US-led global order in the classical sense, i.e. at least with respect to the control of oil and gas global supply, the US is also attempting to build competitive computing and renewable energy sectors and thus redefine hegemony for the future. From this perspective, the limits of structural realism are becoming more apparent in the context of attempts to restructure global institutionalism, that add new variables to great power competition, such as multipolarity, that aim to redefine alliances based on new cooperation paradigms.
2. Conceptual framework contextualization
In the transformation determined by the recent industrial revolutions, particularly energy and Artificial Intelligence (AI), the US remains a strong competing power but the context of competition is undergoing historical transformations. Although Washington’s stances under President Trump are often assessed as controversial by traditional allies, such as European powers, a preliminary analysis hints that the US does not necessarily oppose historical transformation, but attempts to manage it to its interests, based on a self-determined level of anarchy at global level that cannot be imposed to post-World War II (WWII) as a baseline as easy as it was in the past. Thus, in the dynamics of 21st century’s global power projection, a qualitative assessment of US effort to control energy flows can reveal a continuation of past tendencies, but this can be compared to European powers’ tendency to periodically attempt to gain influence in former or current Russian territories, a goal underscored by repeated wars: the Polish-Lithuanian invasion of the Tsardom of Russia at the beginning of 17th century. Swedish invasion of Russian territories at the beginning of 18th century, the French invasion of Russia in early 19th century and the two World Wars (Austrian-Hungarian and subsequently Nazi Germany’s incursions).
Consequently, the major spat apparently emerging between European powers and the US under President Trump entails diverging visions on what historical transformations should prioritize: energy hegemony and inclusion of Russian supplies in the short term, as the US improves its finances as a major competitor in the oil and gas markets and growing hegemon through gradual imposition of control over large sources (Venezuela, Iran, and potentially Saudi Arabia in case the conflict expands), and as a major adopter of renewable energy, or Europe’s energy-saving strategy combined with an envisioned more abrupt interruption of Russian oil and gas (European Commission, 2026). Should President Trump’s policies be equated with US medium-term strategy (in case November 2026 elections allowed him the existing flexibility to act), and the difference in approach to global affairs between European and American governments persists, the two blocs may continue to approach history in apparently different manners.
This analysis hypothesizes that there are at least three components requiring review when assessing the Law and the Executive Order: the implied political consensus between US major political parties and between European pro-war (with the Russian Federation) alliance, visions on timeline of energy supply transformation, and the asynchronous, i.e. anarchic, race to capitalize on AI industrial gains.
3. The US recent law on sanctioning Russia and immediate waivers
The “Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026” Executive Order (White House, 2026) introduced initially in the Senate by Lindsey Graham and Richard Blumenthal emerged as a highly popular initiative, supported by a “supermajority”, that President Trump appeared to accept especially in the context of India’s large oil purchases from the Russian Federation.
The provisions on Iran and other topics are very brief when compared to the space allocated to the expansion of sanctions on the Russian Federation. Section 111 provides for the prohibition of importing uranium from the Russian Federation, although the previous 2024 “H.R. 1042 – Prohibiting Russian Uranium Imports Act” governs this field. The most consequential sections are 112 and 113. In Section 112, the Law stipulates that rates of duty (tariffs) up to 500% ad valorem can be imposed on Russian goods imported into the US, including oil, gas and coal among others.
In Section 113, secondary sanctions, i.e. extraterritorial, are to be imposed on countries that either were top 5 largest importers of Russian oil and gas in the recent 12 months, facilitated Russian oil exports and evasion of oil sanctions in the recent 12 months, or “knowingly made new purchases of crude oil and natural gas that originated from the Russian Federation” (Section 113(c)(1)(A) after the enactment of the law. The two exceptions identified in the Law were countries that imported less than 15 % of Russian total 12-months natural gas exports (not oil), and the countries that have taken significant steps to reduce imports of Russian natural gas. The sanctions would include 100 % tariffs on the goods exported to the US, in yet another American push to control global trade through national legislation and the Dollar system.
The definitions from H.R. 5334 / 2026 are formulated in general terms, but it targets very precise countries. Firstly, China and India are, alongside Russia`s BRICS partners, the largest customers of Russian oil and gas. Türkiye has also emerged as a key customer for both refined and non-refined oil, alongside Brazil, the EU, and global importers such as Japan, Singapore, Egypt, and Saudi Arabia (CREA, 2026). While the French President Emmanuel Macron – alongside other European leaders – reportedly criticizes President Trump’s Russian diesel deal (Farnham, 2026), the EU reportedly increased its imports of Russian Arctic LNG by 9.5% year-on-year for the period spanning January to September 2026. In September alone, France doubled its purchases of Russian LNG to EUR 446 million (in comparison to previous months) and the Netherlands imported EUR 116 million worth of the same commodity
(Quillen, 2026).
While European imports can be assessed as temporary and seasonal, particularly in the context of a rushed decoupling from Russian LNG as early as 2027 if no further exceptions are invoked, Chinese, Indian, Turkish and Saudi imports of Russian oil, products and gas, are connected to potentially longer economicdevelopments and strategic interests (such as the OPEC-US competition in oil markets), that might have been affected by the “H.R. 5334 – Lindsey O. Graham Sanctioning Russia and Iran Act of 2026”.
The effects of this law on global energy trade are not assessed in detail in this section due to at least two reasons: first the sanctions therein were waived by President Trump for an unknown period; second, the reach of these provisions is so encompassing that it requires a separate study. It is worth noting, however, that should the US decide to implement these provisions, it could result 100 % import tariffs on countries that continue importing Russian fossil fuels, whether on a short-term basis or systematically. Moreover, the Russian Federation has not attempted to begin producing electricity and sell it to European and other neighbors, as it is not as explicitly sanctioned as the hydrocarbon exports, confirming the political basis rather than the technical one within the larger confrontation.
Two days before the start of Law’s application, “Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026” Executive Order (White House, 2026) waived the potential sanctions until “…the President or the Secretary of State, in consultation with the Secretary of the Treasury and the Trade Representative, as appropriate, determine that further action is appropriate” in Section 4(d). The interpretation of this order as avoiding 100% tariffs and thus beneficial for countries such as China and India relies on the static assumption that the US market and the dollar ensure an exclusive advantage, and while this can be assessed as a representative evaluation, the global economic diversification efforts must also be taken into account. Likewise, while China reportedly rejected the legal basis for such legislation at international level (Stezhensky, 2026), the potential effect of such sanctions on US economy requires additional considerations, as Washington appears to remain dependent on imports, either from the EU or China (Wagner & Murray, 2025) (Tong, 2026).
President Trump reportedly provided the US Senate with a written certification on the national interest in the decision to temporarily waive the sanctions. Assuming that such a basis exists at least in part if not in full, the following sections add political, environmental and technology-related context to the decision.
4. Political consensus on the Lindsey Graham Russia sanctions law
While the reported consensus within the US Senate was overwhelming, as the initial law was supported by both the Republicans and Democrats, the reasons might have been different. The assumption that President Trump’s administration aims both the expansion and protection of its oil and gas market share, against competitors such as the Russian Federation and OPEC+, the law would have made sense for his policy goals as well. Likewise, cutting direct and cheaper supplies to the EU and China would have provided the US with the competitive advantage of domestic cheaper energy for manufacturing and other energy-intensive industries. However, the unclear elections perspective, amid, for example, allegations of business and electoral campaign donations from Konstantin Sokolov, a magnate with Armenia holdings and business history in the Russian Federation (Landay, Ulmer, & Tsvetkova, 2026), clearly distinguishes between potential common goals and diverging policy directions among republican and democrat camps, and President Trump and the Senate as an institution.
The perspective of Chinese and Indian imports of Russian energy is certainly not a policy priority for the Trump administration, as reflected by the effort to realign Venezuela, Iran and the relatively weak reaction when Saudi Arabia’s oil infrastructure came under threat. Furthermore, the October 2026-announced large-scale exploration for Greenland’s oil and natural gas reserves (Rasmussen, 2026) supports the hypothesis of US attempting to expand its market share in the large commodity markets at global level. Thus, the temporary release of Russian diesel on global and US markets is certainly correlated with other considerations, such as the war against Iran or growing energy demand in the US. This underlines a higher-priority set of objectives when assessing the importance of sanctions on Russian energy at the White House.
Assessing President Trump’s approval as political alignment with European leaders, due to the initial support for the Lindsey Graham Russia sanctions law is likewise challenging. While the US appears to be a major receiver of Ukrainian payments and concessions in various sectors (e.g. Ukraine’s agricultural sector), the consensus is affected by various disputes. One day before publishing the Executive Order on waiving sanctions on Russian oil and gas, reports hinted that the US might have requested European leaders to transfer frozen Russian assets to a US-controlled fund (Trading View, 2026). The potential disagreement confirms not only the prevalence of much higher stakes in the US-European cooperation, as emphasized by US tariffs, request to increase defense spending, among others, but Washington’s determination to pursue strict national policy goals as well.
The interaction between the Russian diesel deal and the war against Iran cannot be overlooked. Besides the release of funds and political pressure with the acquisition of Russian fuel, should this be delivered as projected, the US gains flexibility in pressuring Iran into tougher deals, or in continuing armed attacks. Although the concept of post-elections continuation of confronting Iran has been floated, the continuation of this war may depend on the polls or the agreement with the Israeli Prime Minister Benjamin Netanyahu, himself expecting a ballot test. The maintenance of a credible military threat, as instantiated by US War Secretary Pete Hegseth’s statements from October 17th, 2026 (Gokmen, 2026), the day immediately after the Executive Order’s publication, reflects the increased flexibility in pursuing war on Iran, that especially in the case of weak election forecasts, may represent a basis for quick executive action. Furthermore, the policy shift deters potential buyers from acquiring Iranian sanctioned oil and gas, as the Russian commodities come with a lower risk.
Consequently, the analyzed Executive Order does not represent a major shift in political consensus within the US or with Europe, but the continued reflection of a more pronounced nationalist policy that appears to require, according to President Trump’s administration, short-term arrangements such as the Russian diesel agreement in order to synchronize efforts on multiple fronts. It deepens a rift that was already systemic, and, although presumably properly justified, hands the Russian government an important although conditional political victory in its confrontation with the US Democrat-led alliance that includes most European leaders. Assuming that President Trump does not pursue the facilitation of Chinese and Indian imports of Russian hydrocarbon, among others, the determination of national interests may have surpassed the rationale of the war from Ukraine in US administration’s assessment.
5. Timelines for renewable energy in the context of October 16th US Executive Order
In 2025, China’s solar power production reportedly reached 1,175 TWh, while wind energy generation hit 1,130 TWh. Although China’s electricity production from solar power exceeded the total electricity output of Japan, the added renewable energy primarily served to displace fossil fuels, forcing an absolute decline in thermal power generation. Nevertheless, coal remains dominant, accounting for 51.4% of China’s total energy production (Energy Connects/Bloomberg, 2026). Thus, for China, the energy transition remains a gradual decoupling process rather than an overnight overhaul. China decreased its dependency on fossil fuels from 97.52% in 2000 to 87.55% in 2025 (Ritchie & Rosado, 2026). A comparison between certain US, Chinese and German (as the largest EU economy) energy indexes is presented in Table 1.
Table 1. Comparison of various US, Chinese, and German energy indexes (Ritchie & Rosado, 2026)
| Country | US | China | Germany | ||||
| Year | 2000 | 2025 | 2000 | 2025 | 2000 | 2025 | |
| Primary energy use per person [kWh] | 93,272.01 | 75,051.33 | 8,953.7 | 31,815.43 | 48,326.88 | 33,183.23 | |
| Primary energy use (total) [TWh] | 26,254.59 | 26,063.51 | 11,367.45 | 45,053.71 | 3,953.01 | 2,789.88 | |
| (Total) electricity generation [TWh] | 4,034.99 | 4,519.79 | 1,355.6 | 10,583.36 | 568.95 | 500.47 | |
| Share of primary energy from fossil fuels [%] | 88.47 | 83.17 | 97.52 | 87.55 | 85.80 | 84.83 | |
| Share of primary energy from nuclear [%] | 9.16 | 9.6 | 0.45 | 3.26 | 13 | 0,00 | |
| Energy intensity [kWh/$ of GDP] | 2.03 | 1.31 | 1.91 | 1.49 | 1.45 | 0.80 | |
The hints that while the US and Germany decreased energy consumption per person between 2000 and 2025, China’s per capita consumption increased at 355.33 % of the 2000 value. In terms of total energy usage, China became a global leader with a consumption representing 172.86 % of US total consumption. Even though the energy intensity is higher than that of Germany, and comparable with US energy intensity, China’s total primary energy use suggests, besides the high increase in total energy use, an increasing industrial capacity.
Although Chinese metrics from Table 1 hint at a large energy sector, it is also the most dynamic in adopting new renewable capacity, with the largest decrease of fossil fuels share, i.e. from 97.52 % in 2000 to 87.55 % in 2025. Although non-fossil fuels are not yet equal to those in the US and Germany, the rate of replacement suggests that fossil fuel reliance may decline faster in the latter two nations. In this context, China is the fastest replacer of fossil fuel as share of an increasing total energy use in the context of growing energy demand in both the US and China. The law demands China’s even more accelerated adoption of renewables, or conflict with the US over Russian supplies.
While countries such as Germany or France, the latter relying on nuclear power for its electricity production may, continue to stagnate in terms of energy consumption, due to energy consumption reduction or externalization of supply chains to other countries for energy-intensive industrial processes, China is certainly increasing both its energy consumption and share of renewable energy. As the US and China compete for transitioning to clean energy, and China has the upper hand in terms of solar energy systems production, in the scenario of a peaceful transition to a new energy supply paradigm and a wider competition across the globe, a medium-term maintenance of US oil and gas hegemony, combined with an unclear set of regulations at international level although the US is clearly accelerating in this direction, can rebalance the outcomes of transition by compensating Chinese income from the sales of solar energy systems with oil and gas income. In this case, but also in the scenario of a less peaceful transition to a new competition paradigm, China has many incentives to speed up the transition to renewable energies and maintain oil and gas for baseload energy generation, alongside its massive coal sector.
Consequently, the oil and gas sales by the US do not appear to completely replace the advancement of renewable energy development as a solution to the future, but rather as a means of capitalizing on the lack of action by more static countries and a source of income to compete with the Chinese solar energy sector that delivers energy capacity within China and abroad. This hypothesis is reflected by the US effort to scale up renewable energy installed capacity, while capitalizing on European and other energy deficits: US consumed approx. 19.7 million barrels per day as of 2000, and approx. 20.59 million barrels per day in 2025 (Blas, 2025), i.e. comparable amounts, but its exports, along imports and reexports increased massively in the same period: from an estimated 1 million barrels per day exported in 2000, and approx. 11 million barrels per day imports, the US came to import 7.9 million barrels per day and export 10.7 million barrels per day as of 2025 (Olson, 2026).
6. The AI race and American increase in energy consumption
According to reports from certain industry representatives, and the White House, the AI domain is developing at a fast pace, a financial bet that dominated Wall Street numbers in the recent years. The unmatched increase in computing capacity in the US is projected to increase electricity demand from a 4.5 % of total US energy use in 2026 to an estimated 9-17 % by 2030 (Marshall, 2026). Although China’s electricity generation is approx. double that of the US, the projected increase of data-center power demand to 6 % of total power consumption by 2030
(Wood Mackenzie, 2026) is still conservative when compared to a 9 – 17 % scenario for the US by the same year.
In all scenarios, power consumption in computing centers in key markets such as the US and China is expected to increase significantly. Should the US continue to lag behind China in solar energy, maintaining traditional oil and gas energy sources alongside the development of the nuclear sector, may emerge as a key national security goal for future US administrations. This industrial asset would allow the US not only the generation of revenue, but also leverage in negotiations with energy superpowers such as Canada (only in relation with the US), the Russian Federation or Saudi Arabia.
As such, while Moscow may benefit in the short term from diesel revenues after the researched Executive Order, it contributes to the maintenance of a consumption structure that allows the US to capitalize on in peacetime (in the Persian Gulf), while developing both renewable energy infrastructure and an energy-intensive computing infrastructure that quickly shifts consumption patterns.
Whether the evolving AI infrastructure produces structural imbalances in the US industrial landscape and capital markets – and directly or indirectly fuels inflation through increased energy consumption among other factors – is a broader topic of discussion. However, this cannot be fully decoupled from the diesel deal reached by President Trump with the Russian Federation, especially in the context of mid-term elections, as the US is fighting both inflation and a rampant increase in interest costs for the sovereign debt: the $1.36 trillion gross interest costs for the fiscal year 2026 represent more than double the interest costs from 2021 (Ma, 2026). Thus, the Executive Order might indirectly allow the US to focus capital on sectors it considers strategic for future competitiveness.
7. Discussion and conclusions
The context of “H.R. 5334 – Lindsey O. Graham Sanctioning Russia and Iran Act of 2026” law and “Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026” Executive Order includes complex global dynamics that the US attempts to master through fine adjustments amid a growing structural competition. Neither the law nor its accompanying executive order guarantees a systematic long-term success, the interplay between the two being sometimes assessed as increasingly unstable US policy.
The challenges that the US faces in competing with emerging economic powers include, among others, growth-based models that in the case of AI race, appeared to amass vast amounts of capital in this sector. While the increase in energy demand was an unintended consequence, further consequences may emerge along what appears to be a historical transformation process. The potential imbalances created due to the AI development, or AI bubble as its critics call it, appear to have been sanctioned by BlackRock’s decision to cut its rating on US stocks to neutral while purchasing 10-year treasuries that reached a 5.25 % yield in October 2026 (Sheridan, 2026). Thus, despite holdings amounting to hundreds of billions in technology giants such as Nvidia, Apple, Microsoft, Amazon and Alphabet, BlackRock may have established that stock equity may not return even 5.25 % per year, which is still a conservative expectation compared with the increase in their capitalization.
A discrepancy has been identified in the evaluation of short-term and long-term acute necessities between the Trump administration and the Congress on one hand, and between the American and European administrations when assessing the Graham Russian sanctions law and subsequent executive order. The commitment to advancing renewable energies appears to be present in all cases, but the perceived schedule and scale may be different.
The scenario of implementing such sanctions in the short-term risks aggravating of economic conditions for the large American society that battles an already rampant inflation, the perspective of a continued war in Iran and potentially other theaters, and the uncertain outcomes of AI revolution: although the US is contemplating measures, it was China that launched a comprehensive effort to boost employment amid AI advances in early October 2026 (The State Council of The PRC, 2026). Although the Chinese measure may have been launched too early and does not guarantee any real success, it may contribute to social peace within the country even through its intent.
“Implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026” Executive Order and the pause in US consequence in sanctioning the Russian Federation emphasizes the oscillations specific to a struggle for survival in structural-realist terms, or for hegemony from another perspective, that raises the question whether the previous Democratic administration overestimated the capacity of US and allied countries to conduct a war with the Russian Federation or the current US administration underestimates it. Thus, the correctness of any measure is related to the understanding of historic transformations.
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Cover image credits: Aleksandr Popov via Unsplash. For illustrative purposes only.
Ecaterina MATOI is the president of Strategic Dialogue for Global Affairs initiative.