Three weeks after a Russia sanctions statute — described as the broadest of his presidency — received Donald Trump's signature, the Treasury Department's Office of Foreign Assets Control put General License 135 into effect on 9 October. Under the terms of the authorisation, diesel originating from Russia may be bought, transported, and brought into the country through 7 April 2027.

A number of news outlets portrayed the licence as being at odds with the recently enacted legislation. The statute appears to be functioning in accordance with its original intent. Embedded within the statute that carries Lindsey O. Graham's name — the law directed at Russia and Iran — a national-interest waiver provision allows the president to suspend nearly all of the binding obligations the legislation imposes, and the diesel fuel authorisation has become the first known case of that waiver power being put to use.

Once the Act's 30-day window shuts on 19 October, the debate is likely to pivot away from how far any measures against Russia extend and toward the question of which parties receive exemptions — and what grounds justify those carve-outs.

Enacted on 18 September, the legislation carries three provisions with direct bearing on commercial activity. Under the measure's first provision, full blocking sanctions fall on Sberbank, VTB, Gazprombank, and other banks held by the Russian state, while any foreign financial institution carrying out transactions of a certain scale with those entities faces exposure to secondary sanctions. Under its second provision, ships transporting Russian energy supplies — together with their registered owners, underwriters, and the harbour facilities that handle them — face formal designation.

A fourth provision, drawn from Section 113, would allow tariffs reaching as high as 100 per cent on all goods originating from any nation that ranks among the five largest buyers of Russian crude oil or natural gas and continues those purchases past the stipulated deadline, or that functions as one of the five leading conduits for circumventing existing sanctions. No specific countries are identified anywhere in the law's text. According to a working list circulated among Senate aides, the countries under consideration include China, India, Slovakia, Hungary, and Azerbaijan, with Turkey appearing in certain additional assessments.

Under Section 115, a written certification to Congress stating that deactivation serves the national interest is all that is needed to suspend any of these provisions. The obligation in question covers disclosure alone — it carries no power to block or override a decision.

Retail diesel prices across the US hit $6.51 per gallon in the most recent weekly figures, roughly twice the level recorded a year earlier, with the pump price having climbed around 70% since the outbreak of the Iran war. Senate seats in farm states that both parties once considered reliably Republican have drawn renewed attention as contested territory. Late spending by Republicans has flowed into Kansas and Nebraska, while the open seat in Iowa sits within polling range of either party. Diesel and agricultural fuels have drawn attention at the White House during the weeks before the 3 November midterm elections.

Among the entities assessed as facing the greatest exposure are state-owned Russian banks and the network of vessels operating outside formal shipping registries. Placing restrictions on Sberbank and VTB carries no direct cost for American consumers, given that both institutions had already been largely excluded from US financial markets by 2022. Naming rights for vessels carry a similarly low cost while remaining easy to identify. That month, vessels already operating under sanctions carried roughly three-fifths of Russia's crude exports, whereas tankers with Western ownership or insurance ties handled nearly three-quarters of its refined petroleum shipments.

Sanctions targeting oil tankers carrying Russian crude placed financial strain on Moscow's shipping trade. Measures targeting product tankers would conflict with GL 135, making such designations a low-probability outcome.

Among the sectors analysts view as relatively insulated from the anticipated impact: China's economy and the diesel trade. Roughly half of all crude oil leaving Russia since late 2022 has flowed toward Chinese buyers, positioning that country as the likeliest candidate for action under Section 113. A trade-truce extension running through January — granted by the United States following Xi's first state visit in eleven years — also took effect for the country during this period. Applying a tariff of 100% across an annual import volume of approximately $308.7 billion — with an election approaching — would, according to economic projections, place upward pressure on retail prices.

Data released for July showed Russian crude accounting for 50.8% of India's oil imports — a record share — even though a tariff-reduction agreement reached in February had included a commitment to wind down those purchases to an 18% duty level. Diesel refined within India's borders finds its way into fuel supplies across Western markets, with the country now functioning as a notable node in that international supply chain. Refineries in India, Turkey, and elsewhere that processed Russian crude exported roughly €510 million worth of petroleum products back to countries participating in the sanctions regime during August, with about €143 million of that volume destined for the United States.

According to Indian officials, the two sides stand roughly 99 percent of the way toward a completed trade agreement, and the Section 113 tariff is positioned as a bargaining tool within those negotiations rather than a punitive measure.

Both Hungary and Slovakia draw their oil supply from the Druzhba pipeline using Russian crude, while the legislative exemption written into the Act extends no further than natural gas. Ahead of a 21 November deadline on a one-year waiver, the administration in Budapest has taken its case to Congress in pursuit of relief. Regulatory frameworks on the two sides of the Atlantic have pulled in opposite directions — with Brussels tightening its oversight while Washington has cleared transactions that fall outside what European rules permit, placing businesses operating across the continent under pressure from two conflicting sets of obligations. Depending on the port of call, the same voyage can leave a shipper fully within the rules in New York yet in violation of them in Rotterdam.

Under Section 115, the path to a waiver runs through certification and a formal report — congressional approval plays no part in the process. Campaigning among the membership is set to continue through to November. Three weeks is all the time that exemption requires to remain in place.

Ahead of the legislation's passage, Daniel Fried — who had held the role of sanctions coordinator for the United States — told members of Congress that the provisions warranting the closest attention were not those susceptible to abuse, but rather those at risk of being circumvented through waiver mechanisms or left largely untested in practice. The licence for diesel operations has been cited as bearing on his position.

In the scenario analysts rate as most probable — carrying roughly a 60% likelihood — Treasury would direct new restrictions at Russian state-owned banks, bring additional crude-oil tankers tied to shadow-fleet activity under sanctions, and describe the overall package as the broadest Russia-focused enforcement effort of the current year. Under that scenario, the provision under Section 113 carries no tariff into force. Under the truce arrangement, tariff obligations were set aside for China, while India and Hungary each received formal notices framed around ongoing negotiations rather than direct duty assessments. The GL 135 designation holds without amendment.

In a scenario assigned roughly 25% odds, pressure from lawmakers on both sides of the aisle prompts the administration to submit the legally required 10-day congressional notice while setting India's rate at a relatively low level — somewhere in the 10–25% range. Republican co-sponsors attaching their names to the Fitzpatrick bill would serve as the condition that sets everything in motion. Pharmaceutical shipments, textile goods, and auto-parts exports from India stand to absorb additional duty layers on top of tariffs already in place, while refiners there may pull back on Russian crude purchases — a shift that analysts say could tighten global diesel availability at a point when heating-season demand typically rises.

In one projected outcome — assigned roughly a 15 percent likelihood — senators from the Republican Party representing agriculture-heavy states step away from the fuel agreement in a public display of dissent. Under the revised arrangement, GL 135 would cover only volumes for which contracts were already in place at the time of the change, with the authorisation set to expire ahead of its original schedule, while the first 180-day compliance review would carry binding enforcement weight rather than serving as a procedural formality.

Under Section 113, any tariff action is preceded by a written explanation delivered to Congress no fewer than ten days beforehand. Where no such notice has been placed on record, any secondary tariff attempting to take effect at the deadline would lack a lawful basis for doing so. Those initial Section 115 certifications, lodged during that same week, are set to list by name the individuals granted exemptions.