Trump Risks Violating U.S. Law by Giving Russia Even More Sanctions Relief

The basic rule of negotiation is to get more than you give. With Russia, the Trump administration is taking the opposite approach. On October 27, The New York Times reported the Trump administration is considering lifting sanctions on a Russian government slush fund known as the Russia Direct Investment Fund (RDIF). The move would, according to one U.S. official, “improve U.S.-Russia relations and help end the war.” But absent prior credible reforms by Moscow — including movement to end the war in Ukraine — and the statutorily required congressional notification, the proposal risks running afoul of statutory restrictions on unwinding Russia-related sanctions. Discussion of the proposed rollback comes less than three weeks after the Trump administration authorized Russian diesel imports to the United States for six months. It also follows President Donald Trump’s blanket waiver of additional sanctions and tariffs under the recently enacted Lindsey O. Graham Sanctioning Russia and Iran Act. U.S. Law Prohibits Broad, Unconditional Sanctions Relief to Russia Several statutes constrain Trump’s ability to lift sanctions on RDIF or its management company, given their respective designations under Executive Order (E.O.) 13662 and E.O. 14024. The 2024 Rebuilding Economic Prosperity and Opportunity for Ukrainians (REPO) Act restricts the release of Russian sovereign assets, potentially including qualifying RDIF holdings, until the president certifies that hostilities have ceased and Russia has compensated Ukraine or joined an agreed international compensation mechanism. It also requires 30 days’ congressional notice before releasing such assets. The 2017 Countering America’s Adversaries Through Sanctions Act (CAATSA) also codified restrictions that may limit the rollback of sanctions on RDIF-related entities. Section 222 conditions their termination on evidence of behavior change and assurances against future malign activity. Section 216 separately requires congressional notification and review before lifting covered Russia sanctions. Additionally, the Graham Act required existing E.O. 14024 sanctions to remain in force and mandated sanctions against Russian government-controlled entities. Trump, however, waived those requirements on October 16, raising questions about how far his waiver authority extends and the degree to which it clearly undermines congressional intent. Lifting Sanctions Rewards Oligarchs and Prolongs War Sanctions relief for RDIF would likely bolster Russia’s war effort as Moscow faces mounting financial pressure. The war has cost Russia more than $700 billion — more than 27 percent of its 2025 gross domestic product — and contributed to a budget deficit of $72 billion as of August 2026. To plug that gap, the Kremlin has proposed tax hikes, sought to redirect tens of billions in private pension funds to state-controlled accounts, and reportedly pressed oligarchs for mandatory “donations” to the war effort. Unwinding sanctions on RDIF now would only assist Russia’s war effort and replenish President Vladimir Putin and his patronage network. This would relieve pressure on a key constituency whose incentives might otherwise involve pushing for peace. Continue Sanctions Pressure To Support a Strong Negotiating Position Sanctions relief should be earned through verifiable Russian concessions, not offered in anticipation of them. Washington should condition any rollback on Moscow negotiating in good faith, demonstrating sustained compliance with its commitments, and ending its aggression against Ukraine. Any peace agreement should also provide for reimposing sanctions if Russia resumes aggression against Ukraine or another sovereign nation. To preserve leverage, the Trump administration should maintain sanctions on RDIF, revoke its authorization for Russian diesel imports, and reverse its sweeping waivers under the Graham Act. It should also move expeditiously to sanction hundreds of thus far unsanctioned vessels operating in Russia’s shadow fleet. The Graham Act authorizes Treasury to use allied sanctions designations against shadow fleet vessels as prima facie evidence for their designation. Congress should challenge any rollback that circumvents statutory notification and review requirements or that violates other legal restrictions. Lawmakers should also amend the Graham Act to impose time limits on presidential waivers, rather than allowing them to remain in effect indefinitely. Without such guardrails, the administration risks surrendering economic leverage without securing meaningful concessions in return. Max Meizlish is deputy director of the Center on Economic and Financial Power (CEFP) at the Foundation for Defense of Democracies (FDD). Angela Howard is a research analyst at CEFP. For more analysis from Max, Angela, and FDD, please subscribe HERE. Follow FDD on X @FDD and @FDD_CEFP. Follow Max on X @maxmeizlish. Follow Angela on X @angela__howard. FDD is a Washington, DC-based, nonpartisan research institute focusing on national security and foreign policy.