On 10-10 I read the paperwork behind Trump's Russian diesel deal and left one question open: whether General License 135 reaches the 2022 statute that bans Russian oil imports. Since then the story has moved in two directions. Trump said on Saturday that Ukraine needs "a new president." And the more checkable thing: a second statute, signed three weeks before the license, has a deadline that lands on 10-18. I opened both statutes and the license itself this time, instead of relying on summaries.
The license, re-read
General License 135 is two paragraphs. Paragraph (a) authorizes transactions under 31 CFR parts 587 and 589 "related to the sale, delivery, offloading, or importation, including importation into the United States, of diesel fuel of Russian Federation origin" through 12:01 a.m. EDT on April 7, 2027. Paragraph (b) excludes debits to accounts of the Russian central bank, National Wealth Fund and Finance Ministry at US institutions. It was signed 14:43:59 -04:00.
One discrepancy. The AP story, as republished by ETV Bharat, says the license means sanctions "will not apply until April 2027 on deliveries of Russian diesel that has been loaded onto tankers as of Friday." The license text has no loading-date condition. Earlier 30-day licenses did turn on cargo already in transit (CNBC describes them), and I suspect the wire copy carried that over. That is a guess. The text is what governs.
Section 112 and the clock
The Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 is Public Law 119-111, dated 09-18. Section 112(a):
Not later than 30 days after the date of the enactment of this Act, the President shall, notwithstanding any other provision of law, increase the rate of duty for all goods, including oil, natural gas, liquefied natural gas, petroleum, petroleum products, petrochemical products, coal, and coal products, imported into the United States from the Russian Federation to a rate of up to 500 percent ad valorem.
Thirty days from 09-18 is 10-18, a Sunday. Subsection (b) stacks the duty on top of every other duty. Three features matter for diesel:
- "Shall," with a ceiling and no floor. The text says "up to 500 percent." What I can read is that the President must act on petroleum products and picks the rate. I can't tell from the text whether a very low rate would satisfy "increase."
- The license is not inside the exception. Section 114(h)(1) exempts a US person "operating under the terms of a general license issued by the Department of the Treasury before the date of the enactment." GL 135 was issued 10-09. Section 114(h)(2) preserves Treasury's authority to "extend or issue new general licenses," which keeps the power to license. It does not say a new license exempts anything from a duty. A sanctions license and a customs duty are separate instruments; that is my reading, and Diplomacy & Law reaches a similar one.
- There is a way out, with paperwork. Section 115(a) lets the President waive "any duty under this title," but 115(b) requires a written national-interest certification and a report to Congress first. The one reporting exemption, 115(b)(4), covers only rate changes under section 113(b), not section 112. Section 117 termination needs a certification that Russia has signed a peace agreement accepted by Ukraine's government. I found no report of a certification or waiver filed as of this morning; Business Upturn said the same on Saturday.
Section 113, the one aimed at third-country buyers, is capped at 100%, and its trigger is defined by crude oil (HS 2709) and natural gas (HS 2711) in 113(g)(2). Diesel sits under a different heading, so on my reading a country buying Russian diesel doesn't trip that trigger. I haven't seen anyone else make this point, so treat it as mine to be checked.
The older ban
Public Law 117-109, section 2, bans importing all Russian products classified under chapter 27 of the Harmonized Tariff Schedule, "in a manner consistent with any implementation actions issued under Executive Order 14066." Diesel is in chapter 27. Section 3 is the exit: a presidential certification that Russia has agreed to withdraw and stop hostilities on terms Ukraine's government accepts, 45 days of prior consultation and a report, then a 90-day delay unless Congress disapproves.
GL 135 does not cite this Act. Whether the "consistent with implementation actions" clause lets Treasury license around the ban or merely describes how it is enforced is the open legal question, and I found no court or agency answer to it. The Congressional Research Service noted in its September sidebar on the bill that the Graham Act "would not appear to repeal" the 2022 ban.
What none of this shows
- Whether any Russian diesel is bound for a US port. Russia's own export ban runs to 10-31, and Novak told TASS shipments could begin this month.
- What rate the administration plans under section 112, or whether it intends a waiver. I found no statement from the White House or Treasury on it.
- Whether the licensed trade is lawful. The two statutes make that a real question; I am not claiming the answer.
Since 10-10
Trump said Saturday it is "time for Ukraine to get a new president" and blamed Zelensky for diesel prices. On ABC on Sunday, Zelensky said Ukraine would organize elections if Russia agreed to a 60-day total ceasefire, and earlier said Ukraine would halt refinery strikes if Moscow stopped hitting Ukrainian energy infrastructure. That is the reciprocal condition Kyiv had stated before the license. The diesel claim has the same problem it had on 09-22: AP puts the US record at $6.52 on 09-22 and $6.28 on 10-09, and the Iran war began in February with diesel near $3.60, as I noted in the 09-22 piece.
The Kyiv Independent's exclusive says Ukrainians in Miami were also told the US would cut off intelligence sharing used for deep strikes. That rests on one person present at the talks, speaking anonymously. I found no US confirmation or denial. Hours after the announcement Ukrainian drones hit an oil terminal at Rostov-on-Don, and Russia hit Kyiv's energy facilities on 10-10, so neither side's strikes paused.
What to watch
Between now and 10-18: a section 112 proclamation or notice with a rate, a section 115 certification and report, or silence past the deadline. Any of the three tells you which statute the administration treats as binding.