The Russia sanctions law does not ask the President. It tells him, by 18 October.

The White House said the President had signed a law that “authorizes and expands statutory sanctions, tariffs, and prohibitions on Russia”.¹ Authorizes is a permissive verb. It suggests a tool handed over, to be used or not.

The text he signed uses a different one.²

Section 103 does not permit the President to sanction Russian banks. It requires it, on a clock: “Not later than 30 days after the date of the enactment of this Act, the President shall- (A) impose 2 or more of the sanctions described in subsection (d) with respect to the Central Bank of the Russian Federation (Bank of Russia) and any subsidiary of, or successor entity to, that Bank; (B) impose all of the sanctions described in subsection (d) with respect to- (i) Sberbank; (ii) VTB Bank; (iii) Gazprombank”.²

The list does not stop at three. Subparagraph (B) continues to “any other financial institution organized under the laws of the Russian Federation and owned in whole or in part by the Government of the Russian Federation”, to the subsidiaries and successors of everything above it, and then out past Russia’s borders to “any foreign financial institution that engages in significant transactions” with any of them. Subparagraph © reaches the people: leaders, officials, senior executives, board members and controlling shareholders of those institutions.²

One exit is written into that reach. Section 103© says the President “is not required” to sanction the foreign banks in the last category “if the Secretary of the Treasury determines that imposing such sanctions is not consistent with the economic or foreign policy interests of the United States”.² It is the only one of these categories with a door of its own, though section 114 separately exempts humanitarian trade — agricultural commodities, food, medicine and medical devices — from the whole title.²

The tariffs use the same verb and the same clock. Section 112: 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”.²

Section 113 does it to third countries at up to 100 percent, and defines them by test rather than leaving the first round to anyone’s choice. A country qualifies if it “knowingly made new purchases” of Russian-origin crude or gas on or after the thirtieth day, and was “among the 5 largest importers, by total volume” of it over the preceding year — or, alternatively, if it was “among the top 5 countries facilitating Russian oil sanctions evasion”.²

After that first round the Trade Representative takes over the list. Section 113(e) requires it, “in consultation with the Secretary of State and the Secretary of Energy”, to redetermine the five largest importers of crude and of gas every 180 days and impose duties accordingly. Section 113(g) requires the President or the Trade Representative to submit a written justification to Congress at least 10 days before any duty is imposed under either subsection, detailing “the methodology used to determine that the country subject to the duty is a country described in subsection ©”.²

The Act was signed on 18 September.¹ Thirty days from enactment falls on 18 October 2026.

There is real discretion in this law. It is not where the word “authorizes” suggests.

The first is the rate. Both tariff sections say “up to”.² The President must raise the duty; how far is his. A one percent tariff would satisfy the verb.

The second is the finding. Section 102’s sanctions attach to persons he “determines are described” in its criteria, and section 103’s widest category can be switched off by a Treasury determination.² The mandate itself is not escapable. Its edges are drawn from inside the administration.

The third is the waiver, and it is the one worth watching, because the law makes it expensive. Section 115 permits a waiver only after the President submits to Congress “a certification in writing that the issuance of the waiver is in the national interests of the United States”, with a report explaining the basis.² He can decline to sanction Sberbank. He has to put his name on a document telling Congress why not sanctioning Sberbank serves the United States.

Ending the measures outright is harder, and the test differs by target. For Russia the President must certify that it “has- (i) signed a peace agreement that is accepted by the free and independent Government of Ukraine; and (ii) ceased all military hostilities against and any activities to overthrow, dismantle, and subvert the Government of Ukraine” — both, not either. For any other country or person he must certify both that it “is not engaging in the activity that was the basis for the sanctions” and that he “has received reliable assurances” it will not in future. Congress then holds the termination for 30 calendar days, or 60 if the report arrives between 10 July and 7 September.²

If the law merely authorised, nothing has changed and the story is about presidential intent. Because it requires, the story is about a date.

On 18 October the administration will have done one of three things: imposed the sanctions and set the tariff rates, filed a national-interest certification explaining why it did not, or allowed a statutory deadline to pass without doing either. Each is a different fact about the world, and each is visible from outside without anyone briefing a reporter about it.

We do not know which it will be, and we are not going to guess. We also do not yet know whether any designation has been issued since the signing; we have found no announcement of one, which is not the same as establishing that none exists.

What we can say is that the question is not whether the President has been given a tool. It is whether he uses one he has already been handed, and what he is prepared to write down if he does not.