Denys Sienik, Ukraine’s chargé d’affaires in Washington, said Ukraine would present its proposals to the Trump administration and members of Congress this week. The requests include Russian companies involved in a satellite communications project modeled on SpaceX’s Starlink system and additional vessels believed to be part of Russia’s so-called shadow fleet.

The initiative comes less than two weeks after Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 into law on Sept. 18.

The law establishes mandatory review and sanction provisions covering Russian government officials, financial institutions, defense-industry suppliers, energy interests, vessels involved in sanctions evasion and other categories of people and entities.

Ukraine targets Russian satellite supply chain

Sienik identified companies producing components for Russia’s planned satellite-internet network as Ukraine’s immediate priority.

The principal Russian company developing the network is already under U.S. sanctions, he said, but companies supplying components to the project have not all been designated.

Ukraine argues that completion of the satellite constellation could provide Russian forces with additional communications and real-time battlefield information. Sienik said Kyiv is particularly concerned about the system’s potential effect during the coming winter.

The U.S. legislation gives the administration authority to sanction foreign persons that knowingly provide goods or services to Russia’s defense industrial base. The law specifically identifies categories including advanced sensors, certain machine tools, fiber-optic technology with military applications and items on the U.S. Commerce Department’s Common High Priority Items List.

Whether particular companies connected to Russia’s satellite project meet the statutory criteria remains a determination for the U.S. administration.

Kyiv seeks tougher action against Russia’s shadow fleet

Ukraine is also asking Washington to intensify measures against vessels used to move Russian oil and other commodities in ways designed to circumvent sanctions.

The new law specifically covers foreign vessels that the president determines are being used by Russia or Russian persons to circumvent U.S. or other countries’ sanctions. It also covers certain vessel owners, operators, managers, insurers and senior crew members.

The legislation includes vessels involved in transporting Russian crude oil, petroleum products, natural gas, liquefied natural gas, uranium, coal and other specified commodities.

The law also allows the president to use certain sanctions imposed by the United Kingdom, European Union, G7 or Five Eyes countries as prima facie evidence when determining whether a vessel falls within the relevant category.

Ukraine has previously pressed international partners to strengthen enforcement against companies and vessels involved in helping Russia circumvent sanctions.

New law sets an October deadline

The new legislation requires the president, within 30 days of enactment and every 180 days thereafter, to review people and vessels that fall within specified categories and impose sanctions on those determined to qualify.

Because the law was enacted on Sept. 18, the first 30-day review period runs into October. The administration therefore faces an Oct. 18 statutory deadline for the initial review and required actions covered by the provision.

The law requires sanctions against a number of specified Russian financial institutions. Within 30 days, the president must impose at least two specified sanctions on the Central Bank of Russia and impose the statutory sanctions on Sberbank, VTB Bank, Gazprombank and other qualifying Russian state-owned financial institutions.

The legislation also provides for restrictions on U.S. transactions with covered financial institutions.

Law reaches beyond Russian entities

The legislation is designed to reach some foreign actors that support Russia as well as Russian companies and officials.

Its sanctions provisions cover foreign persons that knowingly supply specified goods or services to Russia’s defense industrial base, conduct significant transactions with Russia’s armed forces, support activities that undermine Ukrainian critical infrastructure or security, or participate in sanctions-evasion transactions.

It also contains provisions concerning Russian energy projects, including specified Arctic liquefied-natural-gas projects.

The law establishes potential measures against countries that purchase Russian-origin crude oil or natural gas or facilitate sanctions evasion. A separate provision authorizes increased duties on goods imported from Russia and duties on certain countries involved in Russian energy purchases.

The legislation gives the president waiver authority under specified circumstances, meaning the existence of a statutory sanctions category does not by itself establish that every potentially covered entity will immediately be designated.

Ukraine has been building sanctions dossiers

Kyiv’s latest requests build on a broader Ukrainian effort to identify companies and suppliers supporting Russia’s military production.

In August, Ukrainian presidential sanctions commissioner Vladyslav Vlasiuk said Ukraine had identified more than 100 Russian companies involved in ballistic-weapons production and had supplied information to partner governments. He also said Ukraine had identified more than 200 Russian plants and more than 1,600 machine tools used in weapons manufacturing.

Ukraine has separately strengthened its own sanctions against Russian financial institutions and cryptocurrency-related entities, saying the measures are intended to prevent Russia from using newer financial instruments to circumvent restrictions.

President Volodymyr Zelenskyy also discussed implementation of the Graham law with U.S. lawmakers during meetings in September. On Sept. 24, he said Ukraine needed sanctions against Russia and those helping it generate revenue from the war.

Washington must decide which requests to adopt

Ukraine’s list does not determine which entities the United States will sanction.

The decision rests with the Trump administration under the authorities and requirements established by the new law. The legislation sets categories and deadlines but leaves determinations about individual foreign persons and vessels to the president and relevant U.S. agencies.

Sienik’s proposals therefore represent Ukraine’s requested targets rather than a finalized U.S. sanctions list.

The administration’s initial decisions will also show how broadly it interprets provisions covering Russia’s defense supply chains, maritime sanctions evasion and foreign companies supporting Russian strategic industries.

For Ukraine, the immediate objective is to persuade Washington to use the new authority against companies and vessels that Kyiv says are contributing to Russia’s military capabilities or helping Moscow maintain energy revenues.

The first statutory review deadline is Oct. 18.

Reporting Credit: U.S. Government Publishing Office; Government of Ukraine and Office of the President of Ukraine; Ukrainian Embassy in Washington; U.S. Congress.

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