Part I — Situation overview

On Friday 18 September 2026, US President Donald Trump signed the Lindsey O Graham Sanctioning Russia and Iran Act of 2026, which the press refers to as the Graham Act. The joint proposal of the Republican senator Lindsey Graham, who died in July, and the Democratic senator Richard Blumenthal was passed by the Senate in August and by the House of Representatives on Wednesday, with the votes of 58 Democratic representatives in favour. According to Al Jazeera, the law imposes sanctions on Vladimir Putin, Russian leaders, oligarchs and banks. It targets the Russian energy and defence industries, as well as the shadow fleet, that is, the tankers of opaque ownership used to circumvent sanctions. Its key provision authorises the President to impose tariffs of up to 100 per cent on the five largest buyers of Russian oil and gas. According to the MTI (Hungarian state news agency) material published by Népszava, the same authorisation also extends to the five countries that do the most to help circumvent the sanctions. According to Balkan Insight, the regional portal of the Balkan Investigative Reporting Network (BIRN), Hungary, with purchases of some five million tonnes a year, is the fifth-largest market for Russian oil. It remains an open question, however, how a tariff could hit an EU member state without hitting the single market as a whole.

On the same day in Brussels, the renewal of the EU’s Russia sanctions list stalled. According to EUobserver’s diplomatic sources, the French ambassador to the EU made France’s consent conditional on the delisting of a Russian oligarch; otherwise France would let the list of some 3,000 names expire. Slovakia supports Paris, and Luxembourg is asking for the delisting of another oligarch. In the absence of a unanimous Council decision, the list expires at midnight on Tuesday (22 September). The Council has already pushed back the deadline once, by a week from 15 September, which according to the outlet is unprecedented since 2022, and the member states have agreed that there will be no further postponement. MIAK found no statement in public sources on the position of the Hungarian Government. On Friday, Hungary, represented by the head of its embassy in Kyiv, took part in the first summit of the regional cooperation format known as the Carpathian Eight (C8), and the Russian embassy in Budapest publicly criticised the Hungarian–Ukrainian rapprochement.

MIAK has previously proposed a public exposure balance sheet and an exemption timetable, a duty to give reasons for requests for sanctions exemptions, and, on the day of the House vote, a measurement-based JANAF decision. Two things are new. The tariff authorisation is now an instrument in force, not a draft. And the EU list may fall on precisely the mechanism that MIAK’s earlier analyses already examined in connection with exemption requests: because of unanimity, even a single member state can extract a concession. MIAK’s reading: linking the two issues is tempting but harmful. If Budapest traded its EU vote for a concession from Washington, or vice versa, it would be weaker at both tables — credibility is the only capital that a small member state can use in both places at once.

Part II — Foundations in the literature

Three sources provide the interpretive framework. Henry Kissinger, former US National Security Advisor and Secretary of State, distinguishes two forms of linkage in his memoir White House Years (1979). One is a deliberate negotiating device, when one objective is used as a pledge for another. The other is a connection created by reality, when an actor’s weakness shown in one issue also damages its credibility in the others. In the same work he describes how the Western alliance countered the Soviet tactic of dealing with the allies one by one with a negotiating system that set limits which could not be crossed without the allies’ agreement. Kristian L. Nielsen, a researcher at Copenhagen Business School and the University of Tartu, shows in his study EU Soft Power and the Capability-Expectations Gap (2013) that the Union’s credibility is built from its past deeds. In his view, every occasion on which it fails to deliver the action expected of it in itself erodes its influence. And the EU founding treaties set out the room for manoeuvre. Common foreign and security policy decisions require unanimity, but a member state can also stay out without blocking. Restrictive measures against persons can be challenged in court, and trade policy is an exclusive EU competence. The detailed treatment of the literature — by author, with quotations — is in section 6.4 Literature in detail.

Part III — MIAK’s concrete proposal

MIAK proposes three measurable steps. The first concerns the current renewal, the second removes the scope for blackmail in future renewals, and the third directs the US tariff risk into the channel that is correct in terms of competence.

3.1 A public, unconditional Hungarian yes to the renewal of the full list (by 21 September 2026, before Monday’s negotiations)

MIAK proposes that the Government — which represents Hungary in the Council — publish a unilateral statement before Monday’s negotiating round: Hungary supports the renewal of the some 3,000 names, and makes this conditional neither on a delisting nor on a concession in any other matter. The statement should also say what the Hungarian vote does not contain: it has no connection with the US tariff authorisation, the Ukrainian accession negotiations or any other dossier. If the Government disputes the justification for a particular listed name, it should do so in the separate procedure under 3.2, in writing and with reasons. In substance the step asks little — Hungary is not blocking — its significance lies in the timing and in the publicity. If the list expires on Tuesday, the legal basis for the asset freezes and entry bans ceases, and relisting would require a new unanimous decision, with litigation risk. This could be the first live application of the voting log of the KP3 transparent foreign policy programme point, and it is also in line with KP4 principled pragmatism: the Hungarian interest here is that the list should not collapse. According to Nielsen’s thesis (see 6.4.2), the Union’s credibility is shaped by such moments that depend on delivery. Hungary, whose earlier veto practice MIAK’s Foreign policy background material classifies among the instruments with diminishing returns, can now signal a change of direction cheaply.

3.2 Decoupling delisting requests from the renewal (a Hungarian procedural proposal by 31 December 2026, to be applied before the spring 2027 renewal)

The structural cause of the current crisis is that delisting and the extension of the entire list are bargained over at the same moment, in the same unanimous decision, so any member state can hold the other three thousand names hostage for a single name. MIAK proposes that Hungary initiate a political agreement on procedure in the Council working party dealing with sanctions, with three elements. First: a delisting proposal may be submitted no later than 60 days before the renewal deadline, with written reasons referring to the listing criteria and the available evidence. Second: the Council should decide on delisting proposals as a separate agenda item, before the renewal, and the member states should undertake not to make the adoption of the renewal conditional on an individual delisting. Third: the member states should examine lengthening the renewal cycle, so that there are fewer deadlines suitable for blackmail, while the listed persons’ legal remedies remain unchanged. The founding treaty (see 6.4.3) gives the listed person a judicial route, meaning that there is a legal channel for remedying an unlawful listing, and a political bargain is not needed for it. The initiative is a typical case of KP17 issue-based coalition-building: every member state that does not want to be a hostage itself in the next round has an interest in the stability of the list.

3.3 Handling the US tariff authorisation through the EU channel, with a public contact log (request by 19 October 2026, first log by 31 December 2026)

The Graham Act is an authorisation, not an obligation: the US President decides on the imposition of the tariff at his discretion, and today’s reports do not name who will be in the crosshairs. How a tariff hitting a member state’s products would work in the single market is an open question. The response, however, whether negotiation or countermeasures, is part of the common commercial policy, in which the Union has exclusive competence (see 6.4.3). MIAK therefore proposes that the Government ask the European Commission in writing within 30 days to put on the agenda of the US–EU trade dialogue the question of how Washington would apply the law to EU member states, and to prepare a common line of response before any presidential decision is taken. The text of the request should be public. In addition, the Government should publish a quarterly contact log of every consultation in Washington concerning the law: when, who, what was asked for and what was offered — with the details of ongoing negotiations published after they have concluded. This is a practical application of the economic diplomacy integration of KP8 and the publicity principle of KP3. According to Kissinger’s account (see 6.4.1), against a great-power tactic of dealing with the allies one by one, the smaller actor’s strength lies in embedding its negotiating room in the common framework — precisely what it would give up with a separate deal.

The three proposals are bound together by a single principle: where linkage is a negotiating device, it must be renounced, but where reality links the issues, the consequences must be accepted. No trade-off must be created between the sanctions vote and the tariff risk, yet the two are still connected: the credibility that Hungary gains or loses in Brussels on Monday also counts in Washington.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Foreign policy and alliance credibility The unconditional yes and the procedural initiative are a visible sign of a break with the earlier veto practice; the Hungarian vote becomes predictable The public advance commitment gives up a negotiating instrument; the French and Luxembourg sides may interpret the decoupling proposal as a move against their own delisting demands
EU decision-making A separate track for delisting requests reduces the chance that the list expires because of one name or another The agreement is political, not legally enforceable: the unanimity rule remains unchanged, and a determined member state can still block
Economy and tariff exposure A common line of response via the Commission reduces the chance of separate deals differing from member state to member state, and handles the tariff risk with the Union’s full negotiating weight EU coordination may be slower than a bilateral channel; if Washington decides quickly, the common response may arrive late
Publicity and accountability The contact log makes visible whether exemptions were requested, and with what in return Premature publicity could reveal the negotiating position — which is why the details of ongoing consultations enter the log only after they have concluded

The main question to weigh is whether the public, unconditional yes weakens Hungary’s negotiating position. MIAK’s answer: bargaining power gained by blocking the renewal is short-lived and expensive, because the other member states learn to work around an unpredictable partner. According to the Foreign policy background material, this adaptation could already be observed in earlier years. The proposal becomes risky if the procedural agreement under 3.2 exists only on paper and the member states still bargain by invoking the renewal as the deadline approaches. This is mitigated by the public delisting deadline and by a Council register of the reasons submitted. In the case of 3.3, the risk is that the Commission does not treat the exposure of a smaller member state as urgent; it is therefore worth submitting the request jointly with other member states that still buy Russian energy.

Part V — Measurability and summary

5.1 What is worth following? (suggested KPIs)

MIAK suggests four key performance indicators (KPIs), from which it will be visible after 6, 12 and 24 months whether the proposals have taken effect:

  • The outcome of the current renewal: it is worth following whether the full list is renewed by midnight on 22 September without further postponement, and whether there was a public, unconditional Hungarian statement beforehand.
  • Separating delisting requests: the suggested target is that the Hungarian procedural proposal be put before the Council working party by 31 December 2026, and that the spring 2027 renewal be concluded without a deadline extension.
  • Number of Hungarian conditions attached to renewals: the suggested target is that in 2027 Hungary make no sanctions renewal conditional on a delisting or on a concession in another matter.
  • The EU channel and the log: it is worth following whether the request to the Commission is public by 19 October 2026, whether the first quarterly Washington contact log appears by 31 December 2026, and within how many days a common EU response is produced to any presidential tariff decision affecting Hungary.

5.2 Summary

MIAK’s request is twofold. In the short term: before Monday, the Government should state publicly that Hungary unconditionally supports the renewal of the Russia sanctions list and does not link this to anything. In the longer term: it should initiate that delisting take place in a separate, reasoned procedure, and it should handle the US tariff risk through the Commission, with a public contact log, not through a bilateral separate deal. The signing of the Graham Act and the threat of the list expiring on the same day show that in sanctions policy the price of a member state’s vote is decided in two capitals at once.

Two MIAK foundational values are affected. Transparency, because Council bargains and requests for exemptions in Washington typically take place behind closed doors, and the public learns of them only when the list is already in trouble. The voting statement and the contact log reverse this order. Accountability, because if a member state puts the entire sanctions regime at risk for the delisting of one name, the cost is borne by the community and the benefit by a single listed actor. A reasoned delisting procedure with deadlines ties the decision back to responsible reasoning.

Part VI — Reasoning and further sources

6.1 Press framing by spectrum

The international press treated the two threads almost entirely separately. Al Jazeera — building on material from AFP and Reuters — framed the law from the perspective of the global energy market. It named China and India as the targets of the tariff threat, and highlighted India’s energy-security response and Xi Jinping’s upcoming visit to Washington. From the US domestic political debate it quoted the criticism of the Democratic minority leader Hakeem Jeffries about the law’s loopholes and the cost of tariffs falling on American families. The article did not write about any European member state. EUobserver presented the EU thread as a test of European cohesion: the outlet described the French position as a game of chicken (who blinks first), and projected the expiry of the list as an unprecedented failure. Only the introduction of the article was publicly readable, not the more detailed background of the negotiations. Balkan Insight is the only source that specifically named Hungary’s exposure, from the angle of the Croatian–Hungarian oil pipeline dispute.

In the domestic press the news was pushed behind the Carpathian Eight summit. In the left-liberal band, Telex, HVG and Népszava carried the C8 announcement and, citing information from the Ministry of Foreign Affairs, recorded that Hungary was represented by Antal Heizer, head of the embassy in Kyiv. In an update, Telex corrected its earlier claim, based on the official photos, that there had been no Hungarian participant. 444.hu, by contrast, relying on the Ukrainian Pravda, wrote that no Hungarian representative appeared in the official photos. In separate MTI material Népszava reported the signing of the Graham Act, putting the emphasis on Zelensky’s thanks and on the demand for action against buyers. None of the domestic sources carried the expiry of the EU list. In the public-affairs band, Index reported the commentary of the Russian embassy, which put the issue of the Hungarian minority in Transcarpathia and the lack of publicity of the Hungarian–Ukrainian agreements at the centre. ATV, for its part, wrote about the European Commission’s latest instalment of EUR 3.3 billion paid to Ukraine. In the economic band, Portfolio reported the formation of the C8 in a short, descriptive news item. The pro-government conservative band (Magyar Nemzet, Mandiner) did not carry the topic among its leading news in MIAK’s press monitoring today. A gap common to the whole spectrum is that no source asked how Hungary will vote on Monday.

6.2 Facts and data

Data Value Source
Signing of the Graham Act 18 September 2026 (Friday) Al Jazeera, Népszava (MTI), 19 September 2026
Official name of the law Lindsey O Graham Sanctioning Russia and Iran Act of 2026 Al Jazeera
Upper limit of the tariff authorisation up to 100% Al Jazeera, Népszava (MTI)
Targets of the tariff authorisation the five largest buyers of Russian oil and gas; according to Népszava (MTI), also the five countries that do most to help circumvention Al Jazeera; Népszava (MTI)
Adoption by the House of Representatives 16 September 2026, with 58 Democratic votes in favour Al Jazeera
Hungary’s annual purchases of Russian crude oil some 5 million tonnes, the fifth-largest market for Russian oil Balkan Insight (BIRN), 16 September 2026 (updated 17 September)
Size of the EU’s Russia sanctions list some 3,000 names EUobserver, 18 September 2026
Expiry of the list without renewal midnight on Tuesday (22 September); the original deadline was 15 September EUobserver
Member states requesting delisting France (one oligarch), Luxembourg (another oligarch); Slovakia supports France EUobserver
EU phase-out target dates Russian pipeline gas: October 2027; Russian crude oil: end of 2027 the European Commission’s objective as summarised by Balkan Insight
First C8 summit and Hungarian representation 18 September 2026; Antal Heizer, head of the embassy in Kyiv Ministry of Foreign Affairs to HVG and Telex; Népszava

Two data points require a separate note. One is the scope of the tariff authorisation: Al Jazeera mentions only the five largest buyers, the MTI material published by Népszava also the five countries helping circumvention, while Balkan Insight gives no number. MIAK’s August analysis, based on reports published about the Senate version, also described a European exemption rule and a presidential waiver power; whether these are unchanged in the final text cannot be verified from today’s reports. MIAK was unable to consult the official text directly by the time this article was finalised. The other is the Hungarian ranking: according to BIRN’s wording, “fifth-largest market” refers to Russian oil, whereas according to the press the law mentions oil and gas together, so it is not known by what measure the list of the five buyers would be compiled.

6.3 Policy dimensions

  • Foreign policy (programme points) — the centre of gravity of the topic: KP3 (transparent foreign policy) covers the public reasoning of the Council vote and the contact log, KP4 (principled pragmatism) the stability of the list as a Hungarian interest, KP17 (issue-based coalition-building in the EU) the initiative on the delisting procedure, KP8 (economic diplomacy integration) the coordination of the Washington and Brussels channels, and KP23 (alliance credibility audit) the measurement of how perceptions of the Hungarian voting pattern change;
  • Economy (programme points) — G25 (energy-price shock preparedness plan) is affected because a tariff decision also targeting Hungary, or an accelerated decoupling from Russian energy, has price effects that must be planned for in advance;
  • Environment and climate (programme points) — K7 (energy-market shock resilience) is the background condition that reduces tariff exposure in the long term: the smaller the share of Russian sources, the less likely Hungary is to be among the five largest buyers.

6.4 Literature in detail

6.4.1 Henry Kissinger: White House Years

In the first volume of his memoirs, Kissinger presents linkage as one of the basic principles of the Nixon administration’s Soviet policy, and precisely delimits its two meanings:

“In our view, linkage existed in two forms: first, when a diplomat deliberately links two separate objectives in a negotiation, using one as leverage on the other; or by virtue of reality, because in an interdependent world the actions of a major power are inevitably related and have consequences beyond the issue or region immediately concerned.”

In other words: linkage is on the one hand a deliberate negotiating device, when one objective is used as a pledge for another, and on the other hand a given of reality, because an actor’s moves have consequences beyond the issue at hand. According to the author, the second meaning is the more important: weakness shown in one region also undermines credibility in the others. Another chapter of the volume describes how Moscow tried to deal with the Western allies one by one — offering détente to some while remaining rigid towards others — and how the alliance responded. The alliance embedded West German Ostpolitik in a negotiating system that strengthened Bonn’s position but also set limits beyond which it could not go without the allies’ agreement. Both theses apply to the present situation. Linking the EU vote to a US tariff exemption would be self-defeating in the first, deliberate sense, while the connection of credibility in the second, real sense is unavoidable. And the small member state’s protection is the common framework rather than a separate deal, which proposal 3.3 designates in consultation through the Commission. The volume is a copyrighted source, so the summary of the second thesis is a paraphrase.

📖 Source: Henry Kissinger: White House Years

6.4.2 Kristian L. Nielsen: EU Soft Power and the Capability-Expectations Gap

In his study published in the Journal of Contemporary European Research, Nielsen starts from an old concept of the British political scientist Christopher Hill, the capability-expectations gap. According to this, the EU promises and elicits from others more action than it is actually able to deliver. Nielsen argues that the Union’s “soft”, attraction-based influence does not substitute for the capacity to act, and that failures to deliver themselves erode this influence:

“But image, reputation and credibility are built up over time, and will invariably be seen in the light of past deeds (or lack thereof). Tomorrow’s perceptions of the EU will be based on others’ experiences of its doings today.”

In other words: image, reputation and credibility are built over time and are always judged in the light of past deeds — or their absence; how the EU is perceived tomorrow depends on what others experience of its deeds today. The expiry of the sanctions list would be exactly such an experience: not the failure to adopt a new measure, but the collapse of an existing instrument, maintained for years, because of an internal bargain. Proposals 3.1 and 3.2 are therefore not merely procedural fine-tuning, but a way of preventing the gap between capability and expectations from opening at the least justified point — through the Union’s own fault.

📖 Source: Kristian L. Nielsen: EU Soft Power and the Capability-Expectations Gap (Journal of Contemporary European Research, 2013)

6.4.3 The EU founding treaties: TEU and TFEU

Under Article 31(1) of the Treaty on European Union (TEU), the Council adopts common foreign and security policy decisions unanimously as a general rule — this is the rule that puts the current renewal in the hands of a single member state. The same paragraph makes constructive abstention possible, that is, a member state may stay out of the decision by means of a formal declaration without preventing it:

“In that case, it shall not be obliged to apply the decision, but shall accept that the decision commits the Union.”

For the current renewal this means that a member state with reservations also has a path that costs less than blocking. Under Article 215 of the Treaty on the Functioning of the European Union (TFEU), the Council may also impose restrictive measures against natural and legal persons, for which the Treaty also prescribes the necessary legal safeguards. Article 275 in turn provides that the Court of Justice of the European Union, whose jurisdiction is otherwise limited in the field of the common foreign and security policy, may review the legality of such decisions concerning persons. There is therefore a judicial route for remedying an unlawful listing, which is the principled basis of proposal 3.2. Finally, Article 3(1)(e) TFEU assigns the common commercial policy to the Union’s exclusive competence, and under Article 207 agreements concerning tariffs are negotiated by the Commission on the basis of an authorisation from the Council. A member state therefore cannot conclude a separate tariff agreement with a third country — this is the legal starting point of proposal 3.3.

📖 Source: European Union: Consolidated versions of the Treaty on European Union and the Treaty on the Functioning of the European Union

6.5 International comparison

There are several working models of a separate, evidence-based procedure for delisting. In 2009, by Resolution 1904, the UN Security Council established the Office of the Ombudsperson attached to the list of the sanctions regime against al-Qaida, which listed persons can approach directly and which prepares reasoned recommendations on delisting requests for the committee. The establishment of the office was also prompted by the 2008 Kadi judgment of the Court of Justice of the European Union, which, on grounds of infringement of the rights of the defence, annulled the EU regulation transposing the UN list as regards the person concerned. In the United States, the Treasury’s Office of Foreign Assets Control (OFAC) examines delisting in a petition procedure regulated at the level of regulations, independently of the maintenance of the list as a whole. The common lesson is that delisting can be handled objectively where it has its own procedure — and becomes a political bargaining chip where it is packaged into the decision on the survival of the entire system. Kissinger’s experience fits here too: the common framework does not eliminate the participants’ room for manoeuvre, but marks where individual bargaining ends.

Foreign policy

  • KP3 — Transparent foreign policy
  • KP4 — Doctrine of principled pragmatism
  • KP8 — Economic diplomacy integration
  • KP17 — Issue-based coalition-building in the EU
  • KP23 — Alliance credibility audit (annual)

Economy

  • G25 — Energy-price shock preparedness plan

Environment and climate

  • K7 — Energy-market shock resilience

Proposed new programme point: Freedom from blackmail in sanctions renewals: a separate, time-limited and reasoned procedure for delisting — for the Foreign policy area.

6.7 List of sources

Press sources (MIAK foreign press monitor, 19 September 2026 — topic 1; MIAK press monitor, 19 September 2026 — topic 4):

Knowledge-base references (books):

  • 📖 Henry Kissinger: White House Years
  • 📖 Kristian L. Nielsen: EU Soft Power and the Capability-Expectations Gap
  • 📖 European Union: Consolidated versions of the Treaty on European Union and the Treaty on the Functioning of the European Union

MIAK internal materials:

  • MIAK policy area: Foreign policy (programme points; programme point ID: KP3, KP4, KP8, KP17, KP23)
  • MIAK policy area: Foreign policy (background material)
  • MIAK policy area: Economy (programme points; programme point ID: G25)
  • MIAK policy area: Environment and climate (programme points; programme point ID: K7)
  • MIAK foreign press monitor, 19 September 2026 — topic 1, score: 89/100
  • MIAK press monitor, 19 September 2026 — topic 4, score: 82/100

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