Oil & Gas in 2026: Trade Policy

Tariff Policies Evolve as Russian Sanctions Harden

This article is part of the "Oil & Gas in 2026: Emerging Trends & Predictions" report. For the full report, click here.

Since the day President Trump arrived at the White House, international trade policy has been at the top of his agenda, starting with the release of the “America First Trade Policy Memo,” which he released on the first day of his second term. Following through on campaign promises, the President has sought to lower America’s trade deficit by imposing tariffs on a broad range of products from every nation on earth. He has imposed those tariffs for purposes of national security and also leveraged duties in trade negotiations to secure deals with trading partners around the world. Many of these deals have included significant purchase commitments affecting the oil & gas industry.

Moving into 2026, while that tariff landscape appears to be more settled than it was at the start of 2025, there are still a number of active negotiations with foreign trading partners that could lead to changes in tariff levels, as well changes to substantive trade rules and purchasing commitments related to oil & gas. As a result, trade policy considerations must be front of mind for oil & gas companies when transacting cross-border. With energy dominance a key pillar of the Administration’s broader economic and national security strategies, the industry is firmly in the spotlight when it comes to the use of trade policy and trade tools going into 2026 as well. 

Evolving Tariff Policies

Since January 20, 2025, President Trump has imposed sweeping tariffs on nearly every product from every country for a variety of reasons, including for purposes of national security and onshoring supply chains, to rebalance the U.S. trade deficit, to incentive domestic investment and manufacturing, and for leverage with trading partners in negotiations on trade and other issues. 

Many of these tariffs have been imposed on the basis of the International Emergency Economic Powers Act (IEEPA) that (as of the date of this report) remain subject to Supreme Court review, although a number of other authorities have also been used as the basis for these measures, including Section 232 of the Trade Act of 1962 and Section 301 of the Trade Act of 1974. Key examples impacting the oil & gas industry include:

• Steel and Aluminum Tariffs: In June 2025, Section 232 duties on steel and aluminum imports were doubled from 25% to 50%. The President also created an “inclusion” process to broaden the scope of the tariffs to hundreds of derivative products containing steel and aluminum, including many inputs for oil & gas infrastructure projects. The Administration also removed virtually all previous country-specific exemptions and product exclusions that had been granted during the first Trump Administration, although it’s possible that we’ll see some country-specific exemptions with trading partners like Canada and Mexico sometime this year as part of the U.S.-Canada-Mexico Agreement (USMCA) review.
  
  
• Bilateral Deals Secure Concessions: A swathe of bilateral trade deals negotiated throughout 2025 in the wake of the “reciprocal tariffs” announced in April have introduced a complex array of country-specific concessions related to oil & gas. For example, the European Union, Indonesia and Japan all agreed to significant purchase and investment commitments for U.S. energy as part of a package of concessions in exchange for lower tariffs. Malaysia also agreed to LNG purchase commitments as part of its trade agreement with the U.S. in October 2025. We would expect to see additional similar commitments from trading partners negotiating with the Administration in 2026.
  
  

• USMCA Agreement Up for Renegotiation: In March 2025, President Trump briefly implemented a 25% tariff on all imports from Canada and Mexico, with an exemption for Canadian energy resources and minerals, which instead faced a 10% tariff. The President ultimately paused those tariffs after Canada and Mexico agreed to take certain action to address fentanyl and migration concerns flagged by the Administration. Tariff negotiations with both countries are ongoing and could impact the upcoming 2026 review of the  USMCA. One area of focus for those negotiations will be Mexico’s recent energy reforms, which have drawn concerns from U.S. oil & gas companies.

Russia

• Russian Oil Tariffs: The Trump Administration has also used tariffs as a key tenet of its foreign policy efforts related to Russia. For example, in an August 6, 2025 Executive Order, the President imposed 25% tariffs on India for continuing to buy Russian oil and indirectly funding Russia’s war. These tariffs were on top of an existing 25% reciprocal tariff on Indian imports, which still remain subject to a 50% tariff going into 2026. In another example, in September 2025, President Trump called on all NATO countries to place a tariff between 50% and 100% tariff on imports from China for Russian oil purchases. Such a policy had not been implemented at year end.
  
  

• U.S. Sanctions Policy Moves: In October 2025, the Office of Foreign Assets Control (OFAC) imposed sanctions on Rosneft and Lukoil, Russia’s two largest oil companies, which followed the President’s attempts to settle the Russia-Ukraine war in August 2025. This move followed 10 months of not imposing additional sanctions measures on Russia, a strategy the Administration had employed in an effort to pivot from the Biden Administration’s approach to Russia. The decision to move forward with sanctions evinces a possible return to a more traditional approach to push for an end to the war in Ukraine in 2026, at least when it comes to trade tools.
  
  
• EU and U.K. Oil Sanctions: The U.K. and EU have both continued to strengthen their sanctions targeting Russia’s energy sector, with the EU import ban on refined products made from Russian origin crude taking effect in January 2026. A similar U.K. import ban has been announced but has yet to be implemented. This prohibition has raised practical questions about its implementation, in particular, how blends of Russian and non-Russian origin refined products created outside of Russia should be treated, with strict rules requiring proof of non-Russian origin crude for refined products.
  
  In October 2025, the EU also implemented a prohibition on the purchase, transfer and import of Russian LNG which will enter into force on April 25, 2026, although for certain long-term contracts this deadline has been extended until January 1, 2027. The U.K. already banned the import of Russian LNG in 2023 but in November, announced a ban on maritime transport and related services, like shipping and insurance, for Russian LNG exports to third countries.
  
  Further, in October the U.K. coordinated with the U.S. in implementing its own sanctions against Russia’s two largest oil companies, Rosneft and Lukoil, making all dealings with both entities off-limits unless licensed.
  
  Lukoil’s global reach, particularly across Europe, means the restrictions have implications for many industry players, that were required to immediately wind down business with the company and its subsidiaries unless their activities could benefit from one of the general licenses issued by the U.K.’s Office of Financial Sanctions Implementation (OFSI) and/or the U.S. OFAC.
  
  Lukoil’s attempt to sell off its non-Russian assets to Gunvor was thwarted in late 2025 when the U.S. Government opposed the deal. Several refineries, such as Lukoil’s refinery in Bulgaria, the largest in the Balkans, have been left in a precarious situation, with potential buyers hesitant to proceed due to the potential impact of U.K. and U.S. sanctions.

Venezuela

On January 3, 2026, the U.S. conducted a successful military operation to capture Venezuela’s de facto leader, Nicolás Maduro, and transport him to New York to face various criminal charges in U.S. federal court. Venezuela’s situation remains uncertain and volatile, but a shift toward a pro-U.S. political and economic climate is now more likely. Such a shift could involve the easing of U.S. sanctions on Venezuela, which have been nearly comprehensive in scope since the first Trump Administration.

In fact, the U.S. government has already announced plans for a U.S.-Venezuela “energy deal” involving Venezuelan oil exports to the U.S. and sales proceeds being used to purchase American goods in support of Venezuelan humanitarian relief and economic reconstruction. If cooperation between the two countries grows, the U. S. could gradually ease sanctions on Venezuela via targeted licenses or broader policy changes, some of which would be necessary to allow for U.S. investment in the energy sector to flow.  

Further progress will depend on several factors, including: the ongoing willingness of the Venezuelan government to cooperate; the willingness of U.S. companies to operate in Venezuela despite substantial political, corruption, anti-money laundering, and other risks; internal Venezuelan political, economic and social stability; reactions from foreign governments that oppose U.S. intervention in Venezuela; and domestic U.S. politics surrounding the 2026 congressional midterm elections.

The Middle East

The major oil & gas companies in the Middle East continue to prioritize energy transition policies, with state-owned entities investing in renewable technologies to meet net zero commitments and energy enhancement goals. Gulf leaders broadly welcomed Trump’s election as the next U.S. president given his pro-hydrocarbon stance and both sovereign wealth funds and national oil companies from the region have been exploring investment opportunities in the U.S. over the past year.

Qatar has led opposition to the EU’s new labelling and sustainability regulations for LNG imports, arguing the rules make it hard for the Gulf state to continue supplying Europe. The EU’s Corporate Sustainability Due Diligence Directive requires companies to identify, prevent and address environment and human rights risks in their supply chains, which QatarEnergy says exposes exporters to significant risk. Qatar is a key supplier to the continent, currently providing around 13% of the EU’s LNG imports.

Finally, the removal of U.S., U.K. and EU sanctions against Syria in 2025, following the fall of the Assad regime, opens up potential energy market opportunities. In late 2025, several leading Saudi oil & gas companies secured contracts to develop Syrian oil & gas fields and further foreign investment could yet be a theme through 2026.

Conclusion

Trade Policy Takes Center Stage for Oil & Gas Investors

With the current U.S. administration increasingly leveraging tariff policy as a key economic and foreign policy tool, and the energy industry in the spotlight of those efforts, oil & gas companies can now afford to do very little without close regard to trade policy considerations.

Going into 2026, U.S. tariff policies continue to evolve, including with a potential shift in tariff authority depending on the results of the U.S. Supreme Court IEEPA tariff case. We also anticipate that additional bilateral deals will be reached, which could impact tariffs, non-tariff barriers and purchasing commitments related to oil & gas, as well as potential shifts in current or new product tariffs under Section 232. 

With the sanctions landscape also still transitory as it relates to Russia’s full-scale invasion of Ukraine and the U.S. intervention in Venezuela, there is much to be taken into account when entering into oil & gas investments globally.

As we move through 2026, we do expect somewhat more solidity when it comes to tariffs and trade policy, but the situation is still exceptionally dynamic. Careful attention to these policies will allow dealmakers to more adequately assess risks and navigate a highly dynamic environment in order to transact.