A complete substitute amendment. v2 introduces a new operative section, Section 6, which mandates the seizure and transfer of certain Russian sovereign assets held by U.S. financial institutions to the Ukraine Support Fund. Additionally, v2 refines the scope of sanctions by narrowing the list of applicable Executive Orders in Section 3(a)(1)(A) and adds a new finding in Section 2.
PEACE Act of 2025
- Sponsor
- Rep. Nunn, Zachary [R-IA-3]
- Committees
- Financial Services Committee (primary)
- Last action
- Oct 3, 2025
Bottom line
This bill aims to intensify financial pressure on Russia to compel a peaceful resolution to the conflict in Ukraine by targeting financial institutions supporting Russian sanctioned entities and seizing Russian sovereign assets.
What it actually does
This bill mandates the Secretary of the Treasury to impose strict sanctions on foreign financial institutions that provide significant services to sanctioned Russian entities or those operating in Russia's energy sector. It also requires the seizure and transfer of certain Russian sovereign assets held in U.S. financial institutions to the Ukraine Support Fund, with provisions for presidential waivers under specific conditions.
Proponents argue
Proponents argue that the bill provides necessary economic leverage to force Russia to the negotiating table, supports Ukraine's defense and recovery by utilizing seized Russian assets, and demonstrates strong U.S. resolve against ongoing Russian aggression and obstruction of peace efforts.
Opponents contend
Opponents might argue that such aggressive financial measures could destabilize global financial markets, provoke further escalation from Russia, or complicate future diplomatic efforts. Concerns may also be raised about the precedent of seizing sovereign assets and its potential long-term implications for international law and financial stability.
The bill is relatively concise and clearly structured, allowing for a thorough understanding within a reasonable timeframe for an informed reader.
Section 3(a)
Mandatory Sanctions on Foreign Financial Institutions Supporting Russia
This provision requires the Secretary of the Treasury to implement regulations that either prohibit or impose strict conditions on foreign financial institutions from opening or maintaining correspondent or payable-through accounts in the United States. This applies if these institutions knowingly provide significant financial services to specific sanctioned Russian entities, including those designated under Executive Order 14024, those subject to Directive 2 or listed in Annex 1 of Directive 3 under that Executive Order, or any foreign person identified by the Secretary as operating in the Russian Federation's energy sector.
Supporters argue
Proponents argue this provision directly targets Russia's financial lifelines, increasing pressure to end the conflict by making it harder for Russia to fund its war efforts and for its key entities to access global financial systems. It aims to cut off financial support for Russian aggression.
Critics contend
Opponents might argue it could lead to unintended consequences for global financial stability, push Russia towards alternative financial systems outside U.S. influence, or harm allied nations whose financial institutions have legitimate ties to the broader Russian economy, potentially complicating international cooperation.
Tradeoffs
The provision balances the goal of maximizing economic pressure on Russia with the potential for ripple effects on global financial markets and diplomatic relations with countries whose financial institutions may be impacted.
Section 3(b)
Civil and Criminal Penalties for Sanctions Violations
This section establishes the penalties for violating the new sanctions regulations. A person who violates, attempts to violate, conspires to violate, or causes a violation of these regulations is subject to a civil penalty. This penalty can be up to $377,700 or twice the amount of the transaction that forms the basis of the violation, whichever is greater. Additionally, a person who willfully commits, attempts, or conspires to commit a violation, or aids in its commission, faces criminal penalties, including a fine of up to $1,000,000, or if a natural person, imprisonment for up to 20 years, or both.
Section 4
Treasury Report on Russian Energy Sector Entities
This section requires the Secretary of the Treasury, within 90 days of the Act's enactment, to submit a report to the House Committee on Financial Services and the Senate Committee on Banking, Housing, and Urban Affairs. The report must determine whether Gazprom, Rosneft, and Lukoil are considered foreign persons operating in the energy sector of the Russian Federation. Such a determination would make them subject to the sanctions outlined in Section 3(a)(4) of the Act, potentially leading to restrictions on foreign financial institutions dealing with them.
Section 5
Presidential Waiver Authority for Sanctions
This section grants the President the authority to waive the requirements of Section 3(a) (regarding sanctions on foreign financial institutions) for periods not exceeding 180 days at a time. Such a waiver can be issued if the President reports to Congress that it advances the objective of resolving the national emergency described in Executive Order 14024, or if the waiver is important to the national interest of the United States. In the latter case, a detailed explanation of the reasons must be provided to Congress.
Section 6(a)
Seizure and Transfer of Covered Russian Resources
This provision mandates that within 90 days of the Act's enactment, the Secretary of the Treasury must seize, confiscate, transfer, or vest any "covered Russian resources" held by a United States financial institution. These resources include funds and property belonging to the Central Bank of the Russian Federation, the Russian National Wealth Fund, or the Ministry of Finance of the Russian Federation that are located in the U.S. The resulting funds are to be deposited into the Ukraine Support Fund, established under the REPO for Ukrainians Act, and can be used for purposes specified in that Act or for purchasing defense articles for the Government of Ukraine.
Section 6(b)
Presidential Waiver for Russian Asset Transfer
This section allows the President to waive the mandatory asset transfer requirements of Section 6(a) for periods of up to 180 days at a time, with a cumulative limit of one year. This waiver can be exercised if the President reports to Congress in writing that the Government of the Russian Federation is taking meaningful steps to cease its destabilizing activities with respect to Ukraine's sovereignty and territorial integrity, or if the waiver is deemed important to the national interest of the United States.
Section 7
Act Termination Conditions
This section specifies the conditions under which the entire Act will cease to have force or effect. The Act will terminate on the earlier of two dates: either 30 days after the President reports to Congress that the Russian Federation has ceased its destabilizing activities with respect to the sovereignty and territorial integrity of Ukraine, or 5 years after the date of the Act's enactment. This ensures the measures are temporary and tied to the resolution of the conflict.
Grants the Secretary of the Treasury broad authority to designate any foreign person operating in the Russian energy sector for sanctions, beyond those already specified or listed in existing executive orders and directives.
Section 3(a)(4)
Why it matters:This is standard legislative practice to provide administrative agencies with necessary flexibility and discretion to adapt to evolving circumstances without requiring new legislation for every specific entity. It allows for dynamic targeting of new or emerging actors in the energy sector.
Case for: Supporters argue this flexibility is crucial for the Treasury to respond dynamically to Russia's evolving economic strategies and ensure the sanctions remain effective against new or emerging actors in the energy sector, preventing circumvention of the sanctions regime.
Case against: Critics might argue this grants excessive, unchecked power to the executive branch, potentially leading to arbitrary designations or designations based on political rather than purely economic criteria, without explicit congressional approval for each target, raising concerns about due process.
Estimated impact: Potentially significant, as the energy sector is a primary source of Russian revenue, and this clause allows for continuous targeting of new entities, thereby expanding the reach of U.S. sanctions.
Incorporates by reference the President's authorities under section 104(b) of the REPO for Ukrainians Act (22 U.S.C. 9521 note) for the seizure, confiscation, transfer, or vesting of covered Russian resources, granting these same powers to the Secretary of the Treasury.
Section 6(a)(2)
Why it matters:This is standard legislative practice to avoid reprinting lengthy statutory language and to ensure consistency with existing legal frameworks. It streamlines the bill by leveraging established legal authorities.
Case for: Supporters argue this streamlines the legislative process and ensures that the asset seizure mechanism aligns with established legal precedents and authorities already granted to the executive branch for similar actions, providing a clear legal basis.
Case against: Critics might argue that incorporating by reference complex legal authorities makes the bill less transparent, requiring readers to consult external statutes to fully grasp the powers being granted, potentially obscuring the full implications of the asset seizure from casual review.
Estimated impact: Significant, as it defines the legal scope and methods for seizing potentially billions in Russian assets, impacting the legal framework for sovereign asset protection and international finance.