HR-4346-119
Placed on the Union Calendar, Calendar No. 277.
Sponsored by Zachary Nunn (R-IA)
What it does
The PEACE Act of 2025 would require the Secretary of the Treasury, within 180 days, to prohibit or impose strict conditions on U.S. correspondent and payable-through bank accounts held by foreign financial institutions that provide significant financial services to sanctioned Russian entities or persons operating in Russia's energy sector. It would also require the Treasury Secretary to seize and transfer Russian sovereign assets held in U.S. financial institutions — including funds of Russia's Central Bank, National Wealth Fund, and Ministry of Finance — into a Ukraine Support Fund for reconstruction or defense purchases. The bill includes presidential waiver authority and a 5-year sunset provision, terminating earlier if Russia ceases destabilizing activities in Ukraine.
Who benefits
Ukraine's government, which would receive seized Russian assets for reconstruction and defense. Ukrainian civilians whose infrastructure has been targeted by Russian strikes. U.S. and allied defense contractors supplying weapons to Ukraine. Countries and businesses seeking to pressure Russia toward a negotiated settlement. U.S. financial institutions that comply and avoid penalties. Advocates for stronger congressional oversight of foreign policy sanctions.
Who is hurt
Foreign financial institutions — particularly in countries like China, India, Turkey, and UAE — that currently process transactions involving sanctioned Russian entities and would face loss of U.S. market access. Russian state energy companies (Gazprom, Rosneft, Lukoil) and their international business partners. U.S. importers and businesses with supply chains touching Russian energy markets. Third-country governments whose banks could be cut off from the U.S. financial system. Holders of Russian sovereign assets in U.S. institutions, whose property would be seized. The executive branch, which would lose some discretion over the pace and scope of Russia sanctions.
Supporters argue
Supporters argue that Russia has continued large-scale military strikes on Ukrainian civilians — including its largest aerial assault of the war on May 25, 2025 — despite repeated diplomatic overtures, demonstrating that economic pressure is necessary to change Russian behavior. They contend that cutting off foreign banks that service sanctioned Russian entities and seizing sovereign assets already frozen under Executive Order 14024 would impose meaningful financial costs on Russia's war economy while aligning with actions already taken by G7 allies under the REPO for Ukrainians Act framework.
Opponents argue
Opponents argue that mandatory, congressionally-directed sanctions constrain the President's constitutional authority to conduct foreign policy and negotiate a peace settlement, potentially hardening Russian positions at a critical diplomatic moment. They contend that secondary sanctions on third-country banks risk alienating key partners — such as India and Turkey — whose cooperation is needed for a durable ceasefire, and that seizing sovereign assets without a final peace agreement could set a precedent that destabilizes international confidence in U.S. financial institutions as a safe haven for foreign reserves.
Constitutional context
The Foreign Commerce Clause (Art. I, §8, cl. 3) gives Congress broad authority to regulate international financial transactions, and the International Emergency Economic Powers Act (IEEPA) provides the executive branch authority to impose sanctions — but this bill would mandate specific Treasury actions, testing the boundary between congressional direction and executive discretion in foreign affairs. The Zivotofsky v. Kerry (2015) framework recognizes exclusive presidential recognition and foreign policy powers, which could be invoked to challenge mandatory congressional directives that constrain diplomatic flexibility.
Checks and balances
Congress gains authority by mandating specific Treasury sanctions actions; the executive branch retains a check through presidential waiver authority (renewable every 180 days) and the ability to trigger early termination by certifying Russia has ceased destabilizing activities.
Historical precedent
The Countering America's Adversaries Through Sanctions Act (CAATSA, 2017) similarly imposed mandatory, congressionally-directed sanctions on Russia with limited presidential waiver authority, and was challenged on separation-of-powers grounds but upheld as a valid exercise of congressional foreign commerce and appropriations power.