President Trump meets with Russian President Vladimir Putin at the G20 Summit in Hamburg on July 7. (Evan Vucci/AP)

The Trump administration is belatedly working to implement the first part of Russia-related sanctions mandated by legislation President Trump signed almost three months ago. Having blown through the first deadline, the administration is now faced with a skeptical Congress preparing a range of action-forcing measures.

One would think an administration besieged by what it claims are unfair Russia controversies would take pains to avoid being seen as failing to implement actions mandated by Congress against the regime of Vladimir Putin. But not the Trump administration. President Trump signed the Countering America’s Adversaries Through Sanctions Act on Aug. 2. The deadline for implementing a host of Russia-related sanctions was Oct. 1.

The State Department, where the bottleneck is, insists it is working as fast as possible. But Congress is not taking the administration’s word for it. A senior Democratic aide told me told me bipartisan discussions are now underway in the Senate to try and increase the pressure – through a possible letter with dozens of signatures, a press strategy to raise the volume and a possible Senate resolution chastising the administration for failing to meet the deadline.

There are some signs of movement. A senior Republican aide told me the State Department has briefed Congress that it is making progress compiling a list of foreign entities that might fall under the new sanctions law because they have links to the Russian defense or intelligence sectors. That’s by far the most significant and complicated aspect of the new law.

According to the measure, the administration is required to sanction any foreign entities that engage in significant transactions with the Russian Federation’s defense and intelligence sectors. That now includes the government of Turkey, which is buying the Russian S-400 anti-aircraft missile system. It might also soon include Saudi Arabia, which agreed to buy the same system from Moscow earlier this month.

“There are important allies and partners in NATO, other parts of the world, who need specific guidance so that they do not run afoul of the sanctions act,” Secretary of State Rex Tillerson said last week.

Defense Secretary Jim Mattis is said to have concerns about the law cutting off U.S. weapons sales to Turkey, which is a member of NATO and an ally in the fight against ISIS. The Trump administration also has upwards of $100 billion worth of arms sales in the works with Riyadh, a major result from Trump’s trip there.

But finishing the list and the guidance to go with it is just the first step. Lawmakers are worried that the State Department plans to roll out the sanctions only a couple of entities at a time, the Senate GOP aide said, diluting the effects. Plus, it could still be weeks until the first announcements are made.

On Capitol Hill, the pressure campaign is being led by Senate Foreign Relations Committee ranking Democrat Ben Cardin (D-Md.) and Senate Armed Services Committee Chairman John McCain (R-Ariz.) Cardin said this week he might impede Trump’s legislative agenda on other issues in order to compel the administration to implement the Russian sanctions fully.

“We have hearings, we have appropriations bills—there are a lot of things we can express ourselves on,” he said. “And we’ll use every opportunity we can.”

Sen. Bob Corker (R-Tenn.), who has no reason to defend the Trump White House at this point, said Wednesday he honestly doesn’t know whether the delays are driven by the Trump administration’s reluctance to implement sanctions Congress forced or just regular bureaucratic intransigence.

“It is very difficult to implement and once you do it, it’s in place and you have to make sure there aren’t unintended consequences,” he told CNN, quickly adding, “The [National Security Council] waited until the very last minute to get this going.”

There is lots of speculation – but no direct evidence – that the Trump administration is dragging its feet because it doesn’t want to upset diplomatic engagement with Russia or because the president seems to defend Putin every time he has the chance.

“I think that the Trump administration is slow when it comes to Russia,” Sen. Lindsey Graham (R-S.C.) said Sunday on Meet The Press when asked about the sanctions delays. “They have a blind spot on Russia I still can’t figure out.”

The real test of the Trump administration will not be when, but how it implements the Russia sanctions. Lawmakers will be watching to see if the State Department issues guidance that lets offenders like Turkey off the hook, rolls out the sanctions so slowly as to dilute their effect, or fails to follow up with strict enforcement. Any of these would show Trump doesn’t intend to follow congressional intent.

It’s possible the Trump team is just slow and will eventually follow through on punishing Russia for interfering in our elections, which is what the sanctions were about. But the administration is not off to a great start and Congress is not going to let this go.