Photo of Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

On January 29, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 46, “Authorizing Certain Activities Involving Venezuelan-Origin Oil.”  The general license authorizes all transactions prohibited by the Venezuela Sanctions Regulations, 31 C.F.R part 591, including those involving the Government of Venezuela, Petróleos de Venezuela, S.A. (PdVSA)

On February 2, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5U, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After March 20, 2026,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO

On January 29, 2026, the Office of the U.S. Trade Representative (USTR) announced that the United States and El Salvador have signed the U.S.-El Salvador Agreement on Reciprocal Trade (Agreement).  According to Ambassador Jamieson Greer, the USTR:  “Today’s signing of the first Agreement on Reciprocal Trade in the Western Hemisphere will further strengthen markets for

On January 30, 2026, the Office of the U.S. Trade Representative (USTR) announced that the United States and Guatemala have signed the United States–Guatemala Agreement on Reciprocal Trade (Agreement).  According to Ambassador Jamieson Greer, the USTR:  “Today’s signing of another Agreement on Reciprocal Trade in the Western Hemisphere addresses trade barriers facing American workers and

On January 15, 2026, the United States and Taiwan agreed to a trade deal to establish “a strategic economic partnership … to decisively strengthen U.S. domestic semiconductor supply chains and secure America’s technological and industrial leadership.” While the text and full terms of the trade deal were not released, the Department of Commerce released a

On January 6, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended Russia-related General License (GL) 13 by issuing a revised GL 13P, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import duties

  • Hundreds of new cases have been filed at the U.S. Court of International Trade (“CIT”) since the November 5, 2025 oral arguments at the U.S. Supreme Court (“SCOTUS”) in the appeal challenging the legality of the International Emergency Economic Powers Act (“IEEPA”) as the statutory authority to impose tariffs and seeking to preserve

On December 31, 2025, President Donald Trump issued a proclamation announcing that he was delaying an increase in the duty rates for imports of upholstered furniture, kitchen cabinets, and vanities. Referencing “productive negotiations of agreements with multiple countries to address the threatened impairment of the national security with respect to imports of wood products,” President

On December 23, 2025, the United States Trade Representative (USTR) determined that China’s acts, policies, and practices related to targeting of the semiconductor industry for dominance are actionable under Section 301 of the Trade Act of 1974. Accordingly, the USTR will take tariff action on U.S. imports of semiconductors from China, with an initial tariff

On December 18, 2025, the Department of Commerce’s International Trade Administration (ITA) issued a notice that the United States was implementing certain tariff-related elements of the Framework for a United States-Switzerland-Liechtenstein Agreement on Fair, Balanced, and Reciprocal Trade. The framework for this agreement was announced in mid-November 2025 and covered various areas of negotiations addressing