On November 5, 2025, the U.S. Supreme Court heard oral arguments in a high-profile consolidated appeal challenging whether President Donald Trump lawfully invoked the International Emergency Economic Powers Act (“IEEPA”) to impose tariffs. The cases challenge two sets of tariffs Trump implemented earlier this year: (1) tariffs against Canada, China, and Mexico in response to
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.
DDTC Amends ITAR to Remove Arms Embargo on Cambodia
On November 7, 2025, the State Department’s Directorate of Defense Trade Controls (DDTC) issued a Final Rule amending 22 C.F.R. § 126.1 to remove the Kingdom of Cambodia as a proscribed country under the International Traffic in Arms Regulations (ITAR). Effective immediately, requests for the export of defense articles and services to Cambodia will now…
President Trump Issues Executive Orders Addressing China Tariff Rates
Following the October 31, 2025 meeting between President Donald Trump and Chinese President Xi Jinping, President Trump on November 4, 2025, issued two Executive Orders related to and reducing certain tariffs on China.
In the first Executive Order, President Trump modified duties on imports from China. In February and March 2025, in response to…
Customs Broker Pleads Guilty to Conspiracy Charge in Latest FCPA Prosecution Following DOJ’s Recent Enforcement Restart
On October 23, 2025, a customs broker operating in both the United States and Mexico pleaded guilty to conspiring to violate the Foreign Corrupt Practices Act (FCPA) before a magistrate judge in the U.S. District Court for the Western District of Texas. Although the plea agreement remains under seal, it was approved and adopted the…
United States and Malaysia Sign Reciprocal Trade Agreement
On October 26, 2025, the United States and the Government of Malaysia signed an Agreement on Reciprocal Trade. The agreement is intended to “enhance reciprocity in their bilateral trade relationship by addressing tariff and non-tariff barriers;” and seeks to “strengthen their commercial relationship through increased alignment on national and regional economic security matters.” …
United States and Cambodia Sign Reciprocal Trade Agreement
On October 26, 2025, the United States and the Kingdom of Cambodia signed an Agreement on Reciprocal Trade. The agreement is intended to “enhance reciprocity in their bilateral trade relationship by addressing tariff and non-tariff barriers;” and seeks to “strengthen their commercial relationship through increased alignment on national and regional economic security matters.” …
United States and Vietnam Agree to Framework Agreement on Reciprocal Trade
- Vietnam’s preferential market access for substantially all U.S. industrial and agricultural exports.
- The continuation of U.S. reciprocal tariffs
United States and Thailand Agree to Framework Agreement on Reciprocal Trade
- Thailand’s elimination of tariff barriers on approximately 99 percent of goods, covering a full range of U.S. industrial, food
OFAC Sanctions Russia’s Two Largest Oil Companies
On October 22, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) placed Russia’s two largest oil companies on its Specially Designated Nationals (SDN) List. This action was taken by the Treasury Department to “increase pressure on Russia’s energy sector and degrade the Kremlin’s ability to raise revenue for its war machine…
USTR Issues Section 301 Determination on Nicaragua’s Abuses of Labor Rights and Human Rights Practices
On October 20, 2025, the United States Trade Representative (USTR) determined under Section 301 of the Trade Act of 1974 that Nicaragua’s acts, policies, and practices related to abuses of labor rights, abuses of human rights and fundamental freedoms, and dismantling of the rule of law are unreasonable and burden or restrict U.S. commerce. The…
