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 June 2, 2026, the Office of the U.S. Trade Representative (USTR) issued its determination under Section 301 of the Trade Act of 1974 that certain acts, policies, and practices of 60 economies related to the failure to impose and effectively enforce a prohibition on the importation of goods produced with forced labor are unreasonable

On June 1, 2026, the Office of the U.S. Trade Representative (USTR) issued its determination that certain of Brazil’s acts, policies, and practices related to (i) digital trade and electronic payment services; (ii) unfair, preferential tariffs; (iii) anti-corruption enforcement; (iv) intellectual property protection; (v) ethanol market access; and (vi) illegal deforestation are unreasonable and burden

On May 29, 2026, the U.S. Trade Representative (USTR) announced that it was launching an investigation of Vietnam under Section 301 of the Trade Act of 1974. The investigation will seek to determine “whether Vietnam’s persistent failure to resolve long-standing concerns about intellectual property (IP) protection and enforcement is unreasonable or discriminatory and burdens or

On May 1, 2026, President Donald Trump issued an Executive Order (EO) titled, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy.”  Pursuant to the EO, the Secretary of State and/or Secretary of Treasury are able to designate for blocking sanctions any foreign person

On April 14, 2026, U.S. Court of International Trade Senior Judge Richard Eaton held a closed conference in the new lead case, Euro-Notions Florida, Inc. v. U.S. Customs and Border Protection, et al., addressing refunds of duties paid under the International Emergency Economic Powers Act (“IEEPA”).  At the conclusion of the conference, the Judge

On April 14, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended two general licenses to continue authorizing limited transactions under previous sanctions involving Russia’s Lukoil operations.

Russia-related General License 128C, “Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia.” This amended general license extends until October 29

On April 14, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two general licenses in the continuing relaxation of certain sanctions involving Venezuela.  These new general licenses authorize certain commercial and banking transactions in the country.

Venezuela General License 56, “Authorizing Commercial-Related Negotiations of Contingent Contracts with the Government

On April 6, 2026, Senior Judge Richard Eaton of the U.S. Court of International Trade (CIT) granted the Notice of Dismissal filed by counsel for Atmus Filtration, Inc. in Atmus Filtration Inc. vs. United States, the lead case seeking refunds of tariffs paid under the International Emergency Economic Powers Act (IEEPA). Subsequently, he issued

On March 20, 2026, Senior Judge Richard Eaton of the U.S. Court of International Trade (CIT) issued another Order in Atmus Filtration Inc. vs. United States regarding refunds of duties paid under the International Emergency Economic Powers Act (IEEPA). In summarizing the CIT’s March 19, 2026 closed conference with plaintiff and government legal counsel, the

On March 12, 2026, the U.S. Trade Representative (USTR) announced that it was launching Section 301 investigations into 60 trade partners to determine whether they have been engaged in forced labor practices. The investigations, to be conducted pursuant to Section 301of the Trade Act of 1974, include China, the European Union, India, and Mexico. A