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.

UPDATE: On February 14, the Federal Register released the formal Presidential Proclamations on the steel and aluminum tariffs that include the annexes for each Proclamation that detail the list of in-scope steel or aluminum articles and derivatives that will be subject to the 25% ad valorem tariffs. The links in this post have been updated

On February 4, 2025, President Donald Trump issued an Executive Order (EO) stating that Iran’s malign behavior and influence threaten the national interest of the United States and that it is “in the national interest to impose maximum pressure on the Iranian regime to end its nuclear threat, curtail its ballistic missile program, and stop

UPDATE: On February 7, President Donald Trump issued an executive order (EO) addressing the additional duties placed on imports into the United States of products of China. The article below stated that use of duty-free de minimis treatment on imports for shipments under $800 was being removed for shipments from China. The president has since

  • Directing the Secretary of Commerce, Secretary of the Treasury and the U.S. Trade Representative to “investigate the causes of our country’s large and persistent

On January 15, 2025, the Department of Commerce’s inflation-adjusted civil monetary penalties for 2025 went into effect. The adjustments, which the Department of Commerce (“Commerce”) published in the Federal Register on December 30, 2024, update the penalty rates for violations of laws and regulations enforced by the agency and its bureaus. 

While over 40 civil

On January 16, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule prohibiting the sale and importation of connected vehicles incorporating certain hardware and software components (or those components sold separately) with a sufficient nexus to the People’s Republic of China (PRC) or Russia. The new prohibitions go into

On January 17, 2025, the Department of State’s Directorate of Defense Trade Controls (DDTC) published an Interim Final Rule that will amend §§ 121.0 and 121.1 of the International Traffic in Arms Regulations (ITAR) by revising certain U.S. Munitions List (USML) definitions, adding new definitions, and updating certain parts of the USML under categories II

On January 17, 2025, Customs and Border Protection (CBP) announced a Notice of Proposed Rulemaking (NPRM) intended to tighten the de minimis duty exemption for certain low-value shipments entering the United States.  Under the proposed rule, merchandise subject to specific trade and national security actions would no longer qualify for the de minimis exemption and

On January 16, 2025, the Office of the U.S. Trade Representative (USTR) released its report and findings in the Section 301 investigation of China’s targeting of the maritime, logistics, and shipbuilding sectors for dominance, concluding that China’s targeted dominance in these sectors is unreasonable and burdens or restricts U.S. commerce, and is thus “actionable” under

On January 14, 2025, the Department of Homeland Security (DHS) announced the addition of 37 companies based in China to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, bringing the total number of entities on the UFLPA Entity List to nearly 150 entities. 

According to a press release by DHS, the entities added include globally recognized