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 April 15, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5O, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After August 13, 2024,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO

On April 4, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released another Interim Final Rule (IFR) offering clarification and correcting inadvertent errors made in earlier rulemakings regarding the implementation of significant export controls on certain advanced computing items and supercomputer and semiconductor end use. This latest rule is effective April 4

On March 28, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) announced a new resource to help identify boycott-related requests U.S. persons and companies may receive during the regular course of conducting business. The resource is a public list of entities identified as making a boycott-related request in reports received by the BIS

On March 20, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule implementing restrictions under the Export Administration Regulations (EAR) on persons who have been designated and placed on the Specially Designated Nationals (SDN) List maintained by the Department of the Treasury’s Office of Foreign Assets Control (OFAC). Under Secretary

On Saturday, March 9, 2024, President Biden signed a six-bill appropriations package to fund the U.S. government through September 30, 2024.  In doing so, he codified a notable trade-related policy rider that adds the Secretary of Agriculture “on a case by case basis” to the Committee on Foreign Investment in the United States (“CFIUS” or

On March 12, 2024, five national labor unions filed a petition with the Office of the U.S. Trade Representative (USTR) under Section 301 of the Trade Act of 1974 requesting an investigation into the acts, policies, and practices of China in the maritime, logistics, and shipbuilding sector. Section 301 allows the United States to respond

  • More than 500 entities and individuals added to the Specially Designated Nationals and Blocked Persons List and nearly 100 added to the Entity List.
  • Four new or updated general licenses issued by the Office of Foreign Assets Control to address wind-down and safety considerations.
  • An expansion of the multilateral Common High Priority Items

On February 20, 2024, Hoshine Silicon (Jia Xing) Industry Co., Ltd. (“Jiaxing Hoshine”), a wholly owned subsidiary of Hoshine Silicon Industry Co., Ltd., filed a complaint at the United States Court of International Trade (USCIT) challenging the U.S. Customs and Border Protection’s (CBP) June 2021 decision to issue a withhold release order (WRO) against Hoshine

President Biden signed the National Defense Authorization Act for Fiscal Year 2024 into law (P.L. 118-31) (NDAA 2024 or Act) in December 2023. Lawmakers frequently target this type of “must pass” legislation as a vehicle to codify their own, often unrelated policy priorities or “rider” provisions. The NDAA 2024 is no exception, containing a patchwork

On February 23, 2024, the eve before Russia’s full-scale invasion of Ukraine officially enters its third year, the United States issued another sanctions package against Russia, taking particular aim at Russia’s financial sector, energy production revenue streams, and military-industrial complex. Specifically, the package sanctions more than 500 entities and individuals by having them added