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 November 16, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8M, extending authorization until May 16, 2024 for certain activities previously authorized under General License 8L. General License 8M authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of

On November 14, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an important guidance document to ensure the provision of humanitarian aid to the Palestinian people in Gaza, while also maintaining strict controls to prevent funds from reaching Hamas. OFAC clarified that “U.S. sanctions do not stand in the

On November 2, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC), the Department of State, and the Department of Commerce’s Bureau of Industry and Security (BIS) announced a combined effort to designate and sanction numerous additional Russian individuals and entities who have been determined to be assisting in the war against

  • These two Interim Final Rules reinforce the October 7, 2022, controls appended to the EAR to restrict China’s ability to both purchase and manufacture certain high-end chips critical for military advantage.
  • The rules impose controls on additional types of semiconductor manufacturing equipment, adjust the parameters that determine whether an advanced computing chip is

On October 25, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued amended Russia-related General License No. 8H once again extending the authorization to conduct transactions involving Vnesheconombank, Bank Financial Corporation Otkritie, Sovcombank, Sberbank, VTB Bank, Alfa-Bank, Rosbank, Bank Zenit, Bank Saint-Petersburg, and the Central Bank of Russia that are related

  • For a period of six months, OFAC permits a wide range of transactions tied to Venezuela’s oil and gas sector, including new investments and financial dealings with specific Venezuelan banks.
  • OFAC allows all forms of transactions with Minerven, the Venezuelan state-owned gold mining company, nullifying prior sanctions solely in this sector.
  • OFAC lifted

On October 12, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two entities and identified as blocked property two vessels that used Price Cap Coalition service providers while carrying Russian crude oil above the Coalition-agreed price cap. See here for additional identifying information on these entities. 

The United States is

On October 6, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) added 49 entities from China, Estonia, Finland, Germany, India, Turkey, United Arab Emirates (UAE), and the United Kingdom to the Entity List after determining that these companies were “acting contrary to the national security or foreign policy interests of the United

On September 26, 2023, the Department of Homeland Security added three entities to the Uyghur Forced Labor Act (UFLPA) List as a result of each entity’s work with the government of the Xinjiang Uyghur Autonomous Region to recruit, transport, transfer, harbor or receive forced labor or Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups

On September 19, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) announced additional items considered significant to Russian weaponry and are now restricted for export to both Russia and Belarus. In coordination with the United Kingdom and European Union, BIS continues to identify “high-priority items” by their six-digit Harmonized System (HS)