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 28, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that the United States was joining its “Five Eye” partners – Australia, Canada, New Zealand, and the United Kingdom – in committing to formally coordinate on export control enforcement.  While these allied countries have shared intelligence and other national security

  • The May 2023 FinCEN/BIS Joint Alert supplements the Joint Alert published by FinCEN and BIS in June 2022.
  • The Supplemental Joint Alert offers financial institutions new and updated information on export control restrictions imposed by BIS related to Russia.
  • Included is a list of certain “high priority” items organized according to their Harmonized

On May 19, 2023, the Department of the Treasury issued a Determination pursuant to E.O. 14071 that prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, of architecture or engineering services to any person located in the Russian Federation. The determination excludes the

On May 23, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8L, extending authorization until November 19, 2023 for certain activities previously authorized under General License 8K. General License 8L authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of

On May 19, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of State sanctioned and placed on the Specially Designated Nationals (SDN) List over 225 individuals, entities, vessels and aircraft. These actions came at the same time the G7 member countries were meeting and jointly announced both continued

On May 19, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a significant Final Rule implementing additional sanctions and revising existing export controls against Russia and Belarus for ongoing aggression against Ukraine. According to the announcement, these revisions and additions seek to better align U.S. sanctions with the controls that have

The Office of the U.S. Trade Representative (USTR) has issued a Notice announcing the continuing extension of Section 301 tariff exclusions for 81 medical products that were scheduled to expire on May 15, 2023. These extensions come after a 75-day extension in February 2023 when USTR sought public comment on whether further exclusions were necessary

On May 12, 2023, the plaintiff group in the China Section 301 tariff refund litigation, in response to the recently issued decision by the U.S. Court of International Trade (CIT) upholding those Section 301 tariffs, formally filed its Notice of Appeal. The appeal will be heard by the U.S. Court of Appeals for the

On May 5, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued amended Russia-related General License No. 8G 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 to energy