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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 8, 2022, President Joseph Biden signed into law H.R. 7108, the Suspending Normal Trade Relations with Russia and Belarus Act, and H.R. 6968, the Suspending Energy Imports from Russia Act. Both pieces of legislation passed the Senate and House of Representatives on April 7, 2022.

The Suspending Normal Trade Relations with

The Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 120 Russian and Belarusian companies to the Entity List. Ninety-five companies (24 Belarusian entities and 71 Russian entities) are being added as they have been determined to be “military end users.” These entities will also be subject to the Russia/Belarus

On March 11, 2022, President Biden called on Congress to pass legislation that will revoke normal trade relations (NTR) with Russia, and announced that the administration “will work closely with Congress to deny Russia the benefits of its WTO membership and ensure that Russian imports do not receive most favored nation treatment” in the U.S.

On March 8, 2022, President Joseph Biden signed an Executive Order banning the import into the United States of Russian oil, liquefied natural gas, and coal. The Executive Order bans:

  • The importation into the United States of Russian-origin crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal

On March 3, 2022, the State Department announced that the United States was sanctioning certain Russian companies deemed to design, develop, and produce items that the Russian military is using to attack Ukraine. Specifically, the following 21 entities are being designated pursuant to E.O. 14024, because “they are persons who operate or have operated in

On March 4, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) announced further sanctions to target Russia’s strategic oil/gas and military/defense sectors. BIS stated that the actions are intended to further restrict access to U.S. commodities, software, and technology in order to limit Russia’s “ability to raise revenue from the sale of

On March 3, 2022, President Joseph Biden announced that the United States was sanctioning an extensive list of “Russian elites” and their family members. In a White House press release, the president stated that, “[t]hese individuals and their family members will be cut off from the U.S. financial system, their assets in the United

On March 2, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule that has added new license requirements and review policies for Belarus to the Export Administration Regulations (EAR) which now subject Belarus to the same sanctions that were imposed on Russia under the EAR effective February 24, 2022.

On February 25, the Office of Foreign Assets Control (OFAC) placed on the Specially Designated Nationals (SDN) List Russian President Vladimir Putin, Foreign Minister Sergei Lavrov, Minister of Defense Sergei Shoigu and Chief of the General Staff of the Russian Armed Forces, First Deputy Minister of Defense, and General of the Army Valery Gerasimov.  Specific

On February 24, 2022, the Department of Treasury’s Office of Foreign Assets Control (OFAC) again expanded sanctions against Russia in response to its invasion of Ukraine by designating numerous Russian and Belarusian financial institutions to the Specially Designated Nationals and Blocked Persons (SDN) List, and Russian financial institutions to the Non-SDN Menu-Based Sanctions (MBS) List