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 May 12, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 22, which authorizes certain transactions, including processing or transfer of funds on behalf of third-country entities, otherwise prohibited under the Syrian Sanctions Regulations (SSR) that are ordinarily incident and necessary to activities in the

Key Notes:

  • Persons, including non-U.S. persons, providing accounting, trust and corporate formation, and management consulting services in Russia may be added to the SDN List.
  • U.S. persons are prohibited from providing these same services to Russian persons unless the recipient of the services is the subsidiary of a U.S. person.

The Department of the Treasury’s

On May 8, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented additional sanctions on several sectors of the Russian economy.  OFAC designated three Russian telecommunications companies and placed them on the Specially Designated Nationals (SDN) list, noting that they are Russian state-controlled television stations generating revenue for the Russian government. 

The Department of Commerce’s Bureau of Industry and Security (BIS) issued on May 9, 2022, a Final Rule that greatly expands the list of items requiring a license to export to Russia. The export restrictions impact a broad range of inputs and products including wood products, industrial engines, boilers, motors, fans, and ventilation equipment, bulldozers,

The Department of Commerce’s Bureau of Industry and Security (BIS) has created a web page offering “Resources on Export Controls Implemented in Response to Russia’s Invasion of Ukraine.” The web page provides convenient links to relevant BIS press releases, fact sheets, and Federal Register notices related to BIS actions involving export controls and

On May 5, 2022, the U.S. International Trade Commission (ITC) announced the initiation of a general factfinding investigation that will examine the impact of tariffs on U.S. imports under section 232 of the Trade Expansion Act of 1962 and section 301 of the Trade Act of 1974 in effect as of March 15, 2022.  The

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has added multiple new entities and persons to its Specially Designated Nationals (SDN) List after determining that they were involved in attempts to evade U.S. sanctions put in place as a result of Russia’s invasion of Ukraine.  OFAC has designated Russian commercial bank PJSC

On and effective April 8, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule that expands upon prior export control restrictions placed on Russian and Belarus in response to Russia’s invasion of Ukraine. This rule expands restrictive license requirements to include Commerce Control List (CCL) categories 0-2, which include

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