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 February 24, 2022, in response to Russia’s invasion of Ukraine, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule, “Implementation of Sanctions Against Russia Under the Export Administration Regulations (EAR),” adding new Russia export license requirements and making licensing policies more stringent. The final rule is effective

On February 23, 2022, President Joseph Biden released a statement announcing that the United States was imposing sanctions on Nord Stream 2 AG and its corporate officers.  Effectively immediately, Nord Stream 2 AG has been designated and placed on the Department of Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List.

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On February 22, 2022, the Office of Foreign Assets Control (OFAC) expanded sanctions against Russia through blocking sanctions against two major Russian state-owned financial institutions, additional restrictions on Russian sovereign debt, sanctions on five Putin/Kremlin-connected elites, and the designation of several vessels. This follows the issuance of comprehensive sanctions on the territory recognized by Russia

On February 21, 2022, in response to Russia’s recognition of the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine as “independent states,” President Biden issued Executive Order (EO) 14065 prohibiting certain transactions with respect to the DNR or LNR or such other regions of Ukraine (collectively, “Covered Regions”) as may