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.

Following the October 31, 2025 meeting between President Donald Trump and Chinese President Xi Jinping, President Trump on November 4, 2025, issued two Executive Orders related to and reducing certain tariffs on China.

In the first Executive Order, President Trump modified duties on imports from China. In February and March 2025, in response to

On October 23, 2025, a customs broker operating in both the United States and Mexico pleaded guilty to conspiring to violate the Foreign Corrupt Practices Act (FCPA) before a magistrate judge in the U.S. District Court for the Western District of Texas.  Although the plea agreement remains under seal, it was approved and adopted the

On October 26, 2025, the United States and the Government of Malaysia signed an Agreement on Reciprocal Trade. The agreement is intended to “enhance reciprocity in their bilateral trade relationship by addressing tariff and non-tariff barriers;” and seeks to strengthen their commercial relationship through increased alignment on national and regional economic security matters.” 

On October 26, 2025, the United States and the Kingdom of Cambodia signed an Agreement on Reciprocal Trade. The agreement is intended to “enhance reciprocity in their bilateral trade relationship by addressing tariff and non-tariff barriers;” and seeks to strengthen their commercial relationship through increased alignment on national and regional economic security matters.” 

On October 22, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) placed Russia’s two largest oil companies on its Specially Designated Nationals (SDN) List. This action was taken by the Treasury Department to “increase pressure on Russia’s energy sector and degrade the Kremlin’s ability to raise revenue for its war machine

On October 20, 2025, the United States Trade Representative (USTR) determined under Section 301 of the Trade Act of 1974 that Nicaragua’s acts, policies, and practices related to abuses of labor rights, abuses of human rights and fundamental freedoms, and dismantling of the rule of law are unreasonable and burden or restrict U.S. commerce.  The

On October 7, 2025, BIS posted a second tranche of requests made by the public for inclusion on the list of derivative products subject to Section 232 tariffs on steel and aluminum derivative products. BIS received 95 inclusion requests in the second submission period that opened on September 15 and closed on September 29. The

As of October 1, 2025, federal funding lapsed for numerous U.S. government agencies, including those engaged in sanctions, export control, and customs compliance and enforcement. Due to the lack of funding, export licensing functions have been significantly curtailed. Below is an overview of the status of key operations at OFAC, DDTC, BIS, and CBP.

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