On May 23, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) No. 25 relaxing sanctions against the Government of Syria and twenty-eight (28) previously blocked Syrian entities and persons. GL 25 authorizes transactions that would otherwise be prohibited under the U.S. economic sanctions on Syria, including new investment
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.
CBP Issues Notice Addressing Refunds to Address Tariff “Stacking” Updates
On May 16, 2025, Customs and Border Protection (CBP) issued a Notice to implement President Donald Trump’s earlier Executive Order (EO) 14289 that eliminated the “stacking” (or accumulation) of certain overlapping tariffs. These overlapping tariffs included the IEEPA tariffs on Canada and Mexico, the Section 232 automobile and automotive part tariffs, and the Section 232…
Top Five Takeaways from DOJ’s Newest Guidance for Investigation & Prosecution of White Collar Crimes
On May 12, the U.S. Department of Justice (DOJ) issued updated policy memoranda relating to the investigation and prosecution of white collar crimes, including its White-Collar Enforcement Plan, Revised Corporate Enforcement and Voluntary Self-Disclosure Policy, Memorandum on Selection of Monitors in Criminal Division Matters, and the Criminal Division’s Corporate Whistleblower Awards Pilot Program Revisited. These…
China and the United States Agree to Temporarily Lower Tariff Rates
- The United States will (i) modify the application of the additional ad valorem rate of duty on
Department of Commerce Initiates Section 232 Investigation of Imports of Commercial Aircraft and Jet Engines
On May 1, 2025, the Department of Commerce (Commerce) announced that, pursuant to Section 232 of the Trade Expansion Act of 1962, it was initiating an investigation to determine the effects on the national security of imports of commercial aircraft, jet engines, and parts for commercial aircraft and jet engines. Interested parties may submit written…
President Trump Announces General Terms to a Forthcoming Trade Deal with the United Kingdom, Keeping 10% Baseline Tariffs But Dropping Tariffs on British Autos, Steel, and Aluminum
On May 8, 2025, the White House published general terms for a future trade deal “to enhance [the] economic partnership” between the United States and the United Kingdom. The general terms, which names the forthcoming agreement as the U.S.-UK Economic Prosperity Deal, “do[] not constitute a legally binding agreement” but rather memorialize a set of…
Treasury Announces Intent to Launch a CFIUS Fast Track Pilot Program to Streamline Review
On May 8, 2025, the U.S. Department of the Treasury announced its intent to launch a Fast Track Pilot Program to encourage greater investment in U.S. businesses from allied and partner countries. This initiative will introduce a Known Investor portal, allowing the Committee on Foreign Investment in the United States (CFIUS) to collect information from…
Department of Commerce Initiates Section 232 Investigation of Imports of Medium- and Heavy-Duty Trucks and Related Parts
On April 22, 2025, the Department of Commerce (Commerce) announced that, pursuant to Section 232 of the Trade Expansion Act of 1962, it was initiating an investigation to determine the effects on the national security of imports of medium-duty trucks, heavy-duty trucks, medium- and heavy-duty truck parts, and their derivative products.
The Federal Register notice…
President Trump Directs Commerce to Initiate Section 232 Investigation of Critical Mineral Imports
On April 15, 2025, President Donald Trump issued an Executive Order (EO) directing the Department of Commerce (Commerce) to initiate an investigation under Section 232 of the Trade Expansion Act of 1962 to determine the effects on national security of imports of processed critical minerals and their derivative products. Because “processed critical minerals and their…
Commerce Initiates Section 232 National Security Investigation of Imports of Pharmaceuticals & Pharmaceutical Ingredients
On April 1, 2025, it was announced that the Department of Commerce had initiated an investigation under Section 232 of the Trade Expansion Act of 1962 to determine the effects on the national security of pharmaceuticals and pharmaceutical ingredients and their derivative products. This includes both finished generic and non-generic drug products, medical countermeasures, critical…
