Photo of Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

On March 2, 2026, the Office of the U.S. Trade Representative (USTR) delivered President Donald Trump’s 2026 Trade Policy Agenda and 2025 Annual Report to Congress. This year’s trade agenda seeks to promote U.S. interests abroad and reduce trade deficits by pursuing trade deals with other countries and strengthening domestic manufacturing.

2025 Annual Report

On March 6, 2026, Judge Richard Eaton of the U.S. Court of International Trade (CIT or Court) held a closed conference in Atmus Filtration, Inc. vs. United States, to continue the Court’s process in determining how the International Economic Emergency Powers Act (IEEPA) tariffs can be refunded to importers of record.  At the conclusion of

On March 4, 2026, in Atmus Filtration, Inc. vs. United States, Judge Richard Eaton of the U.S. Court of International Trade (CIT) issued an order, referencing the U.S. Supreme Court’s February 20, 2026 ruling in Learning Resources, Inc. v. Trump declaring International Emergency Economic Powers Act (IEEPA) tariffs unlawful, that: (1) “[a]ll importers

In a 6-3 ruling, the Supreme Court of the United States ruled that the International Emergency Economic Powers Act (IEEPA) does not grant the president power to impose tariffs. In response, President Donald Trump issued a temporary 10% tariff on all imports pursuant to Section 122 of the Trade Act of 1974. Importers of record

On February 20, 2026, President Donald Trump issued a proclamation announcing that he was imposing a temporary import surcharge (i.e., tariff) pursuant to section 122 of the Trade Act of 1974 (19 U.S.C. Section 2132) to address “fundamental international payments problems” that “could impair United States national interests, including economic and national security interests.” Stating

On February 20, 2026, the U.S. Supreme Court (SCOTUS) in a 6-3 ruling determined that President Donald Trump’s use of the International Economic Emergency Powers Act (IEEPA) to impose tariffs was unlawful. In its decision, the SCOTUS stated: “When Congress grants the power to impose tariffs, it does so clearly and with careful constraints. 

On February 12, 2026, the Office of the U.S. Trade Representative (USTR) announced that the United States and the Republic of China (Taiwan) signed the Agreement on Reciprocal Trade between the United States of America and Taiwan (the “Agreement”), under the auspices of the American Institute in Taiwan and the Taipei Economic and Cultural Representative

On February 6, 2026, President Donald Trump signed an Executive Order continuing the national emergency with respect to Iran and establishing a process to impose tariffs on countries that acquire any goods or services from Iran to protect the national security, foreign policy, and economy of the United States.  The Executive Order “impose[s] an additional 

On February 5, 2026, the Office of the U.S. Trade Representative (USTR) announced that the United States and The Argentine Republic have signed the U.S.-Argentina Agreement on Reciprocal Trade and Investment (Agreement). According to Ambassador Jamieson Greer, the USTR, the Agreement serves “as a model of how countries in the Americas, from Alaska to Tierra

On February 3, 2026, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule removing Cambodia from the list of U.S. arms-embargoed countries—Country Group D:5—within the Export Administration Regulations (EAR). This actions follows the White House’s October 2025 decision to lift the U.S. arms embargo on Cambodia, and aligns with the