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 June 1, 2026, the Office of the U.S. Trade Representative (USTR)  issued its determination that certain of Brazil’s acts, policies, and practices related to (i) digital trade and electronic payment services; (ii) unfair, preferential tariffs; (iii) anti-corruption enforcement; (iv) intellectual property protection; (v) ethanol market access; and (vi) illegal deforestation are unreasonable and burden

On June 1, 2026, the Office of Foreign Assets Control (OFAC), an office of the Department of Treasury, published an “Introduction to the Office of Foreign Assets Control.” OFAC administers and enforces economic sanctions against targeted foreign jurisdictions and regimes, as well as individuals and entities engaging in harmful activity, such as terrorists

On May 29, 2026, the U.S. Trade Representative (USTR) announced that it was launching an investigation of Vietnam under Section 301 of the Trade Act of 1974. The investigation will seek to determine “whether Vietnam’s persistent failure to resolve long-standing concerns about intellectual property (IP) protection and enforcement is unreasonable or discriminatory and burdens or

On May 1, 2026, President Donald Trump issued an Executive Order (EO) titled, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy.”  Pursuant to the EO, the Secretary of State and/or Secretary of Treasury are able to designate for blocking sanctions any foreign person

On April 27, 2026, the Department of Commerce (“Commerce”) published a Federal Register notice adding a duty-free code in the Harmonized Tariff Schedule of the United States (“HTSUS”) with retroactive effect to cover goods subject to the Section 232 aluminum, steel, or copper tariff regimes that do not, in fact, contain these metals.  This new

On April 14, 2026, U.S. Court of International Trade Senior Judge Richard Eaton held a closed conference in the new lead case, Euro-Notions Florida, Inc. v. U.S. Customs and Border Protection, et al., addressing refunds of duties paid under the International Emergency Economic Powers Act (“IEEPA”).  At the conclusion of the conference, the Judge

On April 14, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended two general licenses to continue authorizing limited transactions under previous sanctions involving Russia’s Lukoil operations.

Russia-related General License 128C, “Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia.” This amended general license extends until October 29

On April 14, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two general licenses in the continuing relaxation of certain sanctions involving Venezuela.  These new general licenses authorize certain commercial and banking transactions in the country.

Venezuela General License 56, “Authorizing Commercial-Related Negotiations of Contingent Contracts with the Government

On March 12, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 134, “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 12, 2026.”  The general license authorizes transactions “that are ordinarily incident and necessary

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