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 July 9, 2026, President Trump issued a Presidential Proclamation, pursuant to Section 232 of the Trade Expansion Act of 1962, ordering the Secretary of Commerce and U.S. Trade Representative to continue negotiating agreements with trading partners to address the threatened impairment of national security as to imports of commercial aircraft, jet engines, and

On July 8, 2026, on the sidelines of the NATO summit, President Donald Trump announced his intention to remove Syria from the State Sponsor of Terrorism list, a significant move that would assist Syria’s efforts to re-engage in the global political and financial systems and rebuild the country after more than a decade of civil

On July 7, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) revoked Iran-related General License X and issued Iran-related General License X1, for the “Revocation and Wind Down of June 21, 2026 Authorization for the Production, Delivery and Sale of Crude Oil, Petrochemical Products, and Petroleum Products of Iranian Origin.”

On July 6, 2026, the U.S. Court of International Trade (CIT) issued an Order announcing resolution of all pending but stayed China Section 301 cases because of the June 15, 2026 U.S. Supreme Court decision denying the petition for a writ of certiorari in HMTX Industries LLC v. United States. To facilitate resolution of

On June 29, 2026, the Department of Commerce (Commerce) initiated an investigation under Section 232 of the Trade Expansion Act of 1962, as amended, to determine the effects on the national security of imports of anthracite coal. For the purposes of this investigation, anthracite coal encompasses products classified under Harmonized Tariff Schedule of the United

On July 1, 2026, the U.S. Trade Representative (USTR) issued a formal statement regarding the joint review of the Agreement between the United States of America, the United Mexican States, and Canada (USMCA). The USMCA entered into force on July 1, 2020, and contains a clause requiring that the parties meet on the sixth anniversary

All persons subject to U.S. jurisdiction holding property blocked pursuant to various Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctions programs must file their Annual Report of Blocked Property (ARBP) by September 30, 2026. This required reporting applies to all relevant persons, not only financial institutions.

This report is pursuant to 31

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has launched a Reconsideration Portal for the submission of requests by persons or entities seeking to be removed from an OFAC sanctions list. The portal provides an overview of the process for requesting removal from a list as well as information on OFAC’s

On June 24, 2026, Customs and Border Protection (CBP) issued two Interim Final Rules indefinitely suspending the $800 de minimis duty exemption for all modes of importation of goods into the United States and establish a new informal entry and bonding process for international mail shipments. Public comments on these two interim rules are due

UPDATE: On July 7, 2026, this Iran-related General License X was revoked by OFAC and any activities under this general license must be wound down no later than July 17, 20026. See Thompson Hine Update of July 8, 2026 for additional details.


On June 22, 2026, the Department of the Treasury’s Office of Foreign Assets