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 January 17, 2025, the Department of State’s Directorate of Defense Trade Controls (DDTC) published an Interim Final Rule that will amend §§ 121.0 and 121.1 of the International Traffic in Arms Regulations (ITAR) by revising certain U.S. Munitions List (USML) definitions, adding new definitions, and updating certain parts of the USML under categories II

On January 17, 2025, Customs and Border Protection (CBP) announced a Notice of Proposed Rulemaking (NPRM) intended to tighten the de minimis duty exemption for certain low-value shipments entering the United States.  Under the proposed rule, merchandise subject to specific trade and national security actions would no longer qualify for the de minimis exemption and

On January 14, 2025, the Department of Homeland Security (DHS) announced the addition of 37 companies based in China to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, bringing the total number of entities on the UFLPA Entity List to nearly 150 entities. 

According to a press release by DHS, the entities added include globally recognized

The Department of the Treasury’s Office of Foreign Asset Controls (OFAC) has issued further sanctions (see also January 15, 2025 Thompson Hine Update) to address Russia’s continued efforts to evade U.S. sanctions.   OFAC noted in a press release that this latest action “targets a sanctions evasion scheme established between actors in Russia and [China]

On January 10, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) targeted significant entities involved in Russia’s oil production, maritime insurers, maritime oil tankers, and other entities and persons engaged in Russia’s energy sector. According to an OFAC press release, the sanctions block two major Russian oil producers, over 180

On January 10, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated and placed eight Venezuelan officials on the Specially Designated Nationals (SDN) List for “enabling Nicolas Maduro’s repression and subversion of democracy in Venezuela.” The individuals sanctioned include the president of Petroleos de Venezuela, S.A., (PdVSA), Venezuela’s state-owned oil company

On January 7, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13L, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import

On January 3, 2025, President Joseph Biden issued a Presidential Order blocking an approximately $15 billion proposed acquisition by Nippon Steel Corporation (Nippon Steel) of Japan to purchase Pittsburgh-based United States Steel Corporation (U.S. Steel). Explaining that the proposed acquisition might result in actions that threaten to impair the national security of the United States

On December 30, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released a year-end update of the Boycott Requester List. This list notifies companies, financial institutions, freight forwarders, individuals, and other U.S. persons of potential sources of certain boycott-related requests they may receive during the regular course of business. Introduced in