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 August 21, 2026, trade negotiations between the United States and Canada faltered and the parties, for now, have ceased further negotiations. As a result, the United States has implemented 50% tariffs on a broad range of Canadian products under Section 338 of the Tariff Act of 1930. First announced on July 20, 2026 (…

On August 24, 2026, the State Department announced that the United States was formally rescinding Syria’s designation as a State Sponsor of Terrorism following the conclusion of the mandatory 45-day Congressional notification period.  See SmarTrade update of July 9, 2026.  In a press statement, the State Department indicated that this action, along with…

The Bureau of Industry and Security (“BIS”) has published a temporary final rule to restrict the export of black mass and tungsten waste and scrap without a license. The agency defines black mass as shredded lithium-ion battery scrap that contains cathode material, anode material or other “residual battery cell materials.” The BIS will restrict export…

  • Effective July 28, 2026, the Federal Communications Commission’s (FCC) Covered List now includes foreign-produced power inverters and foreign-produced advanced robotic devices. These equipment categories are now prohibited from receiving new FCC equipment authorizations.
  • The term “foreign-produced” refers to any article that does not qualify as a “domestic end product,” as that term is
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On July 31, 2026, the Department of Homeland Security (DHS) announced the addition of 43 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 187 entities. Effective August 3, 2026, U.S. Customs and Border Protection (CBP) will apply a rebuttable presumption…

On July 23, 2026, the Office of the U.S. Trade Representative (USTR) announced in a Notice of Action its final action in the Section 301 investigation of 60 economies for “their failure to impose and effectively enforce a prohibition on the importation of goods produced with forced labor.”  Under Section 301 of the Tariff Act…

On July 17, 2026, U.S. Court of International Trade (CIT) Senior Judge Richard Eaton, issued an order, which was made available today, directing U.S. Customs and Border Protection (CBP) to “reliquidate, without regard to IEEPA [the International Emergency Economic Powers Act] duties, any and all of Plaintiffs’ entries that have been liquidated for more…

On July 15, 2026, the Office of the U.S. Trade Representative (USTR) announced that, pursuant to Section 301 of the Trade Act of 1974, it was imposing a 25% tariff on certain imports of Brazilian goods. The announcement came at the direction of President Donald Trump following an investigation and determination by the USTR that…

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…