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 May 31, 2024, the Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) published a Federal Register notice announcing the seventh phase of the Lacey Act’s import declaration requirement, adding enforcement of Phase VII will begin on December 1, 2024. Known as “the United States’ oldest wildlife protection statute,” the Lacey Act (16

On May 28, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) revised the Cuban Assets Control Regulations (CACR) to enhance support for the Cuban people and independent Cuban private sector entrepreneurs. These amendments, effective on May 28, 2024, aim to promote internet freedom and broaden financial services in Cuba. In

On May 17, 2024, the Department of Homeland Security (DHS) issued a Federal Register notice announcing that effective immediately, 26 Chinese entities have been added to the UFLPA Entity List. These entities include cotton traders and warehouse facilities within China, but the majority of which operate outside of the Xinjiang Uyghur Autonomous Region (XUAR). DHS

Citing national security concerns, President Biden issued an executive order (EO) on May 13, 2024, demanding a Chinese-affiliated company “sell or transfer” its ownership interests and any other rights in an approximately 12-acre lot that comes within one mile of Francis E. Warren Air Force Base (“Warren AFB”) in Cheyenne, Wyoming. The divestment order is

On May 10, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8N, extending authorization until November 15, 2024 for certain activities previously authorized under General License 8M. General License 8N authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of

On April 24, 2024, President Biden signed into law a broad national security package which included the Israel Security Supplemental Appropriations Act, 2024; Ukraine Security Supplemental Appropriations Act, 2024; Indo-Pacific Security Supplemental Appropriations Act, 2024; 21st Century Peace through Strength Act; FEND off Fentanyl Act; and the Rebuilding Economic Prosperity and Opportunity for Ukrainians Act.

  • On April 16, 2024, the National Institute of Standards and Technology (NIST), part of the Department of Commerce, announced the launch of a new funding opportunity called the Small Business Innovation Research (SBIR) Program for CHIPS for America – CHIPS Metrology.
  • The Notice of Funding Opportunity (NOFO) is aimed at enhancing small businesses’

On May 1, 2024, the State Department published a proposed rule to amend the International Traffic in Arms Regulations (ITAR) and establish an exemption to the licensing requirement for exports, reexports, transfers, or temporary import of defense articles to or within Australia and the United Kingdom. This proposed rule is intended to promote the goals

On May 1, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of State announced further sanctions targeting Russia’s military-industrial base and chemical and biological weapons programs as well as companies and individuals in third countries that continue to help Russia acquire key inputs for weapons or defense-related production.

On April 24, 2024, President Biden signed into law a significant amendment to the statute of limitations for violations under U.S. sanctions laws, as part of the national security package (H.R. 815). This change extends the period for enforcement actions from five to ten years, reflecting a more robust approach to national security