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.

As a reminder to our readers, the annual encryption self-classification report and semi-annual sales report for certain encryption items are due to be filed by February 1, 2024. 

Annual Self-Classification Report

The self-classification report covers less sensitive items described under the Department of Commerce’s Bureau of Industry and Security (BIS) License Exception ENC (b)(1) (i.e., 

On January 16, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5N, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After April 16, 2024,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO

The U.S. International Trade Commission released the 2024 Basic Edition of the Harmonized Tariff Schedule of the United States (HTSUS) on January 1, 2024.

The HTSUS sets out the tariff rates and statistical categories for all merchandise imported into the United States and is based on the international Harmonized System, which is the global system

On December 20, 2023, nearly eleven months after publishing its finalized guidance on the implementation of the twin price caps on Russian oil and Russian petroleum products, the Department of the Treasury (“Treasury”) published a revised Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin

On December 22, 2023, President Joseph Biden issued Executive Order 14114 (EO) amending EO 14024 by authorizing the imposition of U.S. sanctions on foreign financial institutions that are either facilitating significant transactions on behalf of persons designated for operating in certain key sectors of the Russian economy, or facilitating significant transactions or providing services involving Russia’s

On December 22, 2023, President Joseph Biden amended, among other things, Executive Order (EO) 14068, by additionally authorizing the prohibition on the importation and entry into the United States, including a foreign trade zone located in the United States, of the following products of Russian Federation origin: fish, seafood, and preparations thereof, as well

On December 19, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 13 entities to its Unverified List (UVL). The UVL contains the names and addresses of foreign persons who are or have been parties to a transaction involving the export, reexport, or transfer (in-country) of items subject

Pursuant to a Federal Register Notice posted by the Department of Homeland Security (DHS), effective December 11, 2023, three entities have been added to the UFLPA Entity List. These entities have been identified by DHS as entities working with the government of the Xinjiang Uyghur Autonomous Region to recruit, transport, transfer, harbor or receive

On December 12, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of State announced sanctions designating numerous additional Russian individuals and entities who have been determined to be assisting in the war against Ukraine and for efforts to evade U.S. sanctions and export controls on Russia. OFAC also

On December 5, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) imposed sanctions on numerous entities and individuals in order to place additional pressure on both Belarus and Russia. The OFAC sanctions focus on Belarus’ “authoritarian regime” and for its