On October 6, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) added 49 entities from China, Estonia, Finland, Germany, India, Turkey, United Arab Emirates (UAE), and the United Kingdom to the Entity List after determining that these companies were “acting contrary to the national security or foreign policy interests of the United
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.
DHS Adds Three Xinjiang Entities to UFLPA List
On September 26, 2023, the Department of Homeland Security added three entities to the Uyghur Forced Labor Act (UFLPA) List as a result of each entity’s work with the government of the Xinjiang Uyghur Autonomous Region to recruit, transport, transfer, harbor or receive forced labor or Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups…
U.S., UK and EU Announce Updated List of Controlled “High-Priority” Items Restricted for Export to Russia
On September 19, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) announced additional items considered significant to Russian weaponry and are now restricted for export to both Russia and Belarus. In coordination with the United Kingdom and European Union, BIS continues to identify “high-priority items” by their six-digit Harmonized System (HS)…
OFAC Implements Additional Sanctions Targeting Russia’s Technology, Industrial, Construction and Financial Sectors
On September 14, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced another round of sanctions and economic restrictions targeting Russian elites and Russia’s industrial base, financial institutions, and technology suppliers. According to a press release, the sanctions on over 100 individuals and entities continues the effort “to leverage sanctions…
Joint State, Labor and Commerce Department Business Advisory Issued on South Sudan
The U.S. Departments of State, Labor, and Commerce issued a business advisory on August 14, 2023, outlining key risks for U.S. companies operating in South Sudan. Concerns revolve around corruption, transparency, and human rights violations. Businesses are particularly cautioned against engaging with entities connected to South Sudanese government officials, especially in the oil and mining…
Executive Order Issued Restricting U.S. Investments in Chinese Technology; Treasury Seeks Public Comment on Implementation
- A new Executive Order prohibits U.S. investments in semiconductors and microelectronics, quantum information technologies, and artificial intelligence capabilities in China and other countries of concern and imposes certain notification requirements.
- Certain passive and similar investments will be excepted from the restrictions.
- An Advanced Notice of Public Rulemaking seeks public comment on the scope
U.S. Expands Sanctions on the Belarusian Regime, Targeting State-Owned Enterprises and the Aviation Industry
On August 9, 2023, marking the three-year anniversary of the fraudulent August 2020 presidential election in Belarus, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new sanctions on eight individuals and five entities, focusing notably on the aviation sector.
Among the designated entities, OFAC has targeted the state-owned flagship carrier…
DHS Adds to UFLPA Entity List and Releases Updated Strategy to Prevent Importation of Goods Produced with Forced Labor in China
On August 1, 2023, the Department of Homeland Security (DHS) announced new actions to eliminate the use of forced labor practices in the U.S. supply chain by adding two China (PRC)-based companies to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List due to their participation in business practices involving Uyghur minorities in the Xinjiang…
Treasury Releases Annual CFIUS Report
On July 31, 2023, the Treasury Department, as the lead agency of the Committee on Foreign Investment in the United States (CFIUS), released a public version of its annual report to Congress regarding foreign direct investment in the United States. The report highlights key indicators of the CFIUS process and provides statistics on transactions that…
OFAC Designates Additional Russian Companies, Banks and Vessels to Further Hinder Russia’s Military Efforts in Ukraine
On July 20, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented further sanctions against Russia to restrict “access to products that support its military and war efforts; reduce Russia’s revenue from the metals and mining sector; undermine its future energy capabilities; degrade Russia’s access to the international financial system; and…
