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.

  • 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

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

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

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

On April 19, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5L, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After October 20, 2023,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO

On July 10, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 40B, “Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela.” This revised general license continues authorization of all transactions and activities related to the exportation or reexportation, directly or indirectly

On June 28, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that the United States was joining its “Five Eye” partners – Australia, Canada, New Zealand, and the United Kingdom – in committing to formally coordinate on export control enforcement.  While these allied countries have shared intelligence and other national security

  • The May 2023 FinCEN/BIS Joint Alert supplements the Joint Alert published by FinCEN and BIS in June 2022.
  • The Supplemental Joint Alert offers financial institutions new and updated information on export control restrictions imposed by BIS related to Russia.
  • Included is a list of certain “high priority” items organized according to their Harmonized