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 November 14, 2025, the United States, the Swiss Confederation (Switzerland), and the Principality of Liechtenstein (Liechtenstein) agreed to a framework for negotiations on an Agreement on Reciprocal Trade.  While representatives from the three countries continue to negotiate the formal agreement and hope to conclude any agreement during the first quarter of 2026, the key

Key Notes

  • Tariff undervaluation may result in criminal charges.
  • False country of origin may result in government procurement-related fraud charges, not only tariff-related fraud charges.

The Department of Justice (DOJ) in September announced the unsealing of an indictment charging two Colorado companies and three executives with a multiyear scheme to sell Chinese made forklifts to

On November 5, 2025, the U.S. Supreme Court heard oral arguments in a high-profile consolidated appeal challenging whether President Donald Trump lawfully invoked the International Emergency Economic Powers Act (“IEEPA”) to impose tariffs.  The cases challenge two sets of tariffs Trump implemented earlier this year: (1) tariffs against Canada, China, and Mexico in response to

On November 7, 2025, the State Department’s Directorate of Defense Trade Controls (DDTC) issued a Final Rule amending 22 C.F.R. § 126.1 to remove the Kingdom of Cambodia as a proscribed country under the International Traffic in Arms Regulations (ITAR).  Effective immediately, requests for the export of defense articles and services to Cambodia will now

Following the October 31, 2025 meeting between President Donald Trump and Chinese President Xi Jinping, President Trump on November 4, 2025, issued two Executive Orders related to and reducing certain tariffs on China.

In the first Executive Order, President Trump modified duties on imports from China. In February and March 2025, in response to

On November 1, 2025, the White House published a Fact Sheet announcing that the Department of Commerce’s Bureau of Industry and Security (“BIS”) will suspend the new “50% Rule”—also known as the “Affiliates Rule”—for one year, beginning November 10, 2025. The suspension was among several concessions reached during trade negotiations between the United States and

On October 26, 2025, the United States and the Government of Malaysia signed an Agreement on Reciprocal Trade. The agreement is intended to “enhance reciprocity in their bilateral trade relationship by addressing tariff and non-tariff barriers;” and seeks to strengthen their commercial relationship through increased alignment on national and regional economic security matters.”