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 20, 2025, President Donald Trump issued an Executive Order modifying the scope of certain ad valorem tariffs on Brazil implemented on July 30, 2005, pursuant to the International Emergency Economic Powers Act (IEEPA). These earlier tariffs placed a 40% duty rate on certain articles of Brazil, including numerous agricultural products, coffee and beef.

On November 18, 2025, U.S. Customs and Border Protection (CBP) announced the issuance of a Withhold Release Order (WRO) against garments, apparel, and textiles manufactured in Mauritius by Firemount Group Ltd. The WRO follows an investigation into the company where CBP discovered several indicators of forced labor use, including abuse of vulnerability, debt bondage, deception

According to a Joint Statement issued by the White House on November 13, 2025, the United States and the Republic of Ecuador have entered into a Framework for an Agreement on Reciprocal Trade to “provide access to each other’s markets and increase alignment on economic and national security matters.” As noted in a separate White

On November 13, 2025, the United States and the Argentine Republic entered a framework for an Agreement on Reciprocal Trade. The Agreement seeks “to drive long-term growth, expand opportunity, and create a transparent and rules-based environment for commerce and innovation.”  While representatives from both countries continue to negotiate and finalize the formal agreement, it will

On November 13, 2025, the United States and the Republic of Guatemala entered a framework for an Agreement on Reciprocal Trade. The Agreement aims to strengthen the countries’ economic partnership established in 2006 under the Dominican Republic–Central America–United States Free Trade Agreement (“CAFTA-DR”). While representatives from both countries continue to negotiate and finalize the formal

On November 13, 2025, the United States and the Republic of El Salvador entered a framework for an Agreement on Reciprocal Trade. The Agreement aims to strengthen the countries’ economic partnership established in 2006 under the Dominican Republic–Central America–United States Free Trade Agreement (“CAFTA-DR”). The framework agreement is one of several reached by the

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