Francesca is a partner in the firm’s International Trade practice group. She regularly 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.
In addition, Francesca has extensive experience counseling clients on national security issues relevant to foreign investment in the United States. She has represented investors and U.S businesses before the Committee on Foreign Investment in the United States from diverse sectors including energy generation and transmission, pharmaceutical development, heavy manufacturing, defense and aerospace, telecommunications, and software technology.
Focus Areas
- International Trade>
- Corporate Transactions & Securities>
- Government Contracts>
- White Collar Defense & Investigations>
- Automotive & Mobility>
- Corporate Responsibility>
- Site Selection>
- Forced Labor & Human Rights>
- Global Supply Chain Services>
- International Trade – Supply Chain>
- Food & Beverage Industry>
- CFIUS/National Security/Foreign Direct Investment>
- Customs>
- Export Controls & Economic Sanctions>
- FCPA & Other Antibribery Laws>
- International Trade Compliance Risk Evaluation>
- Trade Crimes Defense>
- Advised a U.S. chemicals company in the development of a forced labor risk assessment methodology and a forced labor compliance program.
- Conducted an export control compliance of an audit of a Chinese company as mandated under a settlement agreement with the U.S. Department of Commerce.
- Prepared OFAC license applications for an education services company to conduct business related to Sudan, Iran and Syria.
- Represented a U.S. importer in a prior disclosure of violations of customs regulations with respect to five years of imports from China and other Asian countries.
- Prepared BIS license applications for various technology, manufacturing, and service providers seeking to export items subject to the EAR to companies on the Entity List.
- Represented a U.S. defense and aerospace company in the voluntary disclosure of violations of the ITAR to the Directorate of Defense Trade Controls.
- Represented a foreign government-owned energy company in multiple CFIUS notices regarding the sale of interests in wind energy projects, including the sale to another foreign government-owned investor.
- Represented a Chinese company in the acquisition of a U.S. pharmaceutical company.
- Advised a U.S. manufacturer and global distributor in the development of comprehensive anti-bribery policies and procedures.
- Represented a global leader in solar, wind and battery technology in the acquisition of the world leader in modeling and optimization software for microgrids.
- “President Trump Issues America First Investment Policy Memorandum Impacting FDI into the U.S. and Outbound Investment to Foreign Adversaries,” Thompson Hine Transition – A Presidential Change Update, February 2025
- Thompson Hine Mobility Matters Quarterly, February 2025
- Thompson Hine Mobility Matters Quarterly, October 2024
- “BIS Enhances Its Enforcement Discretion: Revamps Voluntary Self-Disclosure Process, Abolishes Penalty Caps and Amends Penalty Guidelines,” Thompson Hine International Trade Update, October 2024
- “U.S. Department of Commerce Proposes Ban on Connected Vehicles Using Chinese or Russian Hardware and Software,” Thompson Hine International Trade Update, September 2024
- Co-author, “Aid Package for Ukraine, Israel, and the Indo-Pacific Incorporates Extensive Sanctions and Export Control Reforms,” The Global Trade Law Journal, Vol. 1, No. 5, September-October 2024
- “Treasury Proposes Rule on U.S. Investments in Certain National Security Technologies and Products in Countries of Concern,” Thompson Hine International Trade Update, July 1, 2024
- “OFAC and BIS Significantly Extend Sanctions and Export Control Restrictions Against Russia and Belarus,” Thompson Hine International Trade Update, June 2024
- “U.S. Aid Package for Ukraine, Israel and the Indo-Pacific Incorporates Extensive Sanctions and Export Control Reforms,” Thompson Hine International Trade Update, May 2024
- “CHIPS Incentives Program – Notice of Funding Opportunity for Small Business Innovation Research Program for CHIPS for America: CHIPS Metrology,” Thompson Hine Global Supply Chain Services Update, May 2024
- Thompson Hine Mobility Matters Quarterly, April 2024
- “National Defense Authorization Act for Fiscal Year 2024 Adds Significant Trade Provisions: New Law Impacts U.S. Export Controls, Sanctions and Supply Chain Management,” Thompson Hine International Trade Update, February 2024
- “BIS Issues Policy Memo on the Voluntary Self-Disclosure Process,” Thompson Hine International Trade Update, January 2024
- Thompson Hine Mobility Matters Quarterly, December 2023
- “Department of Commerce Issues Further Export Controls Targeting China’s Semiconductor Manufacturing and Advanced Computing,” Thompson Hine International Trade Update, November 2023
- “OFAC Loosens Venezuelan Sanctions: Authorizes Transactions Involving Oil and Gas, State-Owned Gold Mining Company, and Certain Debt and Equity of Venezuela and PdVSA,” Thompson Hine International Trade Update, October 2023
- “FinCEN and BIS Issue Supplemental Joint Alert to Reinforce Continued Vigilance of Potential Russian Export Control Evasion Attempts,” Thompson Hine International Trade Update, June 2023
- “Executive Order Issued Restricting U.S. Investments in Chinese Technology; Treasury Seeks Public Comment on Implementation,” Thompson Hine International Trade Update, August 2023
- Thompson Hine Mobility Matters Quarterly – March 2023
- “CFIUS Determines it Has No Jurisdiction Over Proposed Chinese-Owned Real Estate in North Dakota,” Thompson Hine International Trade & Real Estate Update, December 2022
- “Biden Issues Executive Order to Focus the Consideration of National Security Factors in the CFIUS Review Process,” Thompson Hine Business Law Update, Fall 2022
- “New Export Controls Target Support for China’s Advanced Computing and Semiconductor Manufacturing,” Thompson Hine International Trade Update, October 2022
- “Treasury Department Releases CFIUS Enforcement and Penalty Guidelines,” Thompson Hine International Trade Update, October 2022
- “How to Comply with the Uyghur Forced Labor Prevention Act’s Due Diligence Requirements,” Thompson Hine Business Law Update, Summer 2022
- “Provision of Certain Professional Services to Russia Prohibited under U.S. Sanctions,” Thompson Hine International Trade Update, May 2022
- “Summary of Recent Financial and Comprehensive Sanctions Related to the Ukraine-Russia Crisis,” Thompson Hine The Latest on the Ukraine-Russia Crisis, March 2022
- “What Every Company Should Know About the New Uyghur Forced Labor Prevention Act,” Thompson Hine Business Law Update, Winter 2022
- “President Biden Imposes Sanctions Regarding Russia’s Efforts to Undermine Ukraine,” Thompson Hine International Trade Update, February 2022
- “New Multiagency Business Advisory on Heightened Risk of Doing Business in Burma,” Thompson Hine International Trade Update, February 2022
- “Biden Signs Uyghur Forced Labor Prevention Act,” Thompson Hine International Trade Update, January 2022
- “Changes to HTSUS Classifications Expected in January,” Thompson Hine International Trade Update, November 2021
- Quoted, “Deciphering CBP’s WRO guidance: What the updated FAQ changes and what uncertainty remains,” PVTech, November 17, 2021 (subscription required)
- “Treasury Department Issues Updated Advisory on Ransomware Payments,” Thompson Hine International Trade Update, September 2021
- “Annual Blocked Property Reports Due to OFAC on September 30,” Thompson Hine International Trade Update, September 2021
- “China-U.S. Legal and Regulatory Update,” Thompson Hine International Trade Update, August 2021
- “US Government Releases Xinjiang Supply Chain Business Advisory Update,” Thompson Hine International Trade Update, July 2021
- Quoted,“Magnachip May Have Alternative Deal Partners Should Regulatory Approvals Prove Problematic,” CTFN, June 2021
- “DDTC Proposes to Make Pandemic-Related Telework Rules Permanent,” Thompson Hine International Trade Update, June 2021
- “BIS Eliminates Most Mass Market Encryption Reporting Obligations,” Thompson Hine International Trade Update, April 2021
- “United States Implements Multiple Sanctions and Export Restrictions on Russia,” Thompson Hine International Trade Update, March 2021
- “5 Ways To Address Heightened Forced Labor Compliance Risk”, Law360, January 2021
- “Executive Order on Investments in Communist Chinese Military Companies Amended,” Thompson Hine International Trade Update, January 2021
- “CFIUS Reviews of Foreign Investment Continue to Evolve,” Thompson Hine Business Law Update, Winter 2021
- “OFAC Issues Guidance Regarding Ban on Transacting in Securities of ‘Communist Chinese Military Companies,’” Thompson Hine International Trade Update, January 2021
- “Encryption Exports – Annual Self-Classification Reports Due February 1, 2021,” Thompson Hine International Trade Update, January 2021
- “Executive Order Prohibits U.S. Investment in ‘Communist Chinese Military Companies,’” Thompson Hine International Trade Update, November 2020
- “New CFIUS Critical Technology Mandatory Filing Requirements Take Effect October 15,” Thompson Hine International Trade Update, October 2020
- “BIS Publishes Advance Notice of Proposed Rulemaking to Identify and Review Controls on Foundational Technologies: What’s Next?”, Thompson Hine International Trade Update, September 2020
- “FAR Council Publishes Interim Rule on Section 889 Part B Increasing Prohibitions on Contracting with Companies Using Certain Chinese Telecommunications Equipment and Services,” Thompson Hine Government Contracts & International Trade Update, August 2020
- “President Trump Signs the Hong Kong Autonomy Act and Issues Executive Order on Hong Kong Normalization,” Thompson Hine International Trade Update, July 2020
- “Departments of State, Commerce, Homeland Security and the Treasury Caution Businesses Regarding Human Rights Abuses in Xinjiang,” Thompson Hine International Trade Update, July 2020
- “Section 889 Part B Expands Ban on Federal Contracting with Companies Using Chinese Company Equipment and Services,” Thompson Hine International Trade & Government Contracts Update, July 2020
- “Beyond NAFTA: USMCA Goes into Effect July 1,” Thompson Hine International Trade Update, June 2020
- Co-author, “COVID-19 Mitigation May Trigger New Tech Export Restrictions,” Law360, June 2020
- “INSIGHT: Companies Must Prioritize Anti-Bribery Compliance During the Pandemic,” Bloomberg Law, May 2020
- “Commerce Issues Interim Final Rule Addressing Foreign-Produced Direct Products and Specifically Targets Huawei Technologies Co., Ltd.,” Thompson Hine International Trade Update, May 2020
- “Recent Executive Actions Focus on Bulk-Power System Grid Security and Supply Chain,” Thompson Hine International Trade Update, May 2020
- “GSA Class D&F Provides TAA and BAA Non-Availability Exception for Certain Supplies,” Thompson Hine COVID-19 Update, April 2020
- “Petitions by Vehicle Producers for Alternative Staging Regime for Compliance with USMCA Rules of Origin for Automotive Goods Due to USTR by July 1,” Thompson Hine International Trade Update, April 2020
- “OFAC Issues Fact Sheet on Providing Humanitarian Aid to Combat COVID-19 Under Various Sanctions Programs,” Thompson Hine COVID-19 Update, April 2020
- Quoted, “Thompson Hine Nabs Winston & Strawn Int’l Trade Atty In DC,” Law360, April 2020
- “Government Measures Worldwide in Response to COVID-19,” Thompson Hine COVID-19 Update, April 2020
- “FEMA Announces Export Restrictions on Personal Protective Equipment (PPE),” Thompson Hine COVID-19 Update, April 2020
- Quoted, “Pandemic Puts National Security Focus on Biotech, Health Sectors,” Bloomberg Law, April 2020
- “COVID-19 and International Trade: Status of Trade-Related U.S. Government Agencies & Courts and Helpful Online Resources,” Thompson Hine COVID-19 Update, March 2020
- “Treasury Proposes Regulations to Institute CFIUS Filing Fees; Comments Due April 8,” Thompson Hine International Trade Update, March 2020
- “The Intersection of International Trade Law and Business Operations,” Thompson Hine webinar series, February-March 2024
- Co-presenter, “China, Russia-and the Interplay of Export Controls and Sanctions: The Biggest, Most Enduring Compliance and Enforcement Risks Confronting Canadian Industry,” Forum on U.S. Export & Re-Export Compliance for Canadian Operations, January 2024
- Co-presenter, “CHIPS Incentives Funding Hine Applications: Legal Considerations,” Thompson Hine webinar, November 2023
- Presenter, “Latine In-House: Diversifying the Talent Pipeline,” Thompson Hine webinar, October 16, 2023
- Presenter, “Global Supply Chain Challenges: Forced Labor, Tariffs, Theft and Digitial Security,” Ohio Chemistry Technology Council Annual Meeting, May 2023
- Panel Member, “An ESG Collaborative Roundtable: Developing Best Practices for Navigating the Moving Target That is ESG,” Thompson Hine ESG Collaborative Workshop, January 2023
- Co-presenter, “Uyghur Forced Labor Prevention Act: Supply Chain Risk Management Guidance,” Thompson Hine webinar, July 2022
- Co-presenter, “Potential CFIUS Issues When Taking on Foreign Capital,” Thompson Hine Startups Streamlined podcast, March 2022
- Co-presenter, “The Ukraine Crisis: The Impact of Sanctions on Russia,” Northwest Pennsylvania Regional Planning and Development Commission, March 2022
- Presenter, “The Global Ripple Effect of the Ukraine-Russia Crisis: The Impact of Sanctions,” Thompson Hine webinar, March 2022
- Presenter, “The Global Ripple Effect of the Ukraine-Russia Crisis: The Potential Impact of Sanctions,” Thompson Hine webinar, February 2022
- Presenter, “Addressing Forced Labor Risk in Supply Chains,” Thompson Hine webinar, October 2021
- Co-presenter, “Considerations for Cross-Border M&A: Canada, the UK & the US Trends in Antitrust & National Security Merger Review,” Thompson Hine webinar, February 2021
- Presenter, “Avoiding Forced Labor in International Supply Chains,” Thompson Hine webinar, November 2020
- Presenter, “Beyond NAFTA: Navigating the Impact of USMCA – A Virtual Roundtable Series – Session 4: Supply Chains,” Thompson Hine webinar, July 2020
- Selected for inclusion in Chambers USA: America’s Leading Lawyers for Business, International Trade: Export Controls & Economic Sanctions, 2024
- Selected to Law360’s International Trade Editorial Advisory Board, 2023, 2025
Professional Associations
- International Bar Association
- HNBA, Compliance & Ethics Section
Community Activities
- Elder, First Presbyterian Church of Arlington, VA
Education
- Harvard Law School, J.D., 2006
- Princeton University, B.A., 2002, magna cum laude
Bar Admissions
- District of Columbia
- Virginia
Court Admissions
- U.S. Court of International Trade
- USTR Proposes Actions Against China’s Unfair Trade Practices in Maritime, Logistics, and Shipbuilding Sectors,
International Trade and Transportation Update
, March 5, 2025 - President Trump Issues America First Investment Policy Memorandum Impacting FDI into the U.S. and Outbound Investment to Foreign Adversaries,
Transition – A Presidential Change Update
, February 27, 2025 - Mobility Matters Quarterly – February 2025, February 26, 2025
- U.S. Department of Commerce’s BIS Enhances Its Enforcement Discretion: Revamps Voluntary Self-Disclosure Process, Abolishes Penalty Caps, and Amends Penalty Guidelines,
The Global Trade Law Journal
, January 21, 2025 - Mobility Matters Quarterly – October 2024, October 9, 2024
- BIS Enhances Its Enforcement Discretion: Revamps Voluntary Self-Disclosure Process, Abolishes Penalty Caps and Amends Penalty Guidelines,
International Trade Update
, October 7, 2024 - U.S. Department of Commerce Proposes Ban on Connected Vehicles Using Chinese or Russian Hardware and Software,
International Trade Update
, September 25, 2024 - Aid Package for Ukraine, Israel, and the Indo-Pacific Incorporates Extensive Sanctions and Export Control Reforms,
The Global Trade Law Journal
, July 9, 2024 - Treasury Proposes Rule on U.S. Investments in Certain National Security Technologies and Products in Countries of Concern,
International Trade Update
, July 1, 2024 - OFAC and BIS Significantly Extend Sanctions and Export Control Restrictions Against Russia and Belarus,
International Trade Update
, June 24, 2024