Anitboycott List Shows Breadth of Offenders

The Department of Commerce’s Bureau of Industry and Security (BIS) published its second quarterly update of the boycott Requester List October 1st.  This list notifies companies, financial institutions, freight forwarders, individuals, and other U.S. persons of potential sources of certain boycott-related requests they may receive during the regular course of business.

Of note, many recent reports come from customers outside the Arab world, including Japan, Brazil, Hong Kong, and the United Kingdom.   The greatest number of non-arab boycott requests originated in Bangladesh, Malaysia and Pakistan. 

A party’s inclusion on the Requester List does not mean that U.S. persons are restricted from dealing with the listed party; a party’s inclusion does mean that U.S. persons are on notice that the listed party is more likely to make reportable boycott-related requests.

The updated public list of entities who have been identified as having made a boycott-related request in reports received by BIS includes a total of 36 additions. BIS has also removed 21 entities. Today’s announcement builds on the first quarterly update in June.

“The boycott Requester List has had a meaningful impact on both antiboycott compliance and antiboycott enforcement,” said Assistant Secretary for Export Enforcement Matthew S. Axelrod. “The Requester List has also changed behavior – since the list was implemented, more than 20 foreign entities have certified to us that they have ceased imposing boycott-related requirements in their transactions with U.S. persons.” 

Each entity on this list has been recently reported to BIS on a boycott request report form, as required by Section 760.5 of the Export Administration Regulations (EAR), as having made a boycott-related request in connection with a transaction in the interstate or foreign commerce of the United States. New additions are identified on the Requester List by “September 2024” in column C. If you believe that you have been listed in error or would like to discuss a listing, please contact the Office of Antiboycott Compliance (OAC). 

U.S. persons are encouraged to diligently review transaction documents from all sources, especially those involving these listed parties, to identify possible boycott-related language and to determine whether U.S. person recipients have a reporting requirement to BIS. The boycott request reporting form can be found here.  

The updated boycott Requester List is posted on the OAC webpage link with the objective of helping U.S. persons comply with the reporting requirements of the antiboycott regulations set forth in Part 760 of the EAR, 15 CFR Parts 730-774.