Anti-Boycott Update

Bureau of Industry and Security (BIS) published its third quarterly update of the boycott Requester List.

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.

A party’s inclusion on the boycott Requester List does not mean that U.S. persons are restricted from dealing with the listed party. However, a party’s inclusion puts U.S. persons 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 38 additions. BIS also removed over 20 entities. Today’s announcement builds on the second quarterly update published in October.

“The boycott Requester List has been a dynamic and innovative addition to antiboycott enforcement,” said Assistant Secretary for Export Enforcement Matthew S. Axelrod. “Since its inception in March 2024, the boycott Requester List has made it easier for U.S. persons to fulfill their reporting responsibilities by raising awareness of sources of boycott-related requests. 

"Even more significantly, more than 40 entities have now been removed from the List for ceasing to include boycott conditions in their transaction documents with U.S. persons.”

Firms removed from the list include Siemens Energy Global GMBH & CO KG of Germany,  Saudi operations of Waste Management, and Malaysian operations of nine firms, including Flextronics and Halliburton.

Additions to the list include seven Malaysian entities, six from Bangladesh, four from Saudi and the UAE, three from Turkey and Pakistan, and others, including the UK, Libya, Japan and Australia.

Each entity on the boycott Requester 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. 

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.