BIS updates Boycott Requester List

The US Department of Commerce’s Bureau of Industry and Security (‘BIS’) has published its second quarterly update of the Boycott Requester List which is used to notify ‘companies, financial institutions, freight forwarders, individuals, and other US persons of potential sources of certain boycott-related requests they may receive during the regular course of business.’

The updated list includes 36 new entities, ‘who have been identified as having made a boycott-related request in reports received by BIS,’ the agency said in a news release, 1 October. It said the names of 21 entities have been removed.

Inclusion on the Requester List does not restrict US persons from dealing with the listed parties. Instead, it serves as a notice that these parties are more likely to make reportable boycott-related requests. Each entity on the list has been reported to BIS on a boycott request report form, as required by Section 760.5 of the Export Administration Regulations (‘EAR’).

‘The boycott Requester List has had a meaningful impact on both antiboycott compliance and antiboycott enforcement,’ said Assistant Secretary for Export Enforcement Matthew 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.’

US persons are encouraged to diligently review transaction documents from all sources, especially those involving listed parties, to identify possible boycott-related language and to determine whether US person recipients have a reporting requirement to BIS.

In examples of boycott requests the BIS has provided in the past, the large majority are from Islamic countries instructing that goods of Israeli origin are not acceptable, or that shipments must not show an Israeli nexus.

Qatar Airways landed on the list in June, when BIS released its first quarterly update of the list.

The 21 parties removed from the Requester List were from a host of countries, including Switzerland, Japan and Singapore, but most from Muslim nations like Saudi Arabia, Qatar, Malaysia and Bangladesh.

https://www.bis.gov/press-release/bis-updates-boycott-requester-list-0