The Bureau of Industry and Security has published its first quarterly update to a list of entities identified as having made a boycott-related request in connection with a transaction in U.S. interstate or foreign commerce. This update reflects the addition of 57 entities and the removal of 127 that were misidentified as having made a reportable boycott request or that removed boycott language in transaction documents with U.S. entities.

The anti-boycott provisions set forth in Part 760 of the Export Administration Regulations discourage, and in certain circumstances prohibit, U.S. persons from taking certain actions in furtherance or support of a boycott maintained by a foreign country against a country friendly to the U.S. Boycott-related actions could see an increase amid ongoing conflicts in the Middle East, and U.S. companies and their foreign affiliates can be hit with substantial criminal and civil penalties if they violate related U.S. laws and regulations.

The EAR also require U.S. persons to report to BIS their receipt of certain boycott-related requests. Reports may be filed electronically or by mail on form BIS-621P for single transactions or on form BIS-6051P for multiple transactions involving boycott requests received in the same calendar quarter.

BIS recently started publishing a list to help companies, freight forwarders, and others identify boycott-related requests they may receive during the regular course of business. BIS encourages U.S. persons to diligently review transaction documents from all sources, but especially those involving the parties on this list, to identify possible boycott-related language and determine whether they need to report it to BIS.

For more information on complying with anti-boycott requirements, please contact attorney Kristine Pirnia at (202) 730-4964 or via email.

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