The Bureau of Industry and Security reports that a manufacturer of defense weapon systems has agreed to pay a $48,500 civil penalty, and a defense contractor has agreed to pay a $44,750 civil penalty, for violating the Export Administration Regulations by (1) furnishing information about their business relationships with boycotted countries or blacklisted persons and (2) failing to report their receipt of requests to take action in support of an unsanctioned foreign boycott.
BIS notes that each company secured a significant reduction in its penalty by voluntarily self-disclosing the conduct, cooperating with the investigation by BIS’s Office of Antiboycott Compliance, and taking remedial action after discovering the conduct.
According to BIS, both companies participated in a trade show in Bahrain in 2019. In connection with the shipment of products for display at that show, each company furnished to its freight forwarder a commercial invoice/packing list certifying that the goods were not of Israeli origin and not manufactured by a company on the “Israeli Boycott Blacklist” (a boycott-based list of persons with whom a boycotting country requires U.S. persons to refuse to do business).
The anti-boycott provisions of the EAR 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. In addition, U.S. persons must report their receipt of certain boycott-related requests, whether or not they intend to comply with them.
Copyright © 2025 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.