Background

The Bureau of Industry and Security has issued a final rule that, effective Oct. 7, updates a regulatory provision categorizing anti-boycott violations by their seriousness “to better comport with current boycott-related activity and to better align BIS’s penalty determinations with the agency’s view of the seriousness of the alleged violations.”

Category A violations typically warrant the most stringent penalties, including up to the maximum monetary penalty, a denial order, and/or an exclusion order, and BIS is therefore revising this category to include only those violations deemed the most serious. Specifically, “furnishing information about associations with charitable or fraternal organizations that support a boycotted country” is being moved from Category B to Category A.

To reflect shifting trends in boycott activity, BIS is revising Category B to include violations that most commonly and currently arise in commercial transactions in a boycott context. Specifically, this rule moves “knowingly agreeing to refuse to do business,” “implementing letters of credit,” and “furnishing information about business relationships with boycotted countries or blacklisted persons” from Category A to Category B. Category B violations will be the focus of BIS’ antiboycott enforcement and subject to enhanced penalties to discourage cooperation with boycott-related requirements and to promote awareness, accountability, and deterrence.
For more information on anti-boycott requirements, please contact attorney Kristine Pirnia via email.

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