The Bureau of Industry and Security has imposed a $48,750 civil penalty against a U.S. company to resolve 13 violations of the anti-boycott provisions of the Export Administration Regulations. Assistant Secretary of Commerce for Export Enforcement Matthew Axelrod said this enforcement action “highlights the need for robust antiboycott training and compliance procedures.”

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.

In this case, however, the company failed to report a request from a foreign customer to refrain from importing Israeli-origin goods into the customer’s home country in fulfillment of purchase orders from the customer.

Companies may submit a voluntary self-disclosure if they believe they may have violated the anti-boycott provisions. BIS notes that in this case the company did voluntarily disclose the conduct, cooperated with the investigation by BIS’s Office of Antiboycott Compliance, and took remedial measures, all of which resulted in a significant penalty reduction.

Click here for more information about anti-boycott provisions and penalties.

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