Commerce Introduces Boycott Blacklist

In line witht he Administration's renewed focus on antiboycott enforcement, the Commerce Department has introduced a public list of entities identified as having made a boycott-related request in reports received by BIS.

The list is posted on the Office of Antiboycott Compliance (OAC) webpage with the objective of helping U.S. persons comply with the antiboycott regulations set forth in Part 760 of the Export Administration Regulations, 15 CFR Parts 730-774 (EAR).  

“Today’s announcement reflects BIS’s enhanced enforcement of the antiboycott regulations, including a focus on not just those receiving, but also those making, boycott requests,” said Assistant Secretary for Export Enforcement Matthew S. Axelrod. “By publishing this list, we aim to raise awareness of the sources of past boycott requests, facilitate fulfillment of the antiboycott reporting requirements, and deter foreign parties from imposing – and U.S. parties from acquiescing to – boycott-related requests and conditions.”   

Each entity on this list has been recently reported to BIS on a boycott request report form, as required by Section 760.5 of the EAR, as having made a boycott-related request in connection with a transaction in the interstate or foreign commerce of the United States.

The list is not exhaustive and will be updated quarterly. If you believe that you have been listed in error or would like to discuss the listing, please contact OAC.   

Antiboycott Background

U.S. persons are encouraged to diligently review transaction documents from all sources, but especially transaction documents with or involving these listed parties – given that they’ve been identified by others as a source of boycott requests – to identify possible boycott-related language and to determine whether U.S. persons have a reporting requirement to BIS pursuant to Part 760 of the EAR. The boycott request reporting form can be found here.   

The antiboycott provisions set forth in Part 760 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 United States (an unsanctioned foreign boycott). 

In addition, U.S. persons must report to OAC 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.

U.S. persons located in the United States must postmark or electronically date stamp their reports by the last day of the month following the calendar quarter in which the underlying request was received. For U.S. persons located outside the United States, the postmark or date stamp deadline is the last day of the second month following the calendar quarter in which the request was received. Forms for both electronic transmission and mail submission may be accessed from the forms request page. 

Pursuant to Section 764.8 of the EAR, a party may submit a voluntary self-disclosure if it believes that it may have violated Parts 760 or Part 762 of the EAR (recordkeeping requirements relating to Part 760). 

For information regarding the application of the antiboycott regulations, please contact the OAC Advice Line at (202) 482-2381 or through the online porta