Last month, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published updated guidance materials for freight forwarders and exporters and updated their “Don’t Let This Happen to You” guidance document. BIS also published a new resource to help identify boycott-related requests.
Updated Guidance
BIS issued updated guidance for freight forwarders and exporters who use freight forwarders to help them ensure compliance with US export controls and regulatory requirements. The guidance outlines compliance responsibilities, best practices, and red flags that freight forwarders and exporters should monitor.
BIS also issued a new version of their “Don’t Let This Happen to You” guidance document, which includes summaries and examples of export compliance investigations.
New Antiboycott Compliance Resource
BIS has published a new list of entities who have been 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 companies, freight forwarders, and financial institutions comply with the antiboycott regulations set forth in Part 760 of the Export Administration Regulations (“EAR”). US persons are encouraged to diligently review transaction documents from all sources to identify possible boycott-related language and determine potential reporting requirements to BIS. In particular, transaction documents involving these listed parties should be carefully reviewed given that they’ve been identified by others as a source of boycott requests.
The list is not exhaustive and will be updated quarterly. Companies from Bangladesh, Pakistan and Malaysia make up the majority of the listed companies . We tallied up the companies that BIS identified in the first iteration of this new list and created a table organizing them by jurisdiction from the highest to lowest number of companies:
| Jurisdiction | Count of Companies Issuing Boycott Requests |
| Bangladesh | 51 |
| Pakistan | 48 |
| Malaysia | 37 |
| Qatar | 10 |
| Saudi Arabia | 9 |
| United Arab Emirates | 9 |
| Kuwait | 6 |
| Singapore | 5 |
| Oman | 4 |
| Bahrain | 3 |
| India | 3 |
| Libya | 3 |
| Egypt | 2 |
| Iraq | 2 |
| Japan | 2 |
| Brazil | 1 |
| Germany | 1 |
| Hong Kong | 1 |
| Marshall Islands | 1 |
| Turkey | 1 |
| United Kingdom | 1 |
The authors acknowledge the assistance of Ryan Orange with the preparation of this blog post.
