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:

JurisdictionCount of Companies Issuing Boycott Requests
Saudi Arabia9
United Arab Emirates9
Hong Kong1
Marshall Islands1
United Kingdom1

The authors acknowledge the assistance of Ryan Orange with the preparation of this blog post.


Ms. Contini focuses her practice on export controls, trade sanctions, and anti-boycott laws. This includes advising US and multinational companies on trade compliance programs, risk assessments, licensing, review of proposed transactions and enforcement matters. Ms. Contini works regularly with companies across a wide range of industries, including the pharmaceutical/medical device, oil and gas, and nuclear sectors.


Ms. Test advices clients on issues relating to licensing, regulatory interpretations, enforcement actions, internal investigations and compliance audits, as well as the design, implementation and administration of compliance programs. She also advises clients on the extra-territorial application of trade compliance-related regulations in cross-border transactions.