Question: I’m updating training on US export controls and would like to include some real-life examples of boycott requests preferably aside from Israel with some other countries making such requests. Answer 1: I have hundreds of these, all real life, that I’ve accumulated over the years…here are a couple: Certificate issued by shipping company or […]
Question: I would like to understand what the members are doing regarding anti-boycott compliance. What measures do you have in place to help the Business identify boycott-related requests they may receive during the regular course of business? Regular training? Quarterly reporting? Answer 1: There is nothing new here, other than a bit of ramped up […]
Question: I hope someone can help me understand the Antiboycott rules. I recently discovered on one of our customers routing instructions the phrase “No Israel COO origin product is allowed to ship using this way into Malaysia”. Would this fall under the antiboycott rules? Is this something that needs to be disclosed to BIS/OAC? Correct […]
Question: If an overseas supplier is printing the following statement on the invoice to a US importer, is that a violation of US anti-boycott laws? “We undertake not to load the goods on board of Israeli vessels or on ships blacklisted by Israeli Boycott Office of calling at an Israeli Port.” Answer 1: Much such […]
Question: My question pertains to whether the listed companies, operating outside of the US, are also covered by the Antiboycott Request List, considering that these companies conduct business through distributors not on the list. Furthermore, I would appreciate clarification on the compliance processes we need to adhere to for the companies listed on the Antiboycott […]
QUESTION: I work for a US company and we are entering to the Saudi Arabian market. Our company understands that we can not participate in boycotts, but what happens if any of our suppliers or clients in this territory are participating in a boycott? Would we be breaking the law? Should our company add a […]
QUESTION: Is a clause containing language of “no parts shall include material, component, or processes made or performed in China” from a Taiwan customer prohibited under anti-boycott regulations? Is this reportable to Commerce and Treasury? %%%%%%%%%% ANSWERS: Office of Antiboycott Compliance https://www.bis.doc.gov/index.php/enforcement/oac#Compliance %%%%%%%%%% No, it is not prohibited. There is no recognized boycott in place […]
QUESTION: Does anyone have, and is willing to share, a good boycott language cheat sheet with real-world examples? I don’t mean the examples published by the government, I mean a detailed list with actual language. Including the differences between BIS and Treasury. I have a handle on the obvious stuff, but get tripped up when […]
QUESTION: We are interested in implementing an automated reminder in our ERP system for our sales order entry group to carefully scan purchase orders for boycott language from customers/distributors located in a boycott watch country. We envision establishing a background table that allows us to modify the boycott watch countries as they change and implement […]
QUESTION: I understand clearly that issuing a NEGATIVE certificate of origin is PROHIBITED by part 760 of the EAR. My question is, what part does it offend, is it 760.2(a) “refusal to do business”, or 760.2(d) “furnishing information about business relationships” (or one of the other 760.2 sections)? ************** Answers: I would actually refer you […]
Question: Does the rejection of goods by countries in middle east because the packaging contains Hebrew language (among others) give rise to antiboycott concerns? ========== Answer: Yes, that is an anti-boycott concern. You should report this in your quarterly report to BIS. ========== I would say Yes. Did they give a reason for the rejection […]
Question: Per the new TSA Directive, a security declaration which indicates that none of the cargo…. originated in….Egypt, Syria, Somalia or Yemen is required on imports. According to our colleagues in the EU, this is possibly a boycott type of violation under German Foreign Trade Regulation §7AWV. How are others that import from […]
