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 […]
Question: I am struggling with an Anti-Boycotting issue and could use some help. Section 760.3 (a) permits U.S. companies to “comply or agree to comply” with the Arab League Boycott , due to the importing requirements of that country. If this means a U.S. company may refuse to provide goods or services of Israeli origin […]
Question: Can anyone from the membership advise what the potential violation and associated penalties are for not reporting an anti-boycott statement in a timely manner. **************** ANSWERS: If you’re asking whether you can include a reportable item that should have been submitted in a previous reporting period in a current report, I believe the answer […]
Question:My company recently opened a sales office in the UAE. I believe that we are now required to file a periodic report with the Internal Revenue Service with certain information related to the Arab League boycott of Israel. This is in addition to the BIS Antiboycott regulations. Can someone refer me to a clear description […]
Question: Can anyone in the ICPA Membership share any training material or processeson Antiboycott?
Question: I have a question regarding boycott language on certificates of origin and ocean bills of lading. A, a US company purchases products from foreign country B and ships direct from B to foreign destination C. Country B provides A with a certificate of origin and original bills of lading, both containing boycott […]
Letter of Credit for Saudi Arabia – Certificate of Origin Documents required – Certificate of Origin – no big deal – but then they ask for a “form no 2” if there are “any parts or components of the goods described in the c/o that are the products of such country …other than the country […]