By now, we have all seen the updates to the Boycott Requester List from the Department of Commerce’s Bureau of Industry and Security (BIS), with the most recent update on April 3, 2025. This blog aims to address the fundamental question: What exactly is this list, and more critically, what are the implications if an entity with which your company is transacting with appears on the list.
Background
For over 20 years, United States entities that have received a boycott request have been required to report those details to the Bureau of Industry and Security (BIS). U.S. antiboycott laws prevent U.S. persons from participating in economic boycotts by other countries that are not sanctioned by the U.S., and they also mandate that boycott requests are reported to BIS. To gain a deeper understanding of anti-boycott laws, I encourage you to review a previously written blog: Stay Ahead: Navigate Anti-Boycott Laws with Confidence.
In March of 2024, BIS began publishing a Boycott Requester List, which publicly identifies the names of entities that have made boycott-related requests to U.S. companies, including requests to comply with the Arab League boycott of Israel, with the aim of helping U.S. businesses comply with the Export Administration Regulations’ antiboycott provisions in 15 C.F.R. Part 760.
What is the Boycott Requester List?
Issued quarterly by the Bureau of Industry and Security (BIS) through the Office of Antiboycott Compliance (OAC), this list assists companies in adhering to antiboycott regulations by identifying entities that have previously submitted reportable boycott requests. Note that this list is not static and changes quarterly, meaning an entity that was on the list last quarter may or may not still be the list this quarter. This is because entities added to the list may initiate a removal process through a petition or appeal. This action is contingent upon demonstrating either an error in the initial addition or a significant change in circumstances, such as verifiable measures taken to cease requesting compliance with unsanctioned foreign boycotts.
The intention of the list is to notify companies, financial institutions, freight forwarders, individuals, and other U.S. persons regarding potential sources of specific boycott-related requests that they may encounter during their routine business activities. As a publicly available resource, it identifies entities that have made boycott-related requests in reports received by BIS, aimed at enhancing enforcement and compliance with U.S. antiboycott regulations.
In simpler terms, inclusion on this list indicates that these parties have requested U.S. persons to participate in a boycott not sanctioned by the U.S. Government.
What if the entity that I am doing business with is on the list?
A match on the Boycott Requester List does not automatically preclude conducting business with the listed entity. Rather, it serves as an alert to exercise increased vigilance in transactions with that party. This caution is advised to ensure that you are neither asked to comply with prohibited boycott requests nor inadvertently overlooking such requests that must be reported to the U.S. Government.
The presence of a party on this list indicates to U.S. individuals that the listed party has an elevated likelihood of presenting boycott-related requests that may require reporting. BIS recommends that U.S. individuals carefully examine transaction documents from all sources, particularly those involving listed parties, to detect any language related to boycotts and to ascertain whether any reporting obligations exist. This list should be integrated into companies’ due diligence procedures when assessing transactions.
All transaction documents should be diligently reviewed for boycott language, but especially those with or involving those listed entities as we know 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.
Positive outcomes:
The good news is that since this list has been released, many foreign companies have changed their behavior. Specifically, since the list was implemented, more than 20 foreign entities have certified to the US that they have ceased imposing boycott-related requirements in their transactions with US persons which demonstrates the effectiveness of the list in promoting compliance and protecting US interests.
Need help navigating the Boycott Requestor List or ensuring your company’s compliance procedures are up to date? Schedule a no-charge consultation with one of our experts to assess your risk, review your documentation, and strengthen your antiboycott compliance strategy.
Kristine Kelleher is a Trade Compliance Consultant for Export Solutions -- a full-service consulting firm specializing in U.S. import and export regulations.