On December 30, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released a year-end update of the Boycott Requester List. This list notifies companies, financial institutions, freight forwarders, individuals, and other U.S. persons of potential sources of certain boycott-related requests they may receive during the regular course of business. Introduced in March 2024, this resource is a public list of entities identified as making boycott-related requests in reports received by the BIS and follows the BIS July 2023 policy memo implementing efforts to enhance enforcement and compliance with U.S. antiboycott regulations. See Thompson Hine Updates of July 28, 2023 and March 29, 2024. The updated list can also be downloaded in Excel format from the BIS Office of Antiboycott Compliance website.
A party’s inclusion on the Boycott Requester List does not mean that U.S. persons are restricted from dealing with the listed party. However, a party’s inclusion puts U.S. persons on notice that the listed party is more likely to make reportable boycott-related requests. BIS encourages U.S. persons to review transaction documents from all sources, especially those involving these listed parties, to identify possible boycott-related language and to determine whether there is any reporting requirement. The updated public list includes 38 additional entities, but also has removed over 20 entities from the previous version of the list. A list of those removed is available here.