On April 3, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) released its quarterly update to 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. 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 Update of July 28, 2023. The updated list can also be downloaded in Excel format from the BIS Office of Antiboycott Compliance website.
The updated list adds 30 foreign companies that have made boycott-related requests, and BIS has removed 18 companies from the previous version of the list. A list of those removed is available here. 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.