By: John Black
In the October 15, 2003 Federal Register the Treasury Department published a notice identifying 10 countries that may require cooperation with an international trade boycott not sanctioned by the United States. The ten countries are:
Bahrain, Kuwait, Lebanon, Libya, Oman, Qatar, Saudi Arabia, Syria, United Arab Emirates, Republic of Yemen.
Companies in these countries may require that you comply with the Arab League boycott of Israel. If you are a US company, a US citizen/resident, or a subsidiary of a US company, compliance with the secondary and tertiary levels of the Arab boycott of Israel may be a violation of US antiboycott rules found in the Export Administration Regulations and section 999(b)(3) of the Internal Revenue Code of 1986.
Generally speaking, the key provisions of the US antiboycott rules prohibit US persons from complying with the Arab boycott of Israel. Prohibited cooperation could include 1) refusing to do business with a company or country; and 2) supplying information about your business relationship with other companies or countries.
This list is useful in that it highlights the countries from which you are most likely to receive prohibited boycott requests or inquiries. You should focus your antiboycott compliance procedures on these countries. Please note, however, that EAR antiboycott issues may also arise when dealing with any country, but you also pay close attention to Indonesia, Bangladesh, Pakistan, Iran, India, Ethiopia, and Eritrea.