Meshkat Law advises clients on U.S. antiboycott laws and regulations administered by the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) under the Export Administration Regulations (EAR) and the U.S. Department of the Treasury’s Internal Revenue Service (IRS). We help companies identify and manage boycott-related requests, comply with applicable reporting obligations, and address enforcement and remedial matters when potential violations are identified.
BIS and the IRS both administer U.S. antiboycott authorities that are designed to discourage, and in some circumstances prohibit, U.S. persons from participating in or supporting foreign boycotts of countries friendly to the United States. These rules can restrict how U.S. companies respond to certain requests relating to counterparties, shipping routes, contract clauses, certifications, and other commercial documents, particularly where the underlying boycott is not sanctioned by the U.S. government.
Under BIS-administered antiboycott regulations, companies must not take specified actions in furtherance of or support for unsanctioned foreign boycotts, and they may be required to report the receipt of certain boycott-related requests. IRS antiboycott rules can impose separate tax-related consequences for participation in or cooperation with unsanctioned boycotts. For companies operating in regions where boycott-related language is common in commercial documentation, antiboycott compliance often requires careful review of incoming requests and clear internal escalation processes.
BIS’s Office of Antiboycott Compliance (OAC) enforces the antiboycott rules of the Export Administration Regulations (EAR), including by investigating potential violations, imposing penalties, and maintaining a public Boycott Requester List that identifies parties alleged to have made boycott-related requests. Being identified on that list can create reputational and commercial challenges. Against this backdrop, companies benefit from a structured approach to antiboycott compliance that combines screening, document review, reporting processes, and clear guidance on what employees may and may not agree to in response to customer and counterparty demands.
We assist clients in identifying and evaluating boycott-related language in contracts, tenders, purchase orders, letters of credit, questionnaires, and other commercial documents. Our work includes advising whether particular provisions or requests are problematic under BIS and IRS antiboycott rules, recommending alternative language or approaches, and helping design escalation frameworks so that potentially sensitive requests are reviewed before acceptance or rejection. We also provide tailored antiboycott training for organizations whose personnel are likely to encounter boycott-related language under their job responsibilities.
We represent clients in meeting their antiboycott reporting obligations to BIS and the IRS, including preparing and submitting required boycott reports and coordinating the underlying fact-gathering and documentation.
We represent clients in antiboycott enforcement matters before BIS’s OAC, including responding to investigative inquiries, negotiating resolutions, and addressing proposed penalties and remedial commitments in a manner consistent with the EAR and its guidance on charging and penalty determinations involving antiboycott matters. Where potential antiboycott violations are identified, we help clients assess their exposure and, where appropriate, prepare voluntary self-disclosures to address those issues with BIS under its antiboycott voluntary self-disclosure procedures.
For more information on our broader BIS enforcement and investigations work, please see our BIS Enforcement & Investigations page.
We advise parties identified on BIS’s Boycott Requester List on seeking removal from the list, including investigating the basis for listing, advising on remedial steps, and preparing targeted submissions and engagement with OAC to demonstrate that the original basis for listing was erroneous or no longer applies. We bring experience with prior Boycott Requester List removals to help shape effective removal strategies.
Prior results do not guarantee a similar outcome.
Related Reading
Removal from the BIS Boycott Requester List →Contacting Meshkat Law, P.C. by email, telephone, or this contact form will not establish an attorney-client relationship or obligate the firm to act as your attorney. All new clients and matters must first be processed through the firm’s intake process, including a conflicts check, prior to establishing an attorney-client relationship. Please do not send confidential information until we confirm that there are no conflicts.
Antiboycott Counseling and Document Review