BIS EAR Amendment: UAE Removal from Arab League Boycott of Israel List

Mechanism

UAE Federal Decree-Law No. 4 of 2020, issued on 16 August 2020, formally terminated the UAE's participation in the Arab League Boycott of Israel. This was part of the Abraham Accords normalisation package signed in September 2020 between the UAE and Israel, brokered by the United States.

Under EAR Part 760, US persons are prohibited from complying with, or taking actions that further, unsanctioned foreign boycotts. Before this rule, UAE entities were on the Supplement No. 1 to Part 760 list — meaning requests from UAE parties (e.g., requests to certify that goods are not of Israeli origin, or to refuse to do business with Israeli companies) were presumed to be boycott-related and therefore potentially prohibited or reportable under the EAR.

The June 2021 BIS final rule: 1. Removes UAE from Supplement No. 1 to Part 760 (the list of countries requiring cooperation with an international boycott). 2. Establishes a retroactive effective date of 16 August 2020, so UAE-origin requests issued on or after that date are not treated as boycott-related. 3. Conforms the EAR to parallel actions taken by the Department of the Treasury (which removed the UAE from its boycott-country list in April 2021) and the Department of State (which certified the termination to Congress on 22 April 2021).

Downstream implications

• US exporters, re-exporters, and US persons no longer face EAR Part 760 reporting or

compliance obligations with respect to UAE-origin boycott-related requests.

• The rule facilitates direct US-UAE-Israel supply chains without boycott-compliance friction,

supporting post-Abraham Accords commercial integration.

• The retroactive effective date (2020-08-16) means potential Part 760 violations from the

2020-08-16 to 2021-06-09 window that were predicated solely on UAE's former boycott status would be remediated, reducing retroactive enforcement exposure for US companies that continued trading with UAE after the Accords.

• The regulatory alignment (BIS, Treasury, State) closes the full US-government recognition

loop for the UAE-Israel normalisation — de-risking financial and commercial transactions across the three regulatory perimeters simultaneously.

Open questions

• Whether other Abraham Accords parties (Bahrain, Morocco, Sudan) have completed or will

complete analogous EAR removals; Bahrain's status on Supplement No. 1 to Part 760 was not addressed in this rule.

• Long-term effect on UAE as a trans-shipment point for Israel-facing goods previously

routed around boycott-compliance requirements.