Regulatory basis
EAR Part 760 (15 C.F.R. § 760) prohibits US persons from complying with, or taking actions that further, unsanctioned foreign boycotts — principally the Arab League Boycott of Israel. Supplement No. 1 to Part 740 lists the countries whose requests are presumed to be boycott-related and therefore potentially prohibited or reportable.
BIS amends the Supplement No. 1 list when a country formally terminates its participation in the relevant boycott. Each de-listing retroactively removes compliance obligations for US persons receiving UAE/Gulf-origin trade inquiries, effectively eliminating the need to report or refuse potentially boycott-related requests from those jurisdictions.
The Abraham Accords (UAE-Israel normalisation, 2020; Bahrain-Israel, 2020; Morocco-Israel, 2020; Sudan-Israel, 2020) triggered a wave of US regulatory de-listing actions as each signatory issued the relevant domestic decree.
Member actions
1. 2021-06-09 UAE removal from Supplement No. 1 (severity 2). Retroactive to UAE Federal Decree-Law No. 4 of 2020 (16 August 2020). Completes the BIS/Treasury/State US-government recognition loop for the UAE-Israel Abraham Accords normalisation.
2. 2022-10-07 BIS enhanced antiboycott civil-penalty guidance (severity 2). Establishes enhanced penalty framework for Part 760 violations, raising the ceiling for wilful violations and clarifying the factors BIS considers in determining civil penalties for antiboycott non-compliance.
Pattern to watch
- Whether Bahrain, Morocco, and Sudan de-listing EAR amendments follow as
those Abraham Accords states issue or implement their own domestic termination decrees.
- Whether Saudi Arabia (not yet an Abraham Accords party) issues a domestic
boycott-termination decree as part of any future Saudi-Israel normalisation, triggering a corresponding BIS Supplement No. 1 amendment.