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The U.S. antiboycott laws and regulations have been around since the era of disco. In stark contrast to fast-moving sanctions and export controls, we rarely see updates to the antiboycott regulations or enforcement strategies. Last October, however, the Department of Commerce, Bureau of Industry and Security (BIS) announced enhancements to its antiboycott enforcement strategy. As part of its implementation of this updated enforcement strategy, BIS has both expanded the scope of required antiboycott reports and flagged antiboycott compliance specifically for government contractors. These moves demonstrate how BIS plans to focus its enforcement efforts on Federal contractors.

The U.S. government created antiboycott laws and regulations to counter the Arab League boycott of Israel and other unsanctioned foreign boycotts against countries considered friendly to the United States. These laws and regulations apply to all U.S. companies and subsidiaries (including outside of the United States). Both the Departments of Commerce and Treasury administer and enforce these regulations. There are large overlaps (with some significant differences) between compliance with these sets of regulations, but for purposes of this article, we focus on BIS antiboycott compliance.