All over the world, if a company does business in US dollars, or if it has any legal or commercial presence in the USA, it is required to do business with Israel.

If the businesss (through its officers) decides that it does not want to do business with Israel, the USA gets upset and it can impose financial penalties.

The list of activities that upsets the USA takes in the full gamut of trade and trade support services. A bank cannot refuse, other than on purely and demonstrable commercial grounds to do business where there is a connection to Israel. A shipping company cannot agree that it will not allow its ships to call at Israeli ports. A supermarket cannot decide not to sell food marked "produce of Israel" even when the goods are grown in the Occupied Territories by illegal settlers.

The Anti-Boycott Office was set up long ago and its purpose is to protect friends of the USA from economic sanctions by the boycotting of the country or its commercial activity. The legislation setting it up does not restrict countries that could be protected but since inception only one country has benefited: Israel.

And the list of "boycott requesters" is new - introduced in March 2024. Its purpose is singular and simple: make life difficult for those who take a stand against the conduct of Israel.

The primary motivation for it was the Arab League's boycott of Israel, a local difficulty in which fight the USA had no dog.

Over the years, a steady trickle of companies has been reported for offences such as including in a letter of credit a term that goods must not be shipped on an Israeli flagged ship.

Where trade documents include such requests, the issuing bank must report it to the BIS. In the USA, bankers know about it; outside the USA and outside the banking sector, barely anyone does.

As Israel's attrocities grow, more businesses around the world, frustrated because their own governments will not take even the mildest action, take matters into their own hands and in doing so, fall foul of the USA's sanctions.

As much of the world shut down for the Christmas / New Year break, on 30th December, BIS twice issued a statement saying it "updates boycott requester list."

The notice says "the Department of Commerce’s Bureau of Industry and
Security (BIS) published its third quarterly update of the boycott Requester List. This list notifies companies, financial institutions, freight forwarders, individuals, and other U.S. persons of potential sources of certain boycott-related requests they may receive during the regular course of business."

The USA is careful to phrase this in such a way that the threat remains veiled. It's not a blacklist of persons who have been identified as potentially boycotting something about Israel.

"A party’s inclusion on the boycott Requester List does not mean that U.S. persons are restricted from dealing with the listed party. However, a party’s inclusion puts U.S. persons on notice that the listed party is more likely to make reportable boycott-related requests. The updated public list of entities who have been identified as having made a boycott-related request in reports received by BIS includes a total of 38 additions. BIS also removed over 20 entities. Today’s announcement builds on the second quarterly update published in October."

That sounds awfully like the FATF's meally mouthed comments about its Grey etc. lists - in essence: "deal with them if you like but it's at your own risk especially now that you are on notice".

The US continues to pretend that this is not a Pro-Israel measure and talks in general terms about boycotts: "“The boycott Requester List has been a dynamic and innovative addition to antiboycott enforcement,” said *Assistant Secretary for Export Enforcement Matthew S. Axelrod*. “Since its inception in March 2024, the boycott Requester List has made it easier for U.S. persons to fulfill their reporting responsibilities by raising awareness of sources of boycott-related requests. Even more significantly, more than 40 entities have now been removed from the List for ceasing to include boycott conditions in their transaction documents with U.S. persons.”

Summary: don't try to do business in or through the USA, including in US dollars, if you don't tacitly endorse Israel's actions.

BIS says "U.S. persons are encouraged to diligently review transaction documents from all sources, especially those involving these listed parties, to identify possible boycott-related language and to determine whether U.S. person recipients have a reporting requirement to BIS."

BIS also says "The antiboycott provisions set forth in Part 760 of the EAR discourage, and in certain circumstances prohibit, U.S. persons from taking certain actions in furtherance or support of a boycott maintained by a foreign country against a country friendly to the United States (an unsanctioned foreign boycott)."

This indicates that individual companies who take action on their own are outside the scope of the Order but if the OAC can find a way to decide that the company is acting in support of the Arab League Boycott it will. That's why the language important: if language found in Arab League documents, or by those who express support for the Arab League Boycott, is found, that's enough for OAC to decide it was in support of that boycott.

These were recently added to the list:

AL ATTIYA MOTORS AND TRADING CO QATAR

ASIA PACIFIC AIRCRAFT COMPONENT SERVICES SDN BHD MALAYSIA

BERY MARITIME AS NORWAY

BILT GRAPHIC PAPER PRODUCTS LTD INDIA

COLORCON ASIA PVT. LIMITED BANGLADESH

ENEOS JAPAN

FLEXTRONICS SHAH ALAM SDN BHD INDIA

FLEXTRONICS SHAH ALAM SDN BHD MALAYSIA

FLEXTRONICS TECHNOLOGY (PENANG) SDN BHD MALAYSIA

GENETEC TECHNOLOGY BERHAD MALAYSIA

HALLIBURTON MANUFACTURING AND TECHNOLOGY (M) SDN BHD PAKISTAN

KEYSIGHT TECHNOLOGIES MALAYSIA MALAYSIA

PLEXUS MANUFACTURING SDN BHD MALAYSIA

QATAR AIRWAYS QATAR

QATAR CHEMICAL COMPANY LTD QATAR

QATAR ENERGY QATAR

QATAR PETROLEUM CORPORATION (QP) QATAR

RAS LAFFAN OLEFINS COMPANY LTD SAUDI ARABIA

RAS LAFFAN OLEFINS COMPANY LTD QATAR

SHEARWATER PRODUCT CENTER SDN BHD MALAYSIA

SIEMENS ENERGY GLOBAL GMBH & CO KG GERMANY

ULTRA CLEAN TECHNOLOGY (MALAYSIA) MALAYSIA

WM RECYCLE AMERICA LLC SAUDI ARABIA