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BIS Imposes Penalties for Failure to Report Boycott Request

News & Blog

Today, the Department of Commerce’s Bureau of Industry and Security (BIS) imposed a civil penalty of $48,750 against Pratt & Whitney Component Solutions, Inc (PWCS), located in Muskegon, Michigan, to resolve 13 violations of the antiboycott provisions of the Export Administration Regulations (EAR) (antiboycott regulations), as alleged in BIS’s Proposed Charging Letter. PWCS voluntarily disclosed the conduct to BIS, cooperated with the investigation by BIS’s Office of Antiboycott Compliance (OAC), and took remedial measures after discovering the conduct at issue, all of which resulted in a significant reduction in penalty.

These BIS actions were taken under the authority of the Anti-Boycott Act of 2018, a subpart of the Export Control Reform Act of 2018, and its implementing regulations, the EAR. 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).

The EAR requires that a company self-report if it has been asked to take part in an unsanctioned foreign boycott. Any violation, including those limited to inquiries, must be reported to the U.S. Department of Commerce- Office of Antiboycott Compliance. A failure to report inquiries or requests regarding non-U.S. endorsed boycotts constitute a violation of U.S. anti-boycott laws.

This Blog is made available by Wilmarth & Associates for educational purposes as well as to give you general information and a general understanding of export law and compliance, not to provide specific legal advice. This blog is not legal advice and should not be treated as such. You must not rely on this blog as an alternative to legal advice from your attorney or other professional legal services provider. The information provided on this website is presented “as is” without any representations or warranties, express or implied.
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