On June 9, 2021, the US Department of Commerce (Commerce), Bureau of Industry and Security (BIS), published a notice in the Federal Register amending the Export Administration Regulations (EAR), 15 CFR Part 760, to provide a new interpretation regarding the US antiboycott regime applicable to the United Arab Emirates (UAE).  This Commerce action follows the US Department of the Treasury’s (Treasury) similar action earlier this year to remove the UAE from Treasury’s list of countries that require or may require participation in or cooperation with an international boycott not sanctioned by the United States.  As a result of Commerce’s action, the UAE is no longer presumed to be a country engaging in an unsanctioned boycott, and the risk of violating the prohibitions and reporting obligations under Part 760 of the EAR have been substantially curtailed, but not wholly eliminated.

Continue Reading United Arab Emirates Has Terminated its Boycott Against Israel, but Certain US Antiboycott Risks May Remain

The Treasury Department has removed the United Arab Emirates (“UAE”) from its current list of countries which require or may require participation in, or cooperation with, an international boycott (within the meaning of section 999(b)(3) of the Internal Revenue Code).  Iraq, Kuwait, Lebanon, Libya, Qatar, Saudi Arabia, Syria, and Yemen remain on the Treasury list.

According to the Treasury Department, the UAE has been removed from the list due to the issuance of Federal Decree-Law No. 4 of 2020, which repealed its law mandating a boycott of Israel, and the subsequent actions that the UAE government has taken to implement the new policy.  The change in law followed the 2020 normalization agreement between Israel and the United Arab Emirates.


Continue Reading Treasury Removes UAE From Boycott List: Possible Implications