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As part of its export controls practice, Crowell & Moring is often called on to advise companies on the application of the Antiboycott Law. Codified in the Export Administration Act, the Antiboycott Law is administered and enforced by the Department of Commerce's Office of Antiboycott Compliance (OAC). The law prohibits compliance with unsanctioned boycotts and is primarily targeted at the Arab League boycott of Israel.

As events in the Middle East unfold, U.S. companies are faced with traps for the unwary, which can come in many forms. Key challenges for companies include knowing how to identify boycott-related requests, when to report them, and how to address them while pursuing business opportunities. Crowell & Moring lawyers have significant experience guiding clients through this minefield.

Representative Engagements

  • Advised client companies on the screening and identification of boycott-related requests
  • Advised client companies on reporting boycott-related requests received from potential business partners in the Middle East and in responding lawfully to such requests
  • Represented client companies in enforcement actions
  • Helped client companies develop corporate antiboycott compliance programs
  • Trained client companies on the application of and compliance with the Antiboycott Law
  • Advised client companies on the implications of the Antiboycott Law in business transactions, such as joint ventures or corporate reorganizations (including closing a subsidiary in Israel, partnering with a Saudi company in a third country, and other transactions)

Crowell & Moring Capabilities

Crowell & Moring's international trade lawyers advise clients on U.S. foreign trade laws that directly affect the international business activities of American corporations. Our lawyers advise clients on these policy-driven laws and regulations, including the following:

  • Antiboycott Law of the Export Administration Act, which makes it illegal for companies to comply with non-U.S. sanctioned boycotts by foreign countries
  • Foreign Corrupt Practices Act (FCPA), which prohibits making payments or giving anything of value to foreign government officials in order to obtain or retain business
Even well-intentioned, but ill-informed, overseas activities can give rise to serious penalties under these laws and regulations. We routinely counsel clients on compliance issues arising under these statutes and, where required, represent them before the appropriate government agencies.

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"Treasury Agencies Issue Virtual Currency Sanctions Compliance Guidance and Ransomware Trends Statistics," International Trade Bulletin (November 15, 2021). Contacts: Caroline E. Brown, Carlton Greene, Paul M. Rosen, Sarah Bartle, Anand Sithian, Nicole Sayegh Succar
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Blockchain & Cryptocurrency Regulation 2022 - An Introduction To Virtual Currency Money Transmission Regulation (November 8, 2021). Author: Carlton Greene, Caroline E. Brown, and Michelle Gitlitz.
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"The Month in International Trade – October 2021," International Trade Bulletin (November 8, 2021). Contacts: Jeffrey L. Snyder, Frances P. Hadfield, Edward Goetz
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Crowell & Moring LLP is an international law firm with offices in the United States, Europe, MENA, and Asia that represents clients in litigation and arbitration, regulatory and policy, and transactional and corporate matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation and government-facing matters, as well as its ongoing commitment to pro bono service and diversity, equity, and inclusion.

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