On Tuesday, the U.S. Department of Commerce Bureau of Industry and Security's Office of Antiboycott Compliance (OAC) issued an advisory regarding the Turkish government's announcement that it will "suspend all exports and imports to and from Israel until the Israeli government allows an uninterrupted and sufficient flow of humanitarian aid into Gaza."
The OAC advisory highlights that U.S. anti-boycott laws and regulations prohibit "U.S. persons" from "taking certain actions in furtherance or support of an unsanctioned foreign boycott maintained by a country against a country friendly to the United States and require reporting of receipt of a boycott-related request to BIS," and that companies operating in in Türkiye or doing business with companies there should be aware of "any requests to refrain from importing or exporting goods to or from Israel or to provide certification that the goods are not of Israeli origin or do not contain Israeli-origin components or materials."
In this context, U.S. persons can include U.S. entities and their non-U.S. subsidiaries, partnerships, affiliates, branches, offices, or other permanent foreign establishments. Therefore, U.S. entities and those with a U.S. parent should be mindful of this OAC update when considering transactions in Turkey, particularly of any new requests they receive from Turkish customers or counterparties related to Turkey's announcement.
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