Five Things Every Multinational Company Should Consider for … Recognizing Boycott-Related Requests

Please find our latest “Five Compliance Best Practices” article, which provides quick-hit compliance best practices multinational companies can implement to enhance their compliance programs and internal controls. Additional “Five Things” articles, as well as our What Every Multinational Should Know and Tariff-ied! articles, can be found in the drop-down menu on our Tariff & International Trade Resources page. Click Here to Register for our email list to receive future practical international regulatory compliance tips.

The United States maintains rules against complying with the Arab League boycott of Israel, which seeks to identify and punish companies that have dealings with Israel. Recognizing boycott-related requests is a foundational step in managing antiboycott risk. Such requests often appear in routine business documents and operational communications rather than in overtly legal or compliance-focused settings. They may surface in contracts, purchase orders, letters of credit, shipping instructions, vendor forms, or customer correspondence.

Because these requests can trigger legal restrictions and reporting obligations under U.S. antiboycott laws, companies that operate in the Middle East or with Middle Eastern companies should ensure that employees know how to spot them early and escalate them appropriately. Here are five compliance best practices companies at high risk of such violations should consider:

• Train Relevant Personnel to Identify Boycott-Related Language. Employees in sales, procurement, contracting, logistics, finance, shipping, and customer-facing roles should receive practical training on how boycott-related requests arise in the ordinary course of business. Training should explain not only the legal framework but also the kinds of language employees may encounter in transactional documents and communications. Personnel should understand that antiboycott issues may arise through seemingly routine requests and that early recognition is critical to avoiding improper responses.
• Teach Employees to Recognize Common Red Flags. Companies should provide employees with clear examples of the types of requests that may signal antiboycott risk. Common red flags include requests for information about whether the company does business with Israel, requests to refuse business with persons or entities associated with or doing business in Israel, requests to discriminate on the basis of nationality, and requests for information about the race, religion, sex, or nationality of employees, suppliers, or business partners. Employees should also be alert to references to blacklist requirements, boycott certifications, vessel eligibility restrictions, or country-of-origin conditions that appear tied to a boycott-related purpose.
• Review Transaction Documents and Communications Carefully. Boycott-related requests frequently appear in commercial documents and correspondence that may be processed quickly in fast-moving business environments. Companies should review contracts, purchase orders, tender materials, shipping documents, letters of credit, supplier questionnaires, and related communications for language that may indicate a boycott-related request. Monitoring relevant communication channels — including email and other business correspondence — can also help identify problematic requests before the company acts on them. Careful review is especially important in transactions involving higher-risk jurisdictions or counterparties.
• Establish Clear Escalation and Reporting Procedures. Employees should know exactly what to do when they encounter a suspected boycott-related request, including understanding procedures for escalating such matters to legal, trade compliance, or other designated personnel for review. Reporting channels should be practical and accessible, and employees should understand that requests must be escalated even if the company does not intend to comply. Companies should also maintain procedures for assessing and meeting any applicable legal reporting obligations once a request is identified.
• Support Recognition Efforts with Tools, Guidance, and Documentation. For companies operating frequently in the Middle East or with Middle Eastern partners, antiboycott training alone is rarely enough. Companies should support recognition efforts through keyword screening tools, template guidance, documented examples, and periodic compliance reminders tailored to relevant functions. When a request is identified, the company should document the nature of the request, the parties involved, the internal review conducted, the response provided, and any follow-up actions taken. Strong documentation helps support consistency, defensibility, and continuous improvement.

These compliance best practices can help companies at a heightened risk of violations identify boycott-related requests before they become larger legal or operational problems. Because such requests often appear in routine documents and day-to-day communications, effective recognition depends on practical training, careful review, clear escalation channels, and consistent documentation. A company that equips its personnel to spot and elevate these issues early will be better positioned to meet its antiboycott obligations, reduce compliance risk, and respond consistently across business functions and jurisdictions.

Would you like more practical compliance tips like these? The Foley International Trade & National Security Team is monitoring all international trade developments, including new tariff pronouncements, which we post as they occur on our Tariff & International Trade Resources blog. Click Here To Register for our email list to receive future emails and practical international regulatory compliance tips.

Our white paper on Managing Import and Tariff Risks During a Trade War outlines a 12-step plan to provide practical steps to help importers navigate the tariff and international trade risks in the current tariff and trade environment, while the companion white paper on Managing Supply Chain Integrity Risks provides practical advice to deal with heightened supply chain risks pertaining to goods imported into the United States, including the increasing use of detentions by Customs.