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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Photo of Anand Sithian Anand Sithian

For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand

For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand is resident in the firm’s New York office and a member of the firm’s International Trade, White Collar and Regulatory Enforcement, and Financial Services groups.

A former federal prosecutor, Anand leverages his government experience to guide clients through complex white-collar matters, including grand jury and regulatory investigations, enforcement proceedings, and internal investigations. Anand has deep experience in parallel criminal and civil investigations and proceedings, and often represents clients in defending against civil lawsuits related to government investigations.

Representing some of the world’s largest banks and technology companies, Anand has addressed a wide range of issues, including economic sanctions, BSA/AML; economic sanctions and national security; payments and cryptocurrency; securities laws; and cybersecurity enforcement. In the regulatory space, Anand prides himself on providing commercial and actionable advice, including in the developing areas of digital assets, FinTech, and payments.

Photo of Jeremy Iloulian Jeremy Iloulian

Jeremy Iloulian is an associate in Crowell & Moring’s Chicago office and is a member of the International Trade Group. Jeremy advises clients globally on complex cross-border investigative, regulatory, compliance, and transactional matters and policy developments that touch U.S. national security, international trade…

Jeremy Iloulian is an associate in Crowell & Moring’s Chicago office and is a member of the International Trade Group. Jeremy advises clients globally on complex cross-border investigative, regulatory, compliance, and transactional matters and policy developments that touch U.S. national security, international trade, and foreign investment, including those relating to U.S. export controls, economic sanctions, anti-boycott laws, and the Committee on Foreign Investment in the United States (CFIUS).