One of our business units is participating in a trade exhibition in the Middle East. The logistics partner for the exhibition has sent an International Shipping Manual which covers consignment instructions as well as documentation requirements. Included in the manual is the clause: “Ensure that no labor, capital, parts or raw materials of ‘Israeli origin’ have been used in the printing, publishing or manufacture of the goods and none are part or parent of firms included on the Israeli Boycott Blacklist.”

The question is should this be reported to the US Department of Commerce in accordance with the US Export Administration Act 1977 and Tax Reform Act 1976? Note that the UK company is a subsidiary to a larger US corporate entity. In other words, do the respective Acts have extra-territorial reach or do they only apply to “US persons” in the USA?

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