If you did not migrated your Snap-R account prior to the implementation of the new app and your account is no longer active, you will need to send a letter request to BIS/Snap-R help desk to have your account migrated and reactivated. Please contact our office for assistance or contact the Snap-R help desk at (202) 482-2148. It is important to do this prior to requiring licensing as we have noticed significant delays in resetting some accounts.

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It is important to remember that licensing acquired authorizing the export of controlled technical data (State Department) and technology (BIS) does not authorize release of technology or technical data that is marked as CUI or with a DOD Distribution Statement restricting public access. For parties/persons licensed as end users or consignees not permitted access to the technology/technical data marked as CUI by the distribution control statement, a release must be obtained from the CUI holder prior to export.

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This regulation primarily focuses on the boycott of Israel by the Arab League. Iraq, Kuwait, Lebanon, Libya, Qatar, Saudi Arabia, Syria, and Yemen who have all been determined by the U.S. government to currently enforce the Arab League boycott. It prohibits U.S. companies from conducting any business with any company that makes inquiries about the U.S. company’s business dealings with Israel or national/resident of Israel. Any such inquiries should be reported immediately to the U.S. Commerce Office of Antiboycott Compliance.

A recent example of enforcement of the Anti-Boycott regulations involved the below language contained on a commercial invoice for shipment to the UAE in 2019:

“We certify that no labor, capital, parts or raw materials of Israeli origin have been used in the printing, publishing or manufacture of these goods.” It also stated that none of the relevant parties were “part or parent companies of firms included on the Israeli boycott blacklist.”

This language was determined by investigators to constitute two violation of the Anti-Boycott regulations and this month the U.S. party was assessed a $44,750 civil penalty.

If you have any questions related to the Anti-Boycott regulations or have a concern regarding requests you have received from a customer, please contact our office.

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Users may experience brief system unavailability during this maintenance window. We apologize for any inconvenience.
For questions, please submit a Help Desk Support Case.

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On January 16, 2025, BIS published an interim final rule (IFR) (90 FR 5298) (FDD IFR), adding certain presumptions for “front-end fabricators” and “OSAT” companies seeking to export, reexport, or transfer (in-country) certain “applicable advanced logic integrated circuits” under ECCN 3A090.a (see § 742.6(a)(6)(iii)(A) and Note 1 to 3A090.a), unless the presumption is overcome via Note 1 to 3A090.a. The FDD IFR provided three ways to overcome the presumption that involve Approved IC designers, approved “OSAT” companies, or via identifying authorized IC designers with criteria included in Note 1 to 3A090.a. To be listed, entities must submit requests to BIS and be approved through the End-user Review Committee (ERC).

This final rule revises Note 1 to ECCN 3A090.a by removing the April 13, 2026 date wherever it occurs, and replacing it with December 31, 2026. This change will allow entities additional time to apply to be approved IC designers and allows BIS additional time to process these applications.

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