Emergency Review Request Letter to Mr. Aitken

Mr. Steven D. Aiken

Acting Administrator

Office of Information and Regulatory Affairs

Office of Management and Budget

Washington, DC 20503

Dear Mr. Aiken:

The Department of Commerce’s Bureau of Industry and Security (BIS) requests emergency review for a new information collection, “Voluntary Self-Disclosure of Antiboycott Violations.” On June 30, 2006, BIS published a proposed regulation entitled “Antiboycott Penalty Guidelines.” This regulation will codify the procedure for submitting voluntary Antiboycott self-disclosures and the criteria BIS will use for evaluation. The rule described the specific information and documentation needed by BIS to properly evaluate the severity of a violation and the criteria used for determining a specific penalty. The review is requested by May 4, 2007.

In the published proposed rule, BIS stated that the collection would be implemented as an amendment to existing collection OMB 0694-0058 “Voluntary Self-Disclosure.”

The existing collection involved voluntary self-disclosure of violations of the Export Administration Regulations and was very similar to the proposed collection for voluntary self-disclosure of Antiboycott violations. One comment received on the proposed rule indicated that BIS had greatly underestimated the burden for large multi-national corporations. Based on this comment, BIS has completely revised its burden estimate to reflect a much greater burden on a large multi-national corporation. After consultation with Commerce General Counsel, BIS decided it was no longer appropriate to submit the “Voluntary Self-Disclosure of Antiboycott Violations” as an amendment to existing collection OMB 0694-0058.

BIS expects to publish the “Antiboycott Penalty Guidelines” as a final rule on or about May 4, 2007 and the usual PRA process would greatly delay this publication. The emergency review

of this information collection is necessary so that industry and government may begin to take advantage of the benefits of this rule and begin enforcement activities at the earliest possible date.

Your approval will be greatly appreciated.

Sincerely,

Barry C. West

Enclosures