Who Is Covered by the Laws?

The antiboycott provisions of the Export Administration Regulations (EAR) apply to the activities of U.S. persons in the interstate or foreign commerce of the United States. The term "U.S. person" includes all individuals, corporations and unincorporated associations resident in the United States.

Conduct that may be penalized under the TRA and/or prohibited under the EAR includes:

Agreements to refuse or actual refusal to do business with or in Israel or with blacklisted companies. Agreements to discriminate or actual discrimination against other persons based on race, religion, sex, national origin or nationality.

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I would say that discrimination clearly applies in this case, and individuals do have a responsibility under the EAR.