The Bureau of Industry and Security (BIS) maintains several lists to restrict or monitor exports, reexports, and transfers of items subject to the Export Administration Regulations (EAR). The Entity List is one of the most significant of these lists.
The Entity List identifies foreign parties that are subject to specific license requirements for the export, reexport, and/or transfer (in-country) of specified items. These entities are believed to be involved in activities contrary to the national security or foreign policy interests of the United States.
The Entity List is a tool used by the BIS to restrict the export, reexport, and transfer of certain items to individuals, organizations, and companies that are considered to pose a risk to U.S. national security or foreign policy interests. Entities on this list require special licenses to receive items subject to the EAR, and license applications are often reviewed with a presumption of denial.
The Entity List is published and regularly updated by the BIS. It can be accessed through the official BIS website, where the most current version is available for download. The list is also published in the Federal Register and is incorporated into the Consolidated Screening List maintained by the U.S. government.
In addition to the Entity List, BIS maintains other lists such as the Denied Persons List and the Unverified List, each serving different regulatory purposes.
The Denied Persons List includes individuals and entities that have been denied export privileges, meaning they are prohibited from participating in any transaction subject to the EAR. The Entity List, on the other hand, imposes specific license requirements on certain entities for particular items, rather than a blanket denial of export privileges.
The Unverified List contains names of parties whose bona fides (i.e., legitimacy and reliability) could not be verified in end-use checks. Transactions with parties on the Unverified List may require additional due diligence and are subject to specific restrictions under the EAR.
Understanding the various BIS lists, including the Entity List, Denied Persons List, and Unverified List, is essential for compliance with U.S. export control regulations.