SANCTIONS LISTS AND WATCHLISTS EXPLAINED · GUIDEUPDATED 2026-09-04
    Sanctions Lists and Watchlists Explained

    BIS Denied Persons List: 564 names, and denial orders that run to 2056

    The US export-privilege denial list: five columns, no identifiers, orders lasting decades, and why the aggregated copies are three times too big.

    Most restricted-party lists tell you that a licence is needed. The Denied Persons List tells you that nothing is possible. A denial order issued by the Bureau of Industry and Security strips a person or company of export privileges outright: no exports, no reexports, no transfers, and no participating in anyone else's transaction involving items subject to the Export Administration Regulations. It is administrative, it follows an enforcement case under EAR parts 764 and 766, and there is no licence route around it. The published file is startlingly plain — five columns, one of which crams name, street, city, state, country and postcode into a single string, with no identification numbers, no dates of birth and no aliases. It is also small. BIS's own export, dpl_04142026.csv, held 564 rows when we read it on 4 September 2026, against 1,596 rows in the Denied Persons slice of the Commerce Consolidated Screening List, which retains historical orders. The other surprise is duration: 53 rows carry no expiry date at all and the longest-running order in the file does not lapse until 29 June 2056.

    What this workflow covers

    SCOPE
    • 564 rows in dpl_04142026.csv on 4 September 2026, of which 473 expire on or after that date, 53 carry no expiry, and 38 had already lapsed.
    • Five columns and nothing more: Name_and_Address, Effective_Date, Expiration_Date, Appropriate Federal Register Citations, Type of Denial. There is no record identifier, so tracking a party across file versions means matching on the name string.
    • 559 orders are Standard and 3 are Non-Standard. A standard order denies all export privileges; a non-standard order carves out narrower conduct, which the Federal Register notice defines and the CSV does not.
    • Effective dates in the current file run from 24 March 1981 to 26 March 2026 — a denial order from the Reagan administration can still be live.
    • Download: https://www.bis.gov/denied-persons-list serves the current CSV, with a recent-changes view covering the past 90 days. There is no XML, no JSON and no API from BIS itself.
    • There is no delta file. The filename carries the publication date, so keep the dated copies and diff them; that is the only change mechanism BIS offers on this list.
    • Aliases, transliterations, birth dates, passport numbers and ownership links are all absent. A denial order names the party as the enforcement case named it, and nothing else.
    • The address blob does most of the damage: a US postcode sits where a country code would, so naive parsing sends the wrong jurisdiction to your reviewer. Generic company names do the rest, along with the habit of screening an aggregated copy that still holds orders which expired in the 2000s.
    • A live denial order is a stop, not a review queue. General Prohibition Ten bars you from proceeding with any transaction you know violates a denial order, so the shipment does not move while you check the Federal Register citation and the expiry date. Denial orders are also where point-in-time evidence bites: an order that lapses next quarter makes today's decision look wrong to an auditor reading the list next year, which is why the evidence PDF ScreenVeritAI stores fixes the file version a decision was made against and is never recalculated.

    Key statistics

    DATA
    Rows in dpl_04142026.csv
    564 (473 running on 4 September 2026, 53 with no expiry)
    Counted from the BIS Denied Persons List CSV
    Denial orders by type
    559 Standard, 3 Non-Standard
    Counted from the BIS Denied Persons List CSV
    Latest expiry date in the current file
    29 June 2056
    Counted from the BIS Denied Persons List CSV

    Compliance glossary

    TERMS
    Denial order
    An administrative order under EAR parts 764 and 766 removing a party's privilege to take part in transactions involving items subject to the Export Administration Regulations, for a stated period or indefinitely.
    Standard denial order
    The default form, denying all export privileges. A non-standard order restricts a narrower set of conduct, defined in the Federal Register notice rather than in the published CSV.
    General Prohibition Ten
    The EAR rule barring anyone from proceeding with a transaction knowing that a violation — including a violation of a denial order — has occurred or is about to occur.
    Items subject to the EAR
    Goods, software and technology within US export-control jurisdiction by origin, location or US content, including uncontrolled EAR99 items. Denial orders reach all of them.

    Authoritative references

    SOURCES

    Frequently asked questions

    Q&A
    Q.01
    What is the difference between the Denied Persons List and the Entity List?
    A denial order removes export privileges from a party after an enforcement action, and there is no licence available. An Entity List designation imposes a licence requirement on specified items with a stated review policy, usually a presumption of denial, and a licence can in principle be applied for. One is a punishment; the other is a control.
    Q.02
    Can I ship to a denied person if the item is not controlled?
    No. The denial order attaches to the party rather than to the item's classification, and it reaches anything subject to the EAR — which includes EAR99 goods. That is what makes this list different from most of what sits alongside it in an export screening run.
    Q.03
    How long does a denial order last?
    As long as the order says. In the file published on 14 April 2026, 473 orders were still running on 4 September 2026 and the longest ends on 29 June 2056; 53 rows carry no end date. Ten and twenty year terms are common, and orders can be renewed or modified by a later Federal Register notice.
    Q.04
    Where do I download the DPL and how often does it change?
    From the BIS Denied Persons List page, as a dated CSV. BIS does not publish on a schedule — orders are added when enforcement cases conclude — but the page carries a recent-changes view for the last 90 days. Keep every dated file you download, because that is the only way to reconstruct the list as it stood.
    Q.05
    Why does my vendor show far more denied persons than BIS does?
    Because most vendors ingest the Commerce Consolidated Screening List, which keeps historical denial orders rather than dropping them. On 4 September 2026 that file held 1,596 Denied Persons rows, 1,133 of them already expired, against 564 rows in the BIS file. Ask your provider whether it filters on the expiry date.
    Q.06
    Do non-US companies have to screen the DPL?
    If you handle US-origin goods, software or technology, yes — the EAR follows the item, not the flag on your building. A German distributor reexporting a US-made component is squarely within scope. If nothing you touch is subject to the EAR, the list is not aimed at you, but that is a determination worth documenting rather than assuming.