SANCTIONS LISTS AND WATCHLISTS EXPLAINED · GUIDEUPDATED 2026-09-04
Sanctions Lists and Watchlists Explained
A BIS Entity List hit is an export-licence question, not an asset freeze
Export control, not sanctions: what an Entity List entry restricts, who decides it, where the file is, and the Affiliates Rule stayed to 9 November 2026.
You can, in principle, keep doing business with a company on the BIS Entity List; what you cannot do is send it an item subject to the EAR, by export, re-export or in-country transfer, without the licence its entry demands. The list is published by the Bureau of Industry and Security, part of the US Department of Commerce, and codified as Supplement No. 4 to part 744 of the Export Administration Regulations. It names foreign businesses, research institutions, government bodies, individuals and other legal persons. BIS first published it in February 1997 to flag diversion risk to weapons-of-mass-destruction programmes, and the grounds have since widened to conduct contrary to US national security or foreign policy interests. Additions and removals are decided by the interagency End-User Review Committee and published in the Federal Register. There is no asset freeze in it anywhere. BIS does say that any transaction with a listed party is a red flag, so the right response to a hit is a trade-compliance review of the specific item and destination, not a refusal to trade.
What this workflow covers
SCOPE- Codified at Supplement No. 4 to part 744 of the EAR (15 CFR); the End-User Review Committee that governs it is described at Supplement No. 5 to the same part
- The committee is chaired by a Commerce employee, with representatives from the Departments of State, Defense and Energy; any member agency can propose a change, and the list is reviewed periodically
- Every addition, amendment and removal is published in the Federal Register, which is the authoritative record of when a listing took effect
- Each entry states a licence requirement (which items) and a licence review policy (presumption of denial, case-by-case, or a narrower scope), so read the entry, not just the name
- No US persons on it: a hit that resolves to a US-incorporated company is the wrong party
- 3,419 Entity List records in the ITA Consolidated Screening List CSV of 4 September 2026, alongside 1,596 Denied Persons List, 222 Unverified List and 70 Military End User List records
- Machine-readable through https://data.trade.gov/downloadable_consolidated_screening_list/v1/consolidated.csv (also .tsv and .json, plus a search API), refreshed every day at 05:00 EST/EDT; ITA states the CSL is not a substitute for the Federal Register
- Affiliates Rule (any entity 50 percent or more owned by Entity List parties, directly or indirectly, individually or in the aggregate): published at 90 FR 47201 on 30 September 2025, stayed from 10 November 2025 to 9 November 2026, reimposition scheduled for 10 November 2026 absent a further extension
- Outside its scope: asset freezes, payment prohibitions and blocking measures, which are OFAC's, and the classification of your item, which you still determine from the Commerce Control List
- Usual false positives: institutes, universities and subsidiaries whose names differ only by a city or a numeral, where the address is the main discriminator and often the only one
Key statistics
DATA- BIS Entity List records in the ITA Consolidated Screening List, 4 September 2026
- 3,419
- Counted from the ITA CSL consolidated.csv source field
- Codification
- Supplement No. 4 to part 744 of the EAR
- BIS Entity List FAQs
- Affiliates Rule status on 4 September 2026
- Stayed until 9 November 2026; reimposition scheduled 10 November 2026
- One Year Suspension of Expansion of End-User Controls (Docket 251106-0169)
Compliance glossary
TERMS- Entity List
- The BIS list at Supplement No. 4 to part 744 of the EAR naming foreign parties subject to additional licence requirements for exports, re-exports and in-country transfers of specified items.
- End-User Review Committee (ERC)
- The interagency committee that approves changes to the Entity List. Chaired by Commerce, with representatives from State, Defense and Energy, and described at Supplement No. 5 to part 744.
- Licence review policy
- The disposition BIS states it will apply to licence applications for a listed party — for example a presumption of denial, or case-by-case review. It sits in the entry alongside the licence requirement.
- Affiliates Rule
- The 2025 interim final rule extending Entity List restrictions to entities 50 percent or more owned by listed parties. Published at 90 FR 47201 and stayed from 10 November 2025 to 9 November 2026.
- Consolidated Screening List (CSL)
- The International Trade Administration's combined export-screening dataset, merging Commerce, State and Treasury lists into one daily CSV, TSV, JSON and API feed with a source field on every record.
Authoritative references
SOURCES- 01Entity List FAQs (last updated 29 September 2025)
Bureau of Industry and Security
- 02One Year Suspension of Expansion of End-User Controls for Affiliates of Certain Listed Entities
Federal Register / Bureau of Industry and Security
- 03Consolidated Screening List
International Trade Administration
- 04Entity List — end-user guidance
Bureau of Industry and Security
Frequently asked questions
Q&A- What does the BIS Entity List actually restrict?
- Exports, re-exports and in-country transfers of items subject to the Export Administration Regulations to the parties named at Supplement No. 4 to part 744. A listing is based on conduct that raises diversion risk or runs contrary to US national security or foreign policy interests. It says nothing about payments or property.
- Is an Entity List match a sanctions hit?
- No, it is an export-control finding. There is no asset freeze and no general prohibition on dealings; the listing imposes a licence requirement for specified items together with a stated licence review policy. BIS does advise that any transaction with a listed party carries a red flag, which is a reason to review, not a reason to block.
- Who decides who goes on the Entity List?
- The interagency End-User Review Committee, chaired by Commerce and made up of representatives from State, Defense and Energy. It reviews proposed additions, amendments and removal requests, and reviews the list periodically. Every resulting change is published in the Federal Register.
- Does OFAC's 50 percent rule apply to Entity List parties?
- Not at the moment. The Affiliates Rule published on 30 September 2025 would have made entities 50 percent or more owned by listed parties automatically subject to the same restrictions, but BIS stayed it from 10 November 2025 until 9 November 2026, with reimposition scheduled for 10 November 2026. Put that date in the calendar: it changes the scope of your screening.
- Where do we get the Entity List as a file we can screen against?
- The regulation itself is text in the Code of Federal Regulations. For screening, use the ITA Consolidated Screening List, which publishes Entity List records with a source field in CSV, TSV and JSON at data.trade.gov and through a search API, refreshed daily at 05:00 EST/EDT; ITA is explicit that it does not replace the Federal Register. On the ScreenVeritAI coverage register the Entity List is one of the registered additional US sources, screened by default, and the Quick Check evidence PDF fixes that answer to the date of the check.
- Our counterparty is on the Entity List. Do we have to stop trading with them?
- Not necessarily. The listing restricts exports, re-exports and in-country transfers of items subject to the EAR; it does not prohibit all dealings. Whether a specific transaction needs a licence depends on the item, the destination and the terms of that party's entry, and BIS recommends proceeding with caution and treating the listing as a red flag.
- How is the Entity List different from the Denied Persons List?
- The Denied Persons List names parties whose export privileges have been denied by an order, usually after an enforcement action, and the denial order is broad. The Entity List names parties subject to a licence requirement defined per entry. Both come from BIS, and both appear in the Consolidated Screening List under distinct source tags.
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