SANCTIONS LISTS AND WATCHLISTS EXPLAINED · GUIDEUPDATED 2026-09-04
Sanctions Lists and Watchlists Explained
The Unverified List is not an allegation: BIS just could not check the address
222 parties BIS was unable to verify, the licence-exception ban and UVL statement they trigger, and how a company gets itself removed.
Compliance teams treat a hit on the Unverified List as a red flag, and it is not quite that. A party lands on the UVL because BIS tried to run an end-use check — a pre-licence check before a shipment or a post-shipment verification after one — and could not complete it. Perhaps the host government would not allow the visit, perhaps the address did not exist, perhaps nobody answered. The list records an unresolved question about the party's bona fides, and the way off it is to answer that question by hosting a successful check. The legal effect sits at 15 CFR 744.15 with the population itself in Supplement No. 6 to Part 744: no Licence Exceptions may be used for a UVL party, and where the transaction needs no licence at all, the exporter must first obtain a signed UVL statement from the listed party covering the end use, end user and destination, and retain it under part 762 of the EAR. The list is small and geographically lopsided. On 4 September 2026 it held 222 parties across 25 jurisdictions, 113 of them in China, 40 in the United Arab Emirates and 13 in Finland.
What this workflow covers
SCOPE- 222 listed parties on 4 September 2026, each appearing once. The largest concentrations are China (113), the United Arab Emirates (40), Türkiye (16) and Finland (13).
- Each entry gives a name and one or more physical addresses. There are no dates of birth, no identity numbers, no aliases, and — unlike the Entity List and Denied Persons List — no Federal Register citation in the machine-readable rows.
- Effect under 15 CFR 744.15: Licence Exceptions are unavailable for exports, reexports and in-country transfers involving a UVL party, by way of the restriction at 740.2(a)(17).
- The UVL statement is the operative control. Before an export that needs no licence, the exporter obtains a written, signed and dated statement from the UVL party identifying it, stating the end use, end user and country of ultimate destination, committing to comply with the EAR and to cooperate with end-use checks, and confirming the signatory's authority. One statement can cover repeated shipments, provided you keep a log tying each export to the statement relied on; everything goes into part 762 records.
- Removal is not a petition on the merits. BIS takes a party off the UVL when it can verify the party's bona fides, which in practice means the end-use check that failed gets completed successfully.
- Downloads: the authoritative text is Supplement No. 6 to Part 744 on the BIS site; the machine-readable copy arrives through the Commerce Consolidated Screening List with a source tag of 'Unverified List (UVL)'.
- What the list does not contain: any finding of wrongdoing, any prohibition on shipping, and any ownership rule. A UVL listing does not extend to subsidiaries or affiliates the way a denial order's reach or the Entity List's affiliates rule can.
- Bad matches cluster in trading-company names, where 'International', 'Technology' and 'Trading' recur across the file, and in the Finnish and Emirati entries, several of which share a street address with unrelated tenants.
- Handle a hit as a documentation task rather than an escalation: confirm the address matches, decide whether a licence is required, and if not, get the UVL statement before the goods move. The BIS Unverified List is one of the registered sources on our coverage page, screened in the same pass as the other Commerce lists.
Key statistics
DATA- Parties on the Unverified List, 4 September 2026
- 222 across 25 jurisdictions
- Counted from the UVL rows of the Consolidated Screening List
- Largest concentrations
- China 113, United Arab Emirates 40, Türkiye 16, Finland 13
- Counted from the UVL rows of the Consolidated Screening List
- Regulatory basis
- 15 CFR 744.15, list at Supplement No. 6 to Part 744
- Bureau of Industry and Security, Export Administration Regulations
Compliance glossary
TERMS- Unverified List (UVL)
- The BIS list of parties whose bona fides could not be established through an end-use check, published at Supplement No. 6 to Part 744 of the Export Administration Regulations.
- UVL statement
- The signed document an exporter must obtain from a listed party before a no-licence-required export, covering identity, end use, end user, destination, EAR compliance and cooperation with checks.
- End-use check
- A BIS verification visit — a pre-licence check before a shipment or a post-shipment verification after one — confirming that a foreign party exists, is what it claims to be, and used the items as declared.
- Licence Exception
- An authorisation in the EAR permitting an export that would otherwise need a licence. None may be used where a UVL party is involved in the transaction.
Authoritative references
SOURCES- 01Supplement No. 6 to Part 744 — Unverified List
U.S. Department of Commerce, Bureau of Industry and Security
- 0215 CFR 744.15 — Requirements that apply to entities listed on the Unverified List
Legal Information Institute, Cornell Law School
- 03Consolidated Screening List
U.S. Department of Commerce, International Trade Administration
- 04Guidance on end-user and end-use controls
U.S. Department of Commerce, Bureau of Industry and Security
Frequently asked questions
Q&A- Does a UVL listing mean the company did something wrong?
- No. It means BIS could not verify the party's bona fides through an end-use check. The reason is often outside the company's control — a host government that declines to facilitate the visit, for instance. Treat it as an unresolved question about the counterparty rather than as a finding against it.
- Can I still ship to a party on the Unverified List?
- Usually yes, with extra steps. You cannot use any Licence Exception, so if the item needs a licence you apply for one. If it does not, you must obtain a signed UVL statement from the party before shipping and keep it in your records. That statement is a specific document with required contents, not a general assurance letter.
- What has to be in a UVL statement?
- Identification of the UVL party with its full physical address and contact details, the end use, end user and country of ultimate destination, an undertaking to comply with the EAR prohibitions, an undertaking to cooperate with end-use checks and to produce export records on request, and confirmation that the signatory is authorised. It has to be in writing, with a signature and a date.
- How does a company get removed from the Unverified List?
- By making the check possible. BIS removes a party when it is able to verify the bona fides of that party, which in practice means completing the pre-licence check or post-shipment verification that previously failed. Companies that want off the list usually work through their government and their US counterparties to get the visit scheduled.
- Is the Unverified List the same as the Entity List?
- No. The Entity List imposes a licence requirement on specified items with a stated review policy and reflects a national-security or foreign-policy concern. The Unverified List reflects an incomplete verification and imposes a statement requirement plus the loss of Licence Exceptions. Parties do sometimes move from the UVL to the Entity List when a government continues to obstruct checks.
- Where do I get a machine-readable Unverified List?
- There is no standalone data file from BIS. Supplement No. 6 to Part 744 is the authoritative text, and the practical route is the Consolidated Screening List, where the 222 UVL rows arrive tagged by source alongside the other Commerce lists. Filter on the source column rather than screening the whole aggregate as one list.
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