BIS Entity List 101

If the OFAC SDN list is the best-known name in trade sanctions, the BIS Entity List is its export-control counterpart — and it trips up businesses who assume that a party not on any sanctions list must be safe to supply. It is not that simple. This guide explains what the BIS Entity List is, who is on it, what it actually restricts, how it differs from other blacklists, and how to check a name against it. The Entity List is one of the key lists checked during denied party screening, so understanding it makes your screening more accurate and your risk decisions better informed.

What Is the BIS Entity List?

The Entity List is maintained by the Bureau of Industry and Security (BIS), part of the U.S. Department of Commerce. It names foreign parties — businesses, research institutions, government organizations, and individuals — that are subject to specific license requirements before they can receive items subject to the U.S. Export Administration Regulations (EAR). Parties are added when BIS determines they pose a risk to U.S. national security or foreign-policy interests, for example through involvement in weapons proliferation, military end use, or other activities of concern. In plain terms: if a party is on the Entity List, you generally cannot export, re-export, or transfer controlled items to them without a license — and that license is often subject to a policy of denial, meaning it is unlikely to be granted. The Entity List is an export-control tool, part of the wider framework of export controls for international trade.

What the Entity List Actually Restricts

A crucial feature of the Entity List is that the restriction is defined per entry. Each listing specifies:

• A license requirement — which items subject to the EAR require a license before they can go to that party.
• A licensing policy — how BIS will review any license application, which for many entries is a presumption or policy of denial.
• Limits on license exceptions — the exceptions that would normally allow an export without a license are often unavailable for listed parties.

This is why you cannot judge Entity List risk from the name alone — you must read the specific terms of the entry to understand what is restricted. Determining whether your item is subject to the EAR and what its classification is often comes down to its ECCN.

Entity List vs SDN List vs Denied Persons List

These three U.S. lists are frequently confused, but they come from different agencies and do different jobs. A thorough screening checks all of them.

List	What it does	Agency
Entity List	Requires a license (often policy of denial) to supply EAR items	Commerce (BIS)
Denied Persons List	Parties who violated export laws and are denied export privileges	Commerce (BIS)
SDN List	Sanctioned parties you generally cannot transact with at all	Treasury (OFAC)

The short version: the Entity List restricts what you can send to a party, the SDN list restricts whether you can deal with them financially at all, and the Denied Persons List captures parties stripped of export privileges. For the underlying distinction between these regimes, see our guide to the difference between export controls and sanctions.

Why the Entity List Matters to Non-US Businesses

Like other U.S. controls, the Entity List reaches beyond U.S. borders. Because it applies to items “subject to the EAR” — which can include U.S.-origin goods, software, and technology wherever they end up, and in some cases foreign-made products with U.S. content or derived from U.S. technology — a company outside the United States can still be caught when it handles such items. If you deal in U.S.-origin technology or components, the Entity List is your concern too.

How to Check the Entity List

The Entity List is public, and you can screen names against it for free as part of a consolidated check. Rather than searching each government list separately, you can screen a party against the major U.S. lists — including the Entity List, the SDN list, and others — in one step using Globalior’s free denied party screening tool. When you screen:

1. Enter the party’s full name, using fuzzy matching to catch spelling and alias variants.
2. If you get an Entity List hit, read the specific entry — the license requirement and policy tell you what is actually restricted.
3. Consider ownership and the goods involved, not just the name.
4. Document the result as part of your screening record.

For the full method, follow our step-by-step screening process.

Frequently Asked Questions

Can I ever export to a party on the Entity List?

Sometimes, but only with a license, and many entries carry a policy of denial that makes approval unlikely. The specific license requirement and policy in the entry determine what, if anything, is possible — and license exceptions are usually restricted for listed parties.

Is the Entity List the same as the SDN list?

No. The Entity List (BIS) restricts supplying controlled items without a license, while the SDN list (OFAC) is a sanctions list restricting whether you can transact with a party at all. They are maintained by different agencies and you should check both.

Does the Entity List apply to companies outside the US?

It can. Because it applies to items subject to the EAR — including U.S.-origin goods, software, and technology, and certain foreign items with U.S. content — non-U.S. businesses handling such items can be caught by Entity List restrictions.

Key Takeaways

The BIS Entity List restricts the export of controlled items to named foreign parties by requiring a license — often with a policy of denial — and its reach extends to non-U.S. businesses handling items subject to the EAR. It is distinct from the SDN list and the Denied Persons List, so thorough screening checks all three. You can screen a name against the Entity List and the other major U.S. lists for free using our denied party screening tool. Not sure how an Entity List entry affects your shipment? Contact the Globalior team for free trade-compliance guidance.