What is the BIS Denied Persons List?

The Denied Persons List (DPL) is maintained by the Bureau of Industry and Security (BIS), part of the US Department of Commerce. It identifies individuals and entities that have been denied export privileges under the Export Administration Regulations (EAR). Parties on the DPL are prohibited from participating in any export, reexport, or in-country transfer of items subject to the EAR.

What is the difference between the Denied Persons List and the Entity List?

The Denied Persons List covers parties whose export privileges have been revoked as an enforcement action — typically after a violation. The Entity List identifies parties reasonably believed to be involved in activities contrary to US national security or foreign policy interests. Entity List parties are not fully denied; instead, exports to them require a BIS licence, often with a presumption of denial. The DPL is a blanket prohibition; the Entity List is a licence requirement.

Who needs to screen against BIS restricted party lists?

Any person or organisation exporting, reexporting, or transferring items subject to the Export Administration Regulations (EAR) must screen against BIS lists. This includes manufacturers, freight forwarders, technology companies, universities conducting international research, and any company shipping goods, software, or technology that could have a US origin or contain US-origin components.

What are the penalties for exporting to a denied or listed party?

Criminal penalties for export control violations can reach $1 million per violation and 20 years imprisonment. Civil penalties can reach $300,000 per violation or twice the value of the transaction. BIS can also deny export privileges, effectively shutting a company out of international trade. In 2023, Seagate Technology paid $300 million for selling hard drives to Huawei in violation of export controls.

Is the BIS Entity List the same as the OFAC SDN List?

No. The BIS Entity List and OFAC SDN List are administered by different agencies (Commerce vs Treasury) under different legal authorities (EAR vs IEEPA). A party may appear on one, both, or neither. The BIS Entity List primarily restricts exports of goods and technology, while the OFAC SDN List involves broader financial blocking and transaction prohibitions. Comprehensive compliance requires screening against both.

Denied Persons List & BIS Export Control Lists

The Bureau of Industry and Security (BIS) maintains several restricted party lists that control who can receive US-origin goods, software, and technology. These lists are separate from OFAC sanctions but equally consequential — violations carry criminal penalties of up to $1 million per violation and 20 years imprisonment, and can result in a company being denied all export privileges entirely.

1,518 BIS Denied Persons on Sanctions Checklist

3,329 BIS Entity List entries

12 BIS sub-lists on Sanctions Checklist

What is BIS?

The Bureau of Industry and Security is part of the US Department of Commerce. It administers the Export Administration Regulations (EAR), which govern the export, reexport, and in-country transfer of commercial and dual-use items — goods, software, and technology that have both civilian and potential military or proliferation applications.

While OFAC (Treasury) focuses on financial sanctions and blocking, BIS focuses on what can be shipped or transferred to whom. In practice, any organisation involved in international trade, technology transfer, or research collaboration needs to screen against both OFAC and BIS lists.

The four BIS restricted party lists

BIS maintains four distinct lists, each serving a different purpose and carrying different restrictions. They are often confused with each other and with OFAC lists, but the legal frameworks and consequences are different.

List	What it means	Restriction
Denied Persons List (DPL)	Parties whose export privileges have been revoked as an enforcement action, typically after a violation	Complete prohibition — no items subject to the EAR may be exported, reexported, or transferred
Entity List	Parties reasonably believed to be involved in activities contrary to US national security or foreign policy	Licence required for most EAR-controlled items; often with a presumption of denial
Unverified List (UVL)	Parties whose end-use or end-user bona fides BIS has been unable to verify	Enhanced due diligence required; certain licence exceptions unavailable
Military End-User (MEU) List	Entities involved in military activities in countries of concern (China, Russia, Iran, Venezuela, Myanmar, and others)	Licence required for specified items, typically with presumption of denial

Key distinction from OFAC: The BIS Entity List and OFAC SDN List are administered by different agencies (Commerce vs Treasury) under different legal authorities (EAR vs IEEPA). A party may appear on one, both, or neither. The Entity List primarily restricts exports of goods and technology; the SDN List involves broader financial blocking. Comprehensive compliance requires screening against both.[1]

The Denied Persons List in detail

The DPL is the most severe BIS enforcement outcome. When BIS places a party on the DPL, that party loses all export privileges — they may not participate in any capacity in a transaction subject to the EAR. This means:

No exports, reexports, or transfers of any item subject to the EAR may involve the denied party — as buyer, seller, intermediary, freight forwarder, or end-user
Other parties are also prohibited from knowingly participating in transactions that involve a denied person
No licence exception applies — unlike Entity List restrictions, there is no process to apply for a licence to transact with a denied person
Denial orders typically run for multiple years and are published in the Federal Register

The Entity List: why it keeps growing

The Entity List has become one of the most actively used tools in US export control policy. BIS adds entities on a rolling basis, driven by national security assessments, intelligence findings, and proliferation concerns. Recent trends include:

Semiconductor and AI controls — in September 2025, BIS added 23 Chinese entities to the Entity List over advanced semiconductor, AI/HPC chip, and quantum computing activities, with some receiving "Footnote 4" designations that extend controls to foreign-produced items made with US technology[2]
Russia procurement networks — intermediaries in Turkey, the UAE, and other third countries have been designated for procuring controlled items on behalf of Russia's military, triggering the Russia/Belarus Foreign Direct Product Rule[2]
Biotech and life sciences — suppliers linked to PLA-affiliated medical research institutions have been added[2]
Diversion networks — companies in India, Singapore, Malaysia, and the UAE have been listed for transshipping controlled items to sanctioned destinations

The Foreign Direct Product Rule (FDPR) extends BIS jurisdiction to items manufactured outside the United States if they were produced using US-origin technology, software, or equipment. This means a chip fabricated in Taiwan using US-designed EDA software, or a product manufactured in Germany on US-origin machinery, may be subject to EAR controls — and shipping it to an Entity List party without a licence is a violation, even if the shipper is not a US person.

Search BIS and international restricted party lists

Sanctions Checklist includes the BIS Denied Persons List, Entity List, Unverified List, Military End-User List, and 8 additional BIS sub-lists alongside OFAC, UN, EU, UK, and other international sanctions data. First 10 searches are free.

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Penalties for export control violations

BIS enforcement carries both criminal and civil penalties, and the trend is toward larger fines and more aggressive prosecution:

Criminal penalties: up to $1 million per violation and 20 years imprisonment. In 2024, a defence contractor was sentenced to 15 months in prison for fraud, money laundering, and unlawful export of technical data[3]
Civil penalties: up to $300,000 per violation or twice the value of the transaction, whichever is greater
Denial of export privileges: BIS can bar a company from all future exports, effectively ending its ability to participate in international trade
Seagate Technology (2023): $300 million settlement for selling over 7.4 million hard drives to Huawei in violation of export controls, plus a five-year suspended denial order[4]

BIS's Disruptive Technology Strike Force — a joint initiative with the Department of Justice — brought 15 criminal cases in 2024 targeting sanctions and export control violations, smuggling conspiracies, and illicit technology transfers to China, Russia, and Iran.[5]

Who needs to screen against BIS lists?

Exporters and manufacturers

Any company exporting goods, software, or technology from the United States — or reexporting US-origin items from a third country — must screen all parties to the transaction against BIS restricted party lists. This includes the buyer, the end-user, any intermediaries, and freight forwarders. The obligation extends to items that incorporate US-origin components or were produced using US technology (under the FDPR).

Universities and research institutions

Universities face specific export control exposure that is often underestimated:[6]

Research collaborations — partnering with a foreign institution or researcher on the Entity List can constitute an unauthorised transfer of controlled technology
Visiting scholars — hosting a researcher affiliated with a listed entity may trigger "deemed export" rules, where providing access to controlled technology to a foreign national is treated as an export to their home country
Equipment and materials — shipping lab equipment, biological samples, or software to a foreign partner on a BIS list requires a licence, even for academic purposes
Embargoed destinations — conducting research in or presenting at conferences in comprehensively embargoed countries (Cuba, Iran, North Korea, Syria) typically requires approval from the institution's export control office

Freight forwarders and logistics providers

BIS has increasingly focused enforcement on freight forwarders who facilitate shipments to restricted parties. Forwarders have an independent obligation to screen shipments and cannot rely solely on the exporter's compliance representations.

Technology and software companies

Cloud providers, SaaS companies, and software distributors must screen customers and end-users. Providing access to controlled software or technology to a listed party — even via a cloud platform or download — can constitute an export under the EAR.

BIS lists vs OFAC lists vs the US Consolidated Screening List

The US government's Consolidated Screening List (CSL), maintained at trade.gov, combines lists from the Departments of Commerce (BIS), Treasury (OFAC), and State into a single searchable database of approximately 12,000 entries across 13 federal lists.[7]

However, the CSL covers only US government lists. It does not include EU, UK, UN, Australian, Canadian, Swiss, or other international sanctions and restricted party lists. If your organisation operates internationally, or your counterparties do, screening against the CSL alone leaves significant gaps.

Sanctions Checklist aggregates BIS lists alongside OFAC, UN, EU, UK, Australian, Canadian, Swiss, and other international sanctions data in a single search, covering both the financial sanctions (OFAC-style) and export control (BIS-style) dimensions that comprehensive compliance requires.

Screen against BIS, OFAC, and 15+ international lists in one search

BIS Denied Persons, Entity List, Unverified List, Military End-User, OFAC SDN, UN, EU, UK, and more. First 10 searches are free, no account required.

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Related guides

OFAC Sanctions List — US Treasury financial sanctions (separate from BIS export controls)
Sanctions Screening — how to screen against multiple lists
Sanctions Compliance Checklist — what regulators expect
Canadian Sanctions — includes Named Research Organizations List (relevant for research institutions)
US DoD Lists — Section 1260H & 1286 (related US government restricted party lists)
Japan End User List — METI export control list

Official BIS resources

BIS Denied Persons List — searchable list and CSV download
BIS Entity List — current Entity List with licence requirements
BIS Lists of Parties of Concern — all BIS restricted party lists
US Consolidated Screening List (CSL) — combined Commerce, Treasury, and State lists
BIS Entity List FAQs — frequently asked questions

References

BIS — Entity List FAQs (distinction between Entity List and other BIS lists)
Washington Trade & Tariff Letter — BIS Adds 32 to Entity List (September 2025)
BIS — Defense Contractor Sentenced to 15 Months in Prison (October 2024)
Norton Rose Fulbright — Record Penalties for US Sanctions and Export Controls Violations (Seagate $300M settlement)
BIS — Export Enforcement Year in Review 2024 (15 criminal cases via Disruptive Technology Strike Force)
Lexology — Key US Sanctions and Export Control Considerations for Higher Education and Research Institutions
US International Trade Administration — Consolidated Screening List

This page is provided for informational purposes only and does not constitute legal advice. All regulatory information was sourced from publicly available US government publications, law firm analyses, and news reports as of April 2026. For definitive export control guidance, consult BIS directly or seek qualified legal counsel.