The BIS Entity List: license requirements, not a blanket ban
The BIS Entity List is the Commerce Department's list of parties whose presence in a transaction can trigger an export license requirement beyond those elsewhere in the Export Administration Regulations (EAR). Each entry states the license requirements and the license review policy that apply to that party (Trade.gov CSL). It is published as Supplement No. 4 to part 744 of the EAR. Unlike OFAC's SDN list, it is not a general ban on dealing with the party; it controls exports, reexports and transfers of items subject to the EAR.
Where it lives
The list itself is Supplement No. 4 to 15 CFR part 744. It is also part of Trade.gov's Consolidated Screening List, which is the practical way to screen it alongside other U.S. lists.
How a party gets on it
Under 15 CFR 744.11, BIS can impose license requirements, limit license exceptions and set license review policy for entities acting, or at significant risk of acting, contrary to U.S. national security or foreign policy interests. It does this by adding the entity, or an address that presents a high diversion risk, to the Entity List and stating the requirements that apply. Decisions follow the End-User Review Committee. BIS can also remove entities or addresses that no longer meet the criteria.
What a listing means for you
For a listed party, read its entry. The entry tells you:
- which items need a license (often all items subject to the EAR, sometimes a narrower set)
- the license review policy (for example, a presumption of denial)
- the Federal Register citation that added or changed it
If your transaction involves an item covered by the entry and a listed party, you need a license from BIS before you export, reexport or transfer. The EAR's general prohibitions point to part 744 for end users who may require a license (15 CFR 736.2).
Entity List vs SDN list
| Entity List | OFAC SDN list | |
|---|---|---|
| Agency | Commerce, BIS | Treasury, OFAC |
| Effect | License requirement for items subject to the EAR, per entry | Generally blocks all dealings in the person's property and interests (OFAC FAQ 91) |
| Searched by OFAC's Sanctions List Search | No | Yes |
| Included in Trade.gov's CSL | Yes | Yes |
A party can be on both. A domestic service business with no exports may only need OFAC screening. An exporter, or anyone shipping U.S.-origin goods, software or technology abroad, needs both. See SDN, Consolidated and the CSL.
The affiliates rule
On 30 September 2025 BIS published an interim final rule under which any entity at least 50 percent owned by one or more Entity List entities would itself be subject to Entity List restrictions, mirroring Treasury's 50 percent practice (Federal Register 2025-19001). On 12 November 2025 BIS suspended that rule for one year. The suspension is set to end on 9 November 2026, absent a further extension, and the same rule reimposes the affiliate controls effective 10 November 2026 (Federal Register 2025-19846).
While the suspension holds, the Entity List restrictions apply to the listed entities and addresses themselves. If it lapses, unlisted subsidiaries of listed parties come into scope, and screening by name alone will not find them. See the BIS Affiliates Rule returns in November 2026 and the OFAC 50 percent rule with worked examples for how ownership screening works.
Related lists
The Denied Persons List is stricter: a denial order bars a party from transactions involving items subject to the EAR. See the Denied Persons List. For an exporter's routine, see denied party screening for small exporters.
This is screening data, not legal advice. For a license determination, read the entry and the regulations, and talk to counsel.
Run a free OFAC check on a party, and screen the Consolidated Screening List for the Entity List and other Commerce lists.