Denied party screening for small exporters
Denied party screening means checking every party to an export (customer, consignee, end user, freight forwarder, bank) against the U.S. government's restricted party lists before you ship. For a small exporter the practical starting point is the free Consolidated Screening List on Trade.gov, which combines export screening lists from Commerce, State and the Treasury, including the Entity List, the Denied Persons List and OFAC's SDN list. Trade.gov says a match calls for more due diligence before proceeding: it can mean a prohibition, a license requirement, or other restrictions.
What each list means for a shipment
Trade.gov describes the lists in the CSL this way (Trade.gov CSL):
| List | Agency | What a match means |
|---|---|---|
| Denied Persons List | Commerce (BIS) | Denied export privileges; dealings that would violate the denial order are prohibited |
| Unverified List | Commerce (BIS) | A red flag to resolve before proceeding |
| Entity List | Commerce (BIS) | Can trigger a license requirement; the listing states the requirements and review policy |
| Military End User List | Commerce (BIS) | License requirement for items in supplement no. 2 to part 744 |
| Nonproliferation Sanctions | State | Sanctioned under various statutes; the Federal Register is the official listing |
| AECA Debarred List | State | Barred from participating in exports of defense articles and services |
| SDN list and other OFAC lists | Treasury (OFAC) | Blocking or other sanctions; see OFAC's regulations |
How to run it
- Screen before you quote or accept the order, and again before you ship if time has passed. Trade.gov says the CSL tools update automatically every day at 5:00 AM Eastern (Trade.gov CSL).
- Screen every party, not only the buyer. Trade.gov frames the CSL as screening "potential buyers and end-users" and parties to regulated transactions.
- Use the fuzzy search. The CSL search has a fuzzy name mode that returns a score, which Trade.gov notes helps with names translated from non-Latin alphabets.
- Confirm against the official source before acting. Trade.gov says to check the official publication of restricted parties in the Federal Register and the agencies' own lists before taking further action. Each CSL record carries a link to its source.
- Check ownership. OFAC blocks entities 50 percent or more owned by blocked persons even if they are not listed (OFAC FAQ 91), and from 10 November 2026 BIS applies a similar test to Entity List affiliates. See the BIS Affiliates Rule post.
Clearing a hit
Work out which list it is on first. For OFAC lists, follow OFAC's steps in FAQ 5; for other agencies' lists, OFAC says to contact the agency that maintains the list. Our false positive guide has a rationale template.
Records
Records required by the Export Administration Regulations are kept for five years from the latest of the export, any known reexport or transfer, or the end of the transaction (15 CFR 762.6). Records of transactions subject to OFAC's rules are kept for at least 10 years (31 CFR 501.601). If one screening record serves both, keep it for 10.
For each check, file the party, the date, the lists and their dates, the result, and the decision with its reason.
Start with the OFAC lists
Run a free OFAC check on your next consignee against the SDN and Consolidated lists. Our search covers OFAC's lists only; use the CSL on Trade.gov for the Commerce and State lists. This is screening data, not legal advice.