Entity List explained: how US export blacklisting works

Entity List explained: what it restricts, who is on it and how to search the BIS list in plain English, with Federal Register citations.

The Entity List is a US government list of foreign companies, research bodies, individuals and addresses that need a licence before they can receive certain US-origin items. It is run by the Commerce Department's Bureau of Industry and Security (BIS) and sits in Supplement No. 4 to Part 744 of the Export Administration Regulations (EAR). You can search it for free through the Consolidated Screening List on trade.gov, which merges it with other US restricted-party lists.

This guide explains what a listing does, how names get on and off, how to run a search, and how the Entity List differs from sanctions lists. It is general information, not legal advice. Anyone screening real transactions should work from the regulations and a compliance adviser.

What the Entity List is

The EAR controls exports, reexports and in-country transfers of items "subject to the EAR". That reaches US-made goods, software and technology wherever they are, and some foreign-made items that contain US content or are built with US technology. The Entity List adds a party-specific layer: for a named entity, BIS can require a licence even for items that would otherwise ship without one.

Each entry carries three things: the entity's name, address and country; the licence requirement, which is often "for all items subject to the EAR"; and a licence review policy. The most common policies are a presumption of denial and case-by-case review. Entries can also say whether any licence exceptions remain available. Under 15 CFR 744.11, licence exceptions are unavailable for listed parties unless the entry itself authorises them.

Listings are not limited to one country. They cover parties in China, Russia, Iran, Pakistan, the UAE and elsewhere, and they cite different reasons, from military end use to diversion of controlled goods.

How a company gets listed

Decisions are made by the End-User Review Committee (ERC). Under 15 CFR 744.16 it is chaired by Commerce and includes State, Defense and Energy, with Treasury involved where appropriate.

The test in section 744.11 is "reasonable cause to believe, based on specific and articulable facts" that a party has been involved in, or poses a significant risk of becoming involved in, activities contrary to US national security or foreign policy interests. Examples in the rule include supporting terrorism, improper transfers or production of conventional weapons, and blocking a BIS or State Department end-use check. US persons cannot be listed under this section.

BIS publishes each change as a rule in the Federal Register, and the rule text, not a press release, is the legal record.

What a listing means in practice

  • Licence requirement. Exporting, reexporting or transferring covered items to the listed party needs a BIS licence, to the extent the entry says so.
  • Address matters. Some entries list an address of concern, so a transaction can be caught because of where a party operates, not only its name.
  • Footnoted entries. Certain entries carry a footnote that brings in the foreign direct product (FDP) rules. These can reach items made abroad with US-origin software, technology or equipment, even when no US-made part is shipped. That is why a listing can hit non-US chip suppliers and equipment makers.
  • Ownership. Section 744.11 also contains an ownership-based provision for foreign entities that are 50 percent or more owned by listed parties. It was part of the September 2025 Affiliates Rule and is currently stayed; see below.
  • Targeted notices. BIS can separately inform a specific party that a licence is required for certain transactions, for example involving agents or shell companies helping a listed entity.

The Affiliates Rule and its suspension

In September 2025 BIS issued an interim final rule extending Entity List and related restrictions to foreign affiliates owned 50 percent or more by listed parties. After US-China talks, BIS stayed it from November 10, 2025. As of October 30, 2026, the eCFR text of 744.11(a)(1) shows the stay running until November 9, 2026, under 90 FR 50857. Whether it is extended is a matter for new BIS notices, so check the Federal Register before relying on either outcome, because that date falls days after this guide was published. Our separate explainer covers the mechanics: BIS Affiliates Rule explained: the 50% rule and its suspension.

Chip-industry listings and their citations

Three listings show how the tool has been used against semiconductor targets. Each rule below is the original Federal Register notice; later rules have revised these entries, so read the current entry in the supplement for the present terms.

  • Huawei Technologies and affiliates were added on May 21, 2019, in 84 FR 22961.
  • SMIC (Semiconductor Manufacturing International Corp.) was addressed in a rule published December 22, 2020, 85 FR 83416, which added entities and revised an entry.
  • YMTC (Yangtze Memory Technologies) appeared in a rule published December 19, 2022, 87 FR 77505.

For how such restrictions feed into hardware supply, see our chips coverage.

How to search the Entity List

The practical route is the Consolidated Screening List (CSL), maintained by the International Trade Administration. It combines lists from Commerce, State and Treasury, including the Entity List, Unverified List, Military End User List and the OFAC SDN List. Each record shows its source agency.

  1. Open the CSL search tool and enter the company name. Add a country filter if the name is common.
  2. Use the fuzzy-name option. According to trade.gov, it returns scored near-matches, which helps with names transliterated from non-Latin scripts.
  3. Filter by source to show only the BIS Entity List.
  4. Open any hit and read the licence requirement, the review policy and the Federal Register citation.
  5. Check addresses and aliases as well as the main name.

The CSL also offers downloadable CSV, TSV and JSON files and an API for building screening tools. Trade.gov says the data refreshes daily at 5:00 AM Eastern, but only as fast as the source agencies supply files. It also warns that a match does not settle the question, and that you should follow up with further due diligence and check the official lists and the Federal Register. The authoritative Entity List text is Supplement No. 4 to Part 744 in the eCFR.

Entity List vs OFAC SDN and other lists

These lists are easy to confuse because they are searched together, but they work differently.

  • Entity List (BIS). A trade-control tool. It restricts the flow of items subject to the EAR to a named party and is tailored per entry. Being listed does not by itself freeze assets or bar all dealings.
  • SDN List (Treasury, OFAC). A sanctions tool. It generally blocks property and prohibits US persons from dealing with the party.
  • Military End User (MEU) List (BIS). Covers specific military end users in certain countries and applies to a defined set of items, rather than the entry-by-entry rules of the Entity List.
  • Unverified List (BIS). Parties whose bona fides BIS could not verify through an end-use check. It brings different, lighter obligations.

A company can appear on more than one list, so screening should cover all of them.

Getting removed or modified

Under 744.16, a listed entity, or the owner or operator of a listed address, may ask in writing for removal or modification, giving its reasons and sending the request to the ERC chair at BIS. The ERC reviews requests using the criteria in Supplement No. 5 to Part 744, and the Deputy Assistant Secretary for Export Administration notifies the requester of the outcome, which is final agency action. Removals are also published in the Federal Register.

For wider policy context, see our tech regulation coverage and the Tech Policy section.

Frequently asked questions

What is the BIS Entity List?

It is a list of foreign parties that need a US licence to receive certain items subject to the EAR, kept in Supplement No. 4 to Part 744. Each entry sets out the licence requirement and review policy for that party.

How do I search the Entity List?

Use the Consolidated Screening List on trade.gov, enter the name, and filter by the BIS Entity List source. Confirm any match against the current entry in the eCFR and the Federal Register.

Is the Entity List the same as a sanctions list?

No. The Entity List is a Commerce export-control list that restricts the supply of specific items. OFAC's SDN List is a Treasury sanctions list that generally blocks property and dealings.

Can a company be removed from the Entity List?

Yes. A listed party can submit a written request to the End-User Review Committee, which reviews it and notifies the requester of its decision. BIS publishes removals as Federal Register rules.

Which Chinese chip companies are on the Entity List?

Huawei, SMIC and YMTC are among the best-known, with the listings cited above. Because entries are revised over time, check the current text of Supplement No. 4 to Part 744 for each one.