Written and maintained by CASRAI Editorial Board
Last updated
Who this is for: sponsored-programs, research-security and export-control staff, and researchers who ship items, share technology or host collaborators and need to know what a BIS Entity List hit means and what to do next. After reading you should be able to explain the rule, read an entry correctly and place the list among the other restricted-party lists.
What the BIS Entity List is and who runs it
The BIS Entity List is a list of persons and addresses published by the Bureau of Industry and Security (BIS), part of the US Department of Commerce, as Supplement No. 4 to part 744 of the Export Administration Regulations (EAR). Per 15 CFR 744.16, it identifies persons or addresses reasonably believed to be involved in activities contrary to US national security or foreign policy interests. Being listed does not by itself ban dealings with an entity. Each entry carries its own license requirement, set out in the entry (as described in 15 CFR 744.16, read 2026-11-08 at law.cornell.edu).
BIS adds entities through decisions of the End-User Review Committee (ERC), which follows procedures in Supplement No. 5 to part 744 (15 CFR 744.11, read 2026-11-08). Additions and changes are published as Federal Register rules that amend Supplement No. 4. Because the list changes by rulemaking, always screen against the current text, not a saved copy.
Why an entity is listed
Under 15 CFR 744.11(b), an entity can be added where there is “reasonable cause to believe, based on specific and articulable facts” that it has engaged in, is engaged in, or poses a significant risk of engaging in activity contrary to US national security or foreign policy interests, including human rights. The regulation gives illustrative activities, among them:
- supporting terrorism;
- enhancing the military capability of state sponsors of terrorism;
- improper conventional-weapons activity;
- obstructing end-use checks, for example by refusing, giving false information or evading them. A host government’s sustained lack of cooperation that prevents end-use checks can also put an entity at risk.
The same section says the provision cannot be used to list a US person. Section 744.11(c)(3) lets the ERC add entities or addresses presenting a high diversion risk. These are the “address only” entries people search for.
What listing requires: reading the rule
The operative text is 15 CFR 744.16. The table restates it clause by clause (read 2026-11-08).
| Clause | What it says | What it means in practice |
|---|---|---|
| 744.16(a) | Without a BIS license, you may not export, reexport or transfer (in-country) items when a listed entity, or a listed high-diversion-risk address tied to one, is a party to the transaction. The requirement for each entry is in its “License Requirement” column. | The trigger is a listed party to the transaction, not only the final destination. The scope differs per entry, so read the entry itself. |
| 744.16(b) | No license exceptions are available for exports, reexports or transfers to listed high-diversion-risk entities or addresses. Narrow exceptions exist for certain items to listed Indian or Pakistani entities for civil aviation safety, and for entities added under 744.20 to the extent the list specifies. | For those high-diversion-risk entries, an exception you would normally use is not open to you. |
| 744.16(c) | The license review policy for each entry is in its “License Review Policy” column. | The entry also tells you how BIS will approach an application, not only whether one is needed. |
How universities screen against the list
The steps below are an editorial workflow built on the regulation text above and the Consolidated Screening List description from trade.gov (checked 2026-07-17). They are not a BIS-prescribed procedure. Your export control officer or counsel decides the institution’s own process.
- Identify the parties. Include the sponsor, collaborator, shipping recipient, end user, visiting scholar’s home institution and any intermediary. Section 744.16(a) applies where a listed entity is a party to the transaction.
- Screen name and address. The Consolidated Screening List lets you check one name against every contributing list at once, and its source lists refresh daily per trade.gov. Address-only entries mean an address match matters even when the name differs.
- Trace any hit to Supplement No. 4. The CSL is a consolidation layer, not a separate legal regime. Read the entry in the Entity List itself: the License Requirement column and the License Review Policy column.
- Check the item and the activity. What the entry requires depends on the items it covers. Classify the item or technology first; see export control classification.
- Stop and escalate. If a licence is required, do not ship, release or share technology until the export control officer has a BIS determination.
- Keep a record. Document the date screened, the list version or source, the parties checked and the outcome, so you can show what you knew when.
Typical trigger points are new sponsored agreements, subawards and foreign collaborations, purchase orders and shipments, visitor and scholar invitations, and technology sharing under a technology control plan. The wider program context is in the ITAR and EAR compliance guide for university research.
Common mistakes
- Treating a listing as a blanket ban. The requirement is set entry by entry. Read the License Requirement column rather than assuming.
- Screening only the destination country. Section 744.16(a) turns on listed parties to the transaction, so a recipient in an otherwise ordinary destination can still trigger a licence requirement.
- Screening names only. Address-only high-diversion-risk entries exist under 744.11(c)(3).
- Assuming a licence exception will cover it. For high-diversion-risk entries, 744.16(b) allows no license exceptions, apart from the narrow ones it lists.
- Relying on an old copy of the list. It changes through Federal Register rules; screen at the time of the transaction.
- Stopping at the CSL result. The CSL points you to the source list, but the legal consequence sits in the source regulation.
Related lists: how the Entity List fits
Per trade.gov’s description of the Consolidated Screening List (checked 2026-07-17), the CSL consolidates these lists from three departments. The Entity List is one of several, each under its own legal authority.
| Agency | Lists consolidated in the CSL |
|---|---|
| Commerce / BIS | Denied Persons List, Entity List, Unverified List, Military End-User List |
| State | AECA Debarred List, Nonproliferation Sanctions list |
| Treasury / OFAC | SDN List and other OFAC sanctions lists (for example the Foreign Sanctions Evaders List and Sectoral Sanctions Identifications List) |
The SAM.gov Exclusions list, which covers federal procurement debarment and suspension under 2 CFR Part 180, is a different list with a different purpose and is not part of the CSL. For the term itself see Consolidated Screening List (CSL); for the Treasury side see OFAC list and sanctions and embargoes in university research. The two export regimes behind the Commerce and State lists are compared in ITAR vs EAR.
Frequently asked questions
How do I search the BIS Entity List?
The list itself is Supplement No. 4 to part 744 of the EAR. For a name check across all the US restricted-party lists at once, use the Consolidated Screening List at trade.gov, which offers a search, downloadable files and a public API. Then confirm any hit against the Entity List entry.
Is the Entity List the same as the Consolidated Screening List?
No. The Entity List is one list, run by BIS. The CSL is a consolidation of lists from Commerce, State and Treasury and is not a separate legal regime.
What does “address only” mean?
Under 15 CFR 744.11(c)(3) the ERC may add entities or addresses presenting a high diversion risk, and 744.16 applies to listed addresses as well as listed entities. An address-only entry attaches the requirement to the address.
Is a particular company, such as Huawei, DJI, iFlytek or FiberHome, on the list?
Listings change by rulemaking, so check the current Supplement No. 4 and the CSL on the day of the transaction rather than relying on a page like this one. The entry will show the License Requirement and License Review Policy that apply.
Can a licence exception be used for a listed entity?
For listed high-diversion-risk entities or addresses, 744.16(b) says no license exceptions are available, with the narrow exceptions it names. For other entries, the entry text governs.
Can a US person be placed on the list?
No. Section 744.11 states that it cannot be used to list a US person.
Sources
- 15 CFR 744.16, Entity List (Cornell LII, law.cornell.edu/cfr/text/15/744.16), read 2026-11-08.
- 15 CFR 744.11, License requirements that apply to entities acting contrary to the national security or foreign policy interests of the United States (law.cornell.edu/cfr/text/15/744.11), read 2026-11-08.
- Consolidated Screening List, International Trade Administration (trade.gov/consolidated-screening-list), checked 2026-07-17.
This page is general information, not legal advice. Consult your institution’s export control office or counsel for determinations.
