BIS Entity List — What It Is, How It Works, and How to Check

What the Entity List Is

The Entity List is a list of foreign persons -- companies, organizations, and individuals -- for whom BIS has determined there are reasonable grounds to believe they have engaged, or present a significant risk of engaging, in activities contrary to U.S. national security or foreign policy interests. 15 CFR Part 744, Supplement No. 4.

The practical effect: exporting, reexporting, or transferring any item subject to the Export Administration Regulations (EAR) to an Entity List company requires a license from BIS. The license requirement applies regardless of the item's Export Control Classification Number (ECCN) -- even EAR99 items require a license for Entity List transactions. The default BIS policy for most Entity List entries is denial.

How Name-Based Entries Work

The standard Entity List entry identifies a specific named company or individual at a specific address. A license is required for any export, reexport, or in-country transfer of EAR-subject items to that named entity.

Screening for name-based entries requires matching each party in a transaction -- the shipper, consignee, end user, and any intermediary -- against the current Entity List. Fuzzy matching matters: variations in name spelling, transliteration, and subsidiary relationships are common failure points.

How Address-Only Entries Work -- and Why They Are a Different Problem

In June 2024 (89 FR 51644, eff. June 12, 2024), BIS added a new category: address-only entries. For an address-only entry, the license requirement applies to all entities using that address in a transaction, regardless of what name appears on the shipping documents. 15 CFR Part 744, Supplement No. 4.

Address-only entries were designed to close a diversion loophole: bad actors who rotate transactions among affiliated companies at the same location to defeat name-based screening. The practical implication is significant -- a new company at a blacklisted address triggers the license requirement even if the company name has never appeared on any restricted list.

Teledyne FLIR ran directly into this gap. When a Russia-diversion hub in Hong Kong was added to the Entity List as an address-only entry in June 2024, FLIR's screening vendor had not yet implemented address-only screening. FLIR contacted the vendor and asked specifically whether address-only entries were covered. The vendor said it was "being addressed internally." Between June and December 2024, eight shipments went through. The penalty was $1,000,000. BIS Final Order (Teledyne FLIR, Feb. 2026), bis.gov/enforcement/settlements.

How to Check

Three resources:

Consolidated Screening List (CSL): csl.trade.gov aggregates the Entity List alongside the OFAC SDN list, the Denied Persons List, the Unverified List, and other restricted-party lists into a single searchable interface. Useful as a starting point. Not a substitute for a calibrated compliance program -- the CSL is as current as its last update, and fuzzy-matching configuration matters.

BIS Entity List (bis.gov/entity-list): The authoritative source directly from BIS. Searchable and downloadable. Updated continuously -- confirm that the version your compliance software is using reflects the current list.

Vendor screening calibration: Checking the list and having your software screen correctly for it are different things. The address-only entry category is the most recent illustration of the gap. Ask your screening vendor specifically: which entry types are implemented? When was the last update applied? What is the lag between a new BIS entry and deployment to your system?

If You Shipped to an Entity List Company

See: Should We Voluntarily Self-Disclose? What BIS Enforcement Actually Shows (/bis-vsd/)

The VSD decision is time-sensitive. Before taking any action, evaluate whether BIS has already initiated an investigation -- that threshold determines whether voluntary self-disclosure remains available and whether the benefit is preserved.