Know Your Sanctions Lists - The Entity List

This is the first post in a series of twelve covering the lists that make up the U.S. Government's Consolidated Screening List.  ECScreening includes access to the Consolidated Screening List as well as other sanctions lists and crucial value-adding features such as Recurring Searches, Search History, and Country Alerts.

The Entity List

The Entity List is administered by the U.S. Department of Commerce, Bureau of Industry and Security (BIS).  The list itself is found in Supplement No. 4 to Part 744 of the Export Administration Regulations (EAR) and is updated through Federal Register Notices.

The Entity List began in 1997 as a weapons of mass destruction (WMD) anti-proliferation effort.  It now includes both individuals and entities involved in “activities that are contrary to the national security or foreign policy interests of the United States.” (EAR §744.11).  Listed entities are subject to license requirements for EAR-controlled items (including EAR99 or other items that would otherwise be shipped No License Required, or NLR), typically with a presumption of denial.

For example, Huawei Technologies Co. Ltd., a Chinese telecommunications and electronics manufacturing giant, was added to the Entity List in May 2019.  This listing created a license requirement with a presumption of denial for items subject to the EAR.

The Entity List’s license requirements are “independent of, and in addition to, license requirements imposed elsewhere in the EAR” and license exceptions are generally not available.