Denied Party Digest

Valuable information about denied party screening

Know Your Sanctions Lists - The Unverified List

This is the third post in a series of twelve covering the lists that make up the U.S. Government's Consolidated Screening ListECScreening 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 Unverified List

The Unverified List (UVL) is administered by the U.S. Department of Commerce, Bureau of Industry and Security (BIS).  The list itself is found in Supplement No. 6 to Part 744 of the Export Administration Regulations (EAR) and is updated through Federal Register Notices.

Parties may be added to the Unverified List if the US Government is unable to verify their bona fides (legitimacy and reliability) in an end-use check.

Parties listed on the Unverified List are ineligible to receive items subject to the EAR through license exceptions. The Unverified List does not create a freestanding BIS license requirement, but licenses are required due to unavailable license exceptions.

Transactions that do not require a license – EAR99 or No License Required (NLR) – require an Unverified List (UVL) statement from the listed party.  The requirements for this statement are detailed in §744.15 and include name and contact information, an agreement to comply with the EAR, an end-use declaration, and agreement to cooperate with end-use checks.  An Automated Export System (AES) filing is also required for exports to parties on the Unverified List.

The Unverified List currently includes 158 parties.  Most of these are in China, Hong Kong, and the UAE, but the list also includes parties around the world, from Canada to Estonia to Indonesia.

Parties may be removed from the Unverified List after a subsequent successful end-use check on the listed party.  Listed parties may request removal in writing directly to BIS.

Previous Posts in this Series:

Part 1: The Entity List

Part 2: The SDN List