Entity List

The BIS Entity List restricts exports, reexports, and transfers of items subject to the Export Administration Regulations to listed parties without a license. Unlike OFAC's SDN list, Entity List designation doesn't block assets — it requires a license for any EAR-controlled item, and the license review policy for most listed entities is "presumption of denial." As of early 2025, the Entity List has over 800 Chinese entities, including universities, research institutes, and subsidiaries of major manufacturing groups. Entity List screening must cover the ultimate end user, not just the direct buyer — a sale to a distributor who resells to a listed entity still requires a license. We cover Entity List search methodology, end-user due diligence requirements, and the BIS license application process for listed-entity transactions.