This list is published in the IAEA’s Information Circular titled "Agreement between the Government of India and the International Atomic Energy Agency for the Application of Safeguards to Civilian Nuclear Facilities" (INFCIRC/754), which is available at the IAEA’s website (www.iaea.org).

No. Hospitals and medical centers of Indian Department of Atomic Energy (DAE) entities are not—and were never intended to be--captured by the Entity List. Consequently, hospitals and medical centers of DAE entities are not subject to the Entity List’s licensing requirements. Note that the licensing requirements found elsewhere in the EAR may be applicable to such hospitals and medical centers. Such hospitals and medical centers would also be generally subject to destination-based licensing requirements that apply to India.

No. Although both the Denied Persons List (DPL) and the Entity List are administered by the Department of Commerce, they are separate and distinct lists. The DPL includes parties that have been denied export and reexport privileges. In contrast, the Entity List imposes specific license requirements for the export, reexport, or transfer (in-country) of specified items to the persons named on it.

No. The SDN List is published by the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC). The SDN List has different foreign policy objectives and legal requirements than the Entity List.

The Entity List includes restrictions on exports, reexports, or transfers (in-country) to certain persons by reference, meaning that the EAR defines the licensing policy and requirements specific to such persons but does not necessarily include them as individual entries on the Entity List. These persons are designated in or pursuant to Executive Orders or other legal mechanisms.

The Departments of Commerce, State, and the Treasury maintain separate lists for the programs each agency administers because these programs have different purposes and are regulated under different authorities. BIS maintains three lists: the Denied Persons List (DPL); the Unverified List; and the Entity List. The Entity List is described in detail in these FAQs and can be found here. The DPL lists persons that have been denied export privileges; any dealings with persons listed on the DPL that violate the terms of their denial order would be a violation of the EAR.

It depends on what your company wants to donate, whether BIS requires a license for the export, reexport, or transfer of that item to the university (as specified in the Entity List entry for the university), and, given that a license is required, whether BIS approves your license application.

Employees of persons on the Entity List are subject to the licensing requirements and policies specific to their employer. Therefore, in the case of universities on the Entity List, employees of the universities are subject to the same licensing policy and requirements that the universities are. This also applies to officers, trustees, and other persons in a similar position with the university. Can my company hire an individual who used to be employed by a university on the Entity List? Yes.

Pursuant to §734.8 of the EAR, information resulting from fundamental research is not subject to the EAR. Therefore, given that the collaboration remains limited to fundamental research, it cannot be subject to the Entity List’s licensing requirements and policies. Any research undertaken that involves the export, reexport, or transfer of an item subject to the EAR and that does not conform to the requirements of § 734.8 of the EAR may, depending on the licensing requirements and policies specified in the Entity List entry, require a license from BIS.

A student’s enrollment at a university included on the Entity List is a “red flag” which requires exporters undertake an additional level of due diligence before proceeding with any such transaction. However, a student is not an integral part of the university (e.g., does not have fiduciary duty to from the university in the same manner that as an employee, officer, trustee, or person in a similar position in the university would) in which he/she is enrolled and therefore BIS does not include them in the licensing requirements and policy specific to the university.