The Bureau of Industry & Security’s jurisdiction is limited to the export, reexport and transfer (in-country) of items subject to the Export Administration Regulations (EAR) and the placement of a person on the Entity List imposes supplemental license requirements and license application review policies on the shipment of items subject to the EAR to that person.

BIS does not have jurisdiction over the import of items into the United States. However, you should consult other lists maintained by the U.S. Government, as sanctions or other restrictions may apply to import transactions with the particular listed entity or from that particular country of import. BIS publishes a consolidated version of all of the U.S. Government lists that may be relevant to your transaction.

BIS does not prohibit the sale or transfer of commodities subject to the EAR to persons on the Entity List if those persons are in the United States. However, the release of software source code or technology in the United States to a person on the Entity List or a person employed by or representing an organization on the Entity List may require a license as a “deemed export.” Should such a person depart the United States, a license will be required for the export of commodities and software (other than software source code) consistent with the entity’s listing on the Entity List.

No. All persons named in Entity List entries are subject to the main entry's licensing requirements and policy.

Branches and operating divisions of a listed entity are, by definition, part of the listed entity. They are not legally distinct entities.

A BIS license is required prior to such a transaction. As stated in § 744.11(a), a license is required for the export, reexport, or transfer (in-country) of items subject to the EAR when an entity on the Entity List is a party to the transaction as described in § 748.5(c)-(f). Parties to the transaction may include purchasers, intermediate consignees (such as forwarding agents), ultimate consignees, and end-users. Any application for such a license will be reviewed in accordance with the License Review Policy associated with the listed entity on the Entity List.

You should call the Office of Exporter Services at 202-482-4811, or e-mail them a question via the website. Pursuant to the guidance in §748.3 of the EAR, you may also submit an advisory opinion request to the End-User Review Committee Chair at [email protected], or call the Committee Chair directly at 202-482-5991. Can a listed entity act as purchaser or freight forwarder to transport my shipment of items subject to the EAR to the ultimate consignee or end-user? A BIS license is required prior to such a transaction.

Yes. As set forth in Supplement No. 5 to Part 744 of the EAR, proposed changes to the Entity List are reviewed and approved by the interagency End-User Review Committee (ERC). Comprised of representatives from the Departments of State, Defense, and Energy, the ERC is chaired by a Commerce employee. In addition to the review of appeals, the ERC reviews the Entity List on an annual basis. Any ERC member agency may also recommend changes to the Entity List on an ad-hoc basis.

Yes. See a consolidated version of all U.S. Government proscribed parties lists on the Consolidated Screening List.

No, it does not.