Sanctions Evasion Reference

BIS: the Bureau of Industry and Security

The US Commerce Department bureau that administers export controls on dual-use items, maintains the Entity List, and enforces the Export Administration Regulations.

acronym

BIS

country

United States

part of

U.S. Department of Commerce

reviewed

2026-08-20

BIS administers what the goods can do rather than who the counterparty is. That distinction is the most common source of confusion in this field, and it matters practically: screening a customer against the SDN List discharges no export control obligation at all.

The Entity List is not a sanctions list

Addition to the Entity List imposes a licence requirement, usually with a stated presumption of denial, on exports of items subject to the Export Administration Regulations to the named party. It does not freeze property and it does not prohibit all dealings.

Conflating it with designation is the most frequent error in reporting on this subject, and the two carry entirely different obligations for anyone dealing with the party.

Extraterritorial reach

Two mechanisms carry US export control jurisdiction into goods made entirely abroad. The de minimis rule catches foreign items containing more than a threshold percentage of controlled US content. The foreign direct product rule catches foreign items that are the direct product of US-origin technology, software or production equipment.

Between them they are the reason a transaction with no US party can require a US licence, and they are what third-country re-export schemes are built to work around.

Its enforcement literature

BIS publishes a case compendium that is one of the most useful open sources on procurement network behaviour, because it describes what the purchaser actually did rather than only what was decided.

Lists it publishes

ListFormatsSource
Entity List (EAR Part 744, Supplement No. 4)HTML, Federal Register Publisher page
Consolidated Screening List (bundled)JSON, CSV Publisher page

Penalty powers. Administrative penalties, denial of export privileges, temporary denial orders, and criminal referral. Entity List addition is a licensing measure rather than a penalty.

Sources

  1. Entity List, Supplement No. 4 to Part 744 of the Export Administration Regulations. U.S. Bureau of Industry and Security, 2026.
  2. Don't Let This Happen to You: Actual Investigations of Export Control and Antiboycott Violations. U.S. Bureau of Industry and Security, Office of Export Enforcement, 2024.
  3. Export Enforcement. U.S. Bureau of Industry and Security, 2026.
  4. Consolidated Screening List. U.S. International Trade Administration, 2026.