Sanctions Evasion Reference

Entity List

A US Bureau of Industry and Security list of parties subject to specific export licence requirements because of activity contrary to national security or foreign policy interests.

reviewed

2026-08-20

The Entity List is an export control instrument, not a sanctions list. Being on it does not freeze property or prohibit all dealings; it imposes a licence requirement, usually with a stated presumption of denial, on exports of items subject to the Export Administration Regulations to that party.

It is published as Supplement No. 4 to Part 744 of the EAR and is also bundled into the Consolidated Screening List. Confusing it with the SDN List is one of the most common errors in reporting on sanctions, and the two carry entirely different obligations.

Where this term is used

  • What is dual-use re-export diversion? — Buying controlled civil-use goods lawfully in an open market and re-exporting them to a restricted end user, exploiting the fact that the item itself looks entirely ordinary.
  • How are aircraft parts procured in breach of sanctions? — Buying airframe and engine components through intermediaries in unrestricted countries, so that parts for a restricted operator's Western-built fleet arrive with clean paperwork and no airworthiness trail.
  • What is third-country transshipment? — Routing restricted goods through an intermediate country so that the shipment reaching the restricted destination appears to originate somewhere the exporter would have supplied without question.

Related terms

  • Export control — A licensing regime that restricts the export, re-export or transfer of specified goods, software and technology by reference to the item, the destination and the end use.
  • Specially Designated Nationals and Blocked Persons List — The principal United States sanctions list. Property of anyone on it is blocked and US persons are generally prohibited from dealing with them.
  • Screening — Automated comparison of names, identifiers and other transaction data against sanctions lists and internal watchlists, at onboarding and on each payment.
  • Dual-use goods — Items with legitimate civil applications that can also contribute to military or weapons programmes, and which are therefore export-controlled.

Sources

  1. Entity List, Supplement No. 4 to Part 744 of the Export Administration Regulations. U.S. Bureau of Industry and Security, 2026.
  2. Consolidated Screening List. U.S. International Trade Administration, 2026.

All glossary terms