BIS denied persons list screening

Description

Denied-persons screening is the export-controls equivalent of sanctions screening: before any export-controlled transaction (which under the EAR's deemed-export rules can include sharing technical data with non-US-person employees, not just shipping a physical good), the counterparty has to be screened against the relevant US Bureau of Industry and Security restricted-party lists. The operative lists are the Denied Persons List (categorically prohibited counterparties), the Entity List (counterparties subject to specific licensing requirements that vary per entry), the Unverified List (counterparties for which BIS could not complete an end-use verification), and the Military End User List for the specific Cat-5 and Cat-6 contexts where it applies. Implementation has two pieces: the screening tooling that automatically checks new counterparties at onboarding and re-screens existing counterparties on the BIS update cadence (which is irregular but typically multiple times per month), and the match-handling workflow that triages potential matches into clear hits, false positives, and ambiguous cases requiring human review with documented disposition. The lists update faster than most internal review cycles, so a counterparty that screened clean six months ago may have been added since; the re-screening cadence rather than the initial screen is where most enforcement gaps surface.

Applicability

Applies when: markets include US.

How predicates are evaluated

Required by (1 regulation)

• US EAR

  15 CFR §744 + Part 744 Supp. Nos. 4, 6, 7 — screen against Entity List, Denied Persons List, Unverified List, MEU List; Consolidated Screening List aggregates BIS + OFAC + State Department restricted-party data.

  15 CFR §744 + Part 744 Supp. Nos. 4, 6, 7

Fulfilled by (2)

• comply-advantage · full · medium effort · $$
• descartes · full · medium effort · $$

ClearLaunch does not accept payment from vendors. Methodology.

Evidence formats

• BIS list screening logs