Disbursement Controls Resource · Reference Tables

Commerce (BIS) Restricted & Denied Parties Reference

The Bureau of Industry and Security administers these lists under the Export Administration Regulations (EAR) — a separate legal authority from OFAC's Treasury-based sanctions. A vendor can be entirely clean on the SDN List and still be restricted here if export-controlled items, software, or technology are involved.

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$300K+

Civil penalty per EAR violation, or twice the transaction value, whichever is greater

$1M / 20 yrs

Maximum criminal fine and imprisonment for willful export violations

BIS restricted-party lists that feed the government's Consolidated Screening List

Program / Item	What It Covers	Why AP Should Care
Denied Persons List	Individuals and entities denied export privileges under EAR Parts 764 and 766 following confirmed violations. Acting in violation of the terms of a denial order is itself a separate EAR violation.	Treat as a hard stop for any export-related transaction. Reinstatement requires specific BIS authorization — it doesn't expire on its own.
Entity List	Parties reasonably believed to be, or at risk of becoming, involved in activities contrary to U.S. national security or foreign policy — commonly tied to military end-use, WMD proliferation, or sanctions-evasion concerns.	Listed parties carry a presumption-of-denial licensing policy. Any payment tied to an export transaction with these vendors needs a license review, not just a name screen.
Unverified List	Parties whose legitimacy BIS could not confirm through an end-use check, often because a verification visit could not be completed for reasons outside the government's control.	A documented “red flag” that requires a signed end-user statement before shipment. Absence from the Entity List doesn't mean a vendor is clear.

This reference is provided as an educational resource for accounts payable, treasury, and shared services professionals. It does not constitute legal, tax, or compliance advice. Figures and list contents change; verify against the official source before acting.