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The Entity List

A key component to a company’s export compliance program should be screening of the U.S. government export sanctioned lists prior to shipment. Lists that should be screened include: Denied Persons List (EAR), Entity List (EAR), Unverified List (EAR), Debarment List (ITAR), Sanctioned Parties List (ITAR), Nonproliferation Sanctions List (ITAR), and Specially Designated Nationals (OFAC).

 

One of the specific lists to check as stated above is the U.S. Commerce Department’s Entity List, a list of names of certain foreign persons – including businesses, research institutions, government and private organizations, individuals, and other types of legal persons – that are subject to specific license requirements for the export, reexport and/or transfer (in-country) of specified items. The Entity List can be found in Supplement No. 4 to Part 744 of the EAR.

 

As you will often find when searching parties on these lists, individual and business names can be similar or share the exact same name with a restricted party.  So how do you determine if the party you are searching is the party included on the Entity List?  The first step is to obtain additional information on the individual or company.  For individuals, you should obtain their employment history, past addresses, past affiliations, etc. For companies,  you should request their business registration and any past addresses.  Once the additional information has been received you can contact the BIS End-User Review Committee for additional assistance or submit an Advisory Opinion asking BIS to make a determination if the party you are inquiring about and the party on the Entity List are the same party.  A similar approach should be taken when reviewing subsidiaries, branches, divisions, affiliated companies who are potentially related to a restricted entity.

 

Should you have any questions on a review of any restricted parties list, please contact your Export Compliance Officer or our firm for further assistance.

 

Wilmarth & Associates also offers a subscription service for our consolidated Restricted Parties Manual which allows easier, less time-consuming searching for subscribers, to avoiding going to each individual restricted list to search. Please contact us if you wish to discuss obtaining a subscription to our Restricted Parties Manual.

 

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