BIS Entity List: Why It May Appear in Sanctions Screening
In brief: The BIS Entity List is a US export-control list that may matter to UK firms where a client or matter has US technology, goods, export, or group-policy exposure.
Key points
- The BIS Entity List is not the same as the UK sanctions list.
- It may still matter for clients with US export-control or technology exposure.
- Document why the list hit is relevant or not relevant to the matter.
What is the BIS Entity List?
The BIS Entity List is maintained by the US Bureau of Industry and Security. It is mainly an export-control list, not a UK AML list. It can still appear in screening tools and may matter where a client deals with US-origin goods, software, technology, or controlled items.
When UK firms should care
- The client trades in sensitive goods or technology.
- There is a US export-control nexus.
- A group policy requires BIS screening.
- A counterparty appears on the list.
- The firm is advising on cross-border trade, restructuring, or funds.
What to record
Record the source, result, US nexus analysis, client explanation, specialist advice if needed, and final decision.
Always check current official sources before deciding. UK firms should start with the UK sanctions list, the OFSI consolidated financial sanctions list, and the relevant GOV.UK regime pages.