The Denied Persons List (DPL) is maintained by the Bureau of Industry and Security (BIS), an agency within the U.S. Department of Commerce. It identifies persons—both individuals and companies—who have been formally denied export privileges following an administrative or criminal proceeding under the Export Administration Regulations (EAR), codified at 15 C.F.R. Parts 730–774.
A denial order issued by BIS typically prohibits the named party from participating in any transaction involving commodities, software, or technology subject to the EAR. The prohibitions are sweeping: U.S. persons and foreign parties alike are forbidden from exporting or reexporting items to a denied person, from servicing items already in their possession, or from purchasing items from them with knowledge that an EAR violation has occurred or is intended. Denial orders are usually time-limited (commonly five or ten years) and are published in the Federal Register.
The DPL is distinct from the other BIS-administered screening lists. The Entity List restricts exports to specific foreign parties identified as posing national security or foreign policy concerns, while the Unverified List flags parties whose bona fides BIS could not confirm during an end-use check. The Treasury Department's OFAC separately maintains the Specially Designated Nationals (SDN) List under different statutory authorities. Exporters generally screen against all of these via the U.S. government's Consolidated Screening List.
Violations of a denial order can trigger civil penalties under the Export Control Reform Act of 2018 and criminal prosecution. High-profile DPL actions have included the 2018 denial order against ZTE Corporation, which was suspended after the company agreed to a settlement and compliance monitorship, and earlier denial orders involving entities tied to unauthorized reexports to Iran and other embargoed destinations.
For MUN delegates and researchers, the DPL illustrates how export-control enforcement operates as a targeted sanction—punishing specific actors for documented EAR breaches rather than imposing broad country-based embargoes.
Example
In April 2018, BIS placed ZTE Corporation on the Denied Persons List after finding the Chinese telecom firm violated a 2017 settlement related to unlawful exports to Iran and North Korea.
Frequently asked questions
The DPL names parties who have already been adjudicated to have violated the EAR and stripped of export privileges, whereas the Entity List restricts exports to parties identified as national security or foreign policy risks, often without a finding of past violation.
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