BIS Military End User List

The Military End User (MEU) List is maintained by the U.S. Department of Commerce's Bureau of Industry and Security (BIS) and published as Supplement No. 7 to Part 744 of the Export Administration Regulations (EAR). It identifies foreign entities that BIS has determined are "military end users" within the meaning of EAR §744.21, meaning national armed services, national guard, national police, government intelligence or reconnaissance organizations, or any person or entity whose actions or functions are intended to support military end uses.

BIS introduced the list on December 23, 2020, initially designating dozens of companies in China and Russia, and later expanded it to include parties in Venezuela and Burma (Myanmar). Once a party appears on the MEU List, exports, reexports, or in-country transfers of items enumerated in Supplement No. 2 to Part 744 — which covers a wide range of electronics, sensors, materials, telecommunications, and aerospace items — require a BIS license, generally reviewed under a presumption of denial.

The MEU List should not be confused with related BIS instruments:

• The Entity List (Supplement No. 4 to Part 744) imposes broader, party-specific license requirements often covering all items subject to the EAR.
• The Unverified List flags parties BIS cannot verify through end-use checks.
• The Military Intelligence End User (MIEU) List, added in 2021, targets intelligence organizations specifically.

Importantly, the MEU List is non-exhaustive: even if a party is not listed, exporters still bear due-diligence obligations under §744.21 when they know or have reason to know an item is destined for a military end use or end user in covered destinations. Treasury's OFAC sanctions operate separately and can apply concurrently. Violations of the EAR may result in administrative penalties, denial of export privileges, and criminal prosecution under the Export Control Reform Act of 2018.