BIS Unverified List

The Unverified List (UVL) is maintained by the Bureau of Industry and Security (BIS) within the U.S. Department of Commerce and published at 15 C.F.R. Part 744, Supplement No. 6. A foreign person is added when BIS is unable to complete an end-use check—typically a pre-license check or post-shipment verification—on items subject to the Export Administration Regulations (EAR). Common reasons include the host government blocking the check, the party being non-responsive, or BIS being unable to confirm the bona fides of the recipient (e.g., that the entity exists at the stated address or uses items as represented).

Consequences of UVL placement are narrower than those of the Entity List, but still significant:

• License exceptions are suspended for exports, reexports, or transfers involving a UVL party.
• Exporters must obtain a signed UVL statement from the listed party before shipping items that would otherwise not require a license (the "no-license-required" workaround).
• Transactions receive heightened scrutiny under BIS's "Know Your Customer" guidance and the EAR's "red flag" framework.

Sustained inability to conduct end-use checks can escalate a party from the UVL to the Entity List. BIS formalized this escalation pathway in a final rule effective October 9, 2022, which also clarified that a host-government's refusal to schedule a check within 60 days can itself justify Entity List addition. In practice, BIS has used the UVL heavily against parties in China, Russia, the UAE, and Hong Kong. High-profile actions include the October 2022 addition of dozens of Chinese entities alongside the sweeping advanced-semiconductor controls, and periodic removals after Chinese authorities permitted on-site verifications. The UVL is distinct from OFAC's SDN List, which is sanctions-based rather than export-control-based.