The Key Sanctions Lists Every U.S. Company Should Know About

Over the past decade or so, a succession of U.S. presidential administrations representing both political parties have ramped up the number of countries, entities, and individuals targeted by American sanctions. At any one time today, there are roughly 15,000 companies and individuals on one of the myriad U.S. sanctions lists. These lists are maintained by a variety of U.S. agencies and bureaus, including the Department of Homeland Security (DHS), the State Department, the Bureau of Industry and Security (BIS), and the Office of Foreign Assets Control (OFAC). 

At any one time today, there are roughly 15,000 companies and individuals on one of the myriad U.S. sanctions lists.

Businesses that use international suppliers and draw on global supply chains should familiarize themselves with the landscape of U.S. sanctions lists (as well as a few key international sanctions). Because these lists are highly dynamic, and often subject to sudden revisions or expansions based on new developments and other material revelations, companies would be well-served to keep regular tabs on these lists and new sanctions targets that are added to them. Violating U.S. sanctions by doing business with an individual, entity, or country on one of these lists can result in swift and severe punishments. These include financial penalties in the hundreds of thousands of dollars and—in the case of willful violations that bring about criminal charges—stiff prison sentences. 

U.S. Sanctions Lists 

The U.S. imposes sanctions on thousands of targets all over the world. Keeping track of these 11 lists—which collectively encompass a significant proportion of the nation’s total sanctions—puts U.S. firms in a strong, agile position to understand, assess, and mitigate risks associated with sanctioned entities. 

BIS Unverified List 

The Bureau of Industry and Security maintains three primary sanctions lists: the Unverified List (UVL), the Entity List, and the Denied Persons List (DPL). The BIS Unverified List consists of parties that have either not cooperated with the BIS during verification checks, or that the agency otherwise has not been able to verify with respect to the Export Administration Regulation (EAR). (EAR regulates and restricts the export of technology, software, and other commodities for national security and foreign policy purposes.)

According to the Code of Federal Regulations, individuals and entities may be added to the BIS Unverified List if BIS “cannot verify the bona fides (i.e., legitimacy and reliability relating to the end use and end user of items subject to the EAR) of such persons.” Such a failure could occur because a pre-license check, post-shipment verification, or other verification check conducted by the Department of Commerce or the BIS could not be completed to a satisfactory degree. While the BIS Unverified List is not intended to serve a punitive function for included parties, individuals and entities on the UVL are ineligible to receive any items subject to the EAR.

Why It Matters to U.S. Manufacturers 

U.S. original equipment manufacturers (OEMs) and other companies operating in the electronics supply chain may want to pay particular attention to the BIS UVL, as firms included on the list are prohibited from receiving U.S. exports of certain sensitive technologies. 

BIS Entity List 

The second major sanctions list administered by the Department of Commerce, the Entity List is composed of individuals, businesses, organizations, and other “legal persons” that U.S. businesses must fulfill special licensing requirements for in order to send any items subject to the EAR. These licensing requirements may vary between listed entities, and the Entity List published in the Code of Federal Regulations specifies these obligations. The BIS is responsible for reviewing these license applications and evaluating them according to “all applicable licensing policies.”

Why It Matters to U.S. Manufacturers 

A large and consistently expanding set of parties that the Department of Commerce has identified as posing a potential risk to the national security interests of the U.S., the Entity List increased nearly ten-fold in the decade between 2011 and 2021. Today, it restricts well over 1,000 entities from receiving U.S. exports. 

Denied Persons List 

The Denied Persons List is the most restrictive of the three interrelated lists managed and administered by the BIS. Individuals and entities on the DPL have had their export and re-export privileges explicitly denied by the agency. Any attempt to export or re-export goods to any of the parties on the list would constitute a violation of federal law and could result in substantial fines and even imprisonment. 

Why It Matters to U.S. Manufacturers 

Another list encompassing hundreds of entities ranging from large manufacturers headquartered in Iran to Turkish nationals, the DPL is a critical list to pay attention to because of its legal implications. Violating the Export Administration Regulation (EAR) by exporting goods to an entity on the DPL could result in financial penalties of up to $1 million and a maximum prison sentence of 20 years. 

NDAA 889 

The National Defense Authorization Act (NDAA) for 2019 included a section, titled “Prohibition on Contracting With Entities Using Certain Telecommunications and Video Surveillance Services or Equipment,” that is now simply referred to as Section 889. NDA Section 889 prohibits executive agencies and their contractors from entering, extending, or renewing contracts with outside entities that use “covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system.” This provision of the NDAA entered into force in August 2020. 

Though the phrase “covered telecommunications equipment or services” seems almost deliberately vague and indefinite, it actually refers to goods and services from a highly specific group of companies. NDAA Section 889 restricts the federal government from obtaining certain telecommunications equipment and services from Huawei Technologies, ZTE Corporation, and any subsidiaries or affiliates of those companies. In addition, the act prohibits agencies from obtaining specific video surveillance products and telecommunications equipment from Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, or Dahua Technology Company (as well as any subsidiary or affiliate of those firms). 

The purpose of NDAA 889 is to protect the U.S. federal government, its executive agencies, and American industry from foreign attempts to exfiltrate sensitive data, carry out acts of cyberespionage, and steal technological and industrial secrets. As the final rule explained, because the People’s Republic of China possesses sophisticated cyber operations that are being actively used against the U.S., a “proactive cyber approach is needed to degrade or deny these threats before they reach our nation’s networks, including those of the Federal Government and its contractors.”

As the final rule explained, because the People’s Republic of China possesses sophisticated cyber operations that are being actively used against the U.S., a “proactive cyber approach is needed to degrade or deny these threats before they reach our nation’s networks, including those of the Federal Government and its contractors.”

Why It Matters to U.S. Manufacturers 

The reason U.S. manufacturers and other American businesses should familiarize themselves with NDAA Section 889 and take its restrictions seriously is simple: the act applies not only to executive agencies but also to federal contractors. Any organization fulfilling a federal contract must steer clear of the five companies mentioned above and their subsidiaries. 

NDAA Section 1260H

As with Section 889, this sanctions list also first appeared in a National Defense Authorization Act, in this case for 2021. Section 1260H of the 2021 NDAA requires the U.S. Department of Defense (DoD) to publish an annual list of “Chinese military companies” (CMCs) that are contributing to the Chinese Communist Party’s (CCP) military-civil fusion strategy and actively operating “directly or indirectly in the United States.” 

The CCP’s military-civil fusion is a sweeping and ambitious national initiative to rapidly accelerate China’s military capabilities by granting the government and military unprecedented access to the country’s science and technology sectors. The doctrine is not restricted to China’s domestic corporations and their industries, however. As the U.S. Department of State explained in a document outlining the doctrine, the CCP is not only implementing the strategy through its own home-grown research and development efforts, “but also by acquiring and diverting the world’s cutting-edge technologies – including through theft – in order to achieve military dominance.”

NDAA Section 1260H was created to combat and counter this multifaceted project and its alleged insidious tactics by identifying CMCs. Though there are currently no legal repercussions for entities on the Section 1260H list, the 2024 NDAA included a provision that will eventually restrict the Department of Defense from contracting with any entities on the list. 

Why It Matters to U.S. Manufacturers 

The significance of NDAA Section 1260H for U.S. firms contracting with the federal government is specific and nuanced. As stated above, there are no current legal prohibitions on purchasing commodities from firms identified as CMCs. However, beginning in June 2026, the DoD will be restricted from executing, renewing, or extending contracts with any of the companies on the CMC list—and this prohibition will almost certainly extend to DoD contractors. 

NDAA Section 5949 

Part of the Fiscal Year 2023 National Defense Authorization Act, Section 5949 prohibits federal agencies—as well as their contractors—from procuring products or services that contain or otherwise use “covered semiconductor products or services.” This NDAA provision also targets China, in this case Chinese semiconductor manufacturers. The “covered semiconductor products or services” outlined in Section 5949 include those designed, manufactured, or provided by the Semiconductor Manufacturing International Corporation (SMIC); ChangXin Memory Technologies (CXMT); Yangtze Memory Technologies Corp (YMTC); or any of these companies’ subsidiaries or affiliates. 

Why It Matters to U.S. Manufacturers 

Simply put, American businesses contracted by U.S. government agencies cannot procure semiconductors from SMIC, CXMT, or YMTC. 

BIS Military End User (MEU) List 

Published for the first time in December 2020, the BIS’s MEU List targets foreign parties that the U.S. government has determined are functioning as “military end users” and pose a significant risk of diverting goods to military use in either China, Russia, or Venezuela. A special license is required to export, re-export, or transfer any items subject to the Export Administration Regulation when an entity on the MEU List is a party to the transaction. 

An updated version of the MEU List can be viewed in the Code of Federal Regulations. 

Why It Matters to U.S. Manufacturers 

Another export control in the vein of the Denied Persons List, the MEU List is similarly worth paying attention to because of the hefty repercussions associated with violating it (as with the DPL, up to $1 million and a maximum prison sentence of 20 years).

UFLPA Entity List 

The Uyghur Forced Labor Prevention Act (UFLPA) was enacted in December 2021 and entered into force six months later, in June 2022. The legislation’s express objective is to deter U.S. importers from doing business with any individuals, businesses, or other entities that have ties to China’s systematic forced labor practices in the nation’s Xinjiang-Uyghur Autonomous Region (XUAR). 

To help enforce the UFLPA and ensure that the Department Homeland Security—the agency responsible for the law’s strategy and implementation—is effectively repelling any goods mined, manufactured, or produced using forced labor from U.S. ports of entry, the DHS maintains a UFLPA Entity List containing entities with established links to forced labor in the XUAR. Following multiple additions through the first half of 2024, the UFLPA Entity List now covers nearly 70 companies across a wide cross-section of sectors. The official list is published and updated regularly on the DHS website. 

Why It Matters to U.S. Manufacturers 

Considering how much attention has been paid to the UFLPA and its accompanying Entity List by U.S. businesses, politicians, and news agencies over the past year, its implications and significance should be self-evident. Violating the UFLPA—either by doing business with suppliers connected to the XUAR or those on the Entity List—can result in costly detainments and high-profile scandals with the potential for enduring reputational damage. 

AECA Debarred List 

Any individuals, organizations, or other entities convicted of violating or conspiring to violate the Arms Export Control Act (AECA) are subject to “statutory debarment” and placed on the AECA Debarred List. Persons on the AECA Debarred List are strictly prohibited from participating—either directly or indirectly—in any activities regulated by the International Traffic in Arms Regulation (ITAR). This includes the export of defense articles and services. 

Statutory debarment, and thus inclusion on the AECA Debarred List, remains in effect until the debarred person applies for reinstatement through the Directorate of Defense Trade Controls (DDTC). The DDTC, the organization tasked with enforcement of ITAR, must approve the application for any legal person to be removed from the Debarred List. 

Why It Matters to U.S. Manufacturers 

As with the BIS Entity List, this is a sweeping sanction that restricts hundreds of individuals and organizations from participating in transactions and transfers involving defense items. Any U.S. company operating in the aerospace and defense industry should be familiar with the AECA Debarred List, and have a screening mechanism in place for rooting out debarred parties. 

Nonproliferation Sanctions List 

The Bureau of International Security and Nonproliferation (ISN), housed within the U.S. Department of State, is responsible for monitoring nuclear proliferation threats throughout the world and crafting robust policy responses aimed at deterring the development of weapons of mass destruction (WMDs) and other advanced weapons capabilities. ISN imposes sanctions against governments, individuals, and other entities engaged in these proliferation activities. Though the ISN uses “various legal authorities” to impose sanctions in response to these activities, the Department of State maintains a complete master list of the bureau’s sanctioned entities.

Why It Matters to U.S. Manufacturers 

The ISN uses a myriad of laws, acts, and executive orders to impose sanctions on foreign entities, and the master list of individuals and organizations sanctioned by the bureau is extensive and modified regularly. 

OFAC U.S. Sanctions List

The Office of Foreign Asset Control (OFAC) maintains its own Sanctions List, which is actually a consolidation of a range of smaller U.S. sanctions lists and related programs. These include the Foreign Sanctions Evaders List, the Sectoral Sanctions Identifications List, and the Non-SDN Communist Chinese Military Companies List, among others. 

Why It Matters to U.S. Manufacturers 

OFAC’s consolidated list covers a lot of territory, and keeping track of it is a responsible and efficient way for manufacturers to ensure compliance with a multitude of U.S. sanctions lists. 

International Sanctions Lists

In addition to the major U.S. sanctions lists, there are also a few critical international sanctions lists that U.S. companies should be keeping an eye on. Either because of the scope of the sanctions or the country’s strategic and trade importance to American businesses, these lists are among the most consequential non-U.S. sanctions in the world. 

UK Sanctions List 

The United Kingdom imposes a range of different types of sanctions, including trade restrictions, arms embargoes, and asset freezes. The complete UK Sanctions List—which includes thousands of sanctions targeting individuals, organizations, companies, and other entities—can be accessed on the UK government’s website. 

Why It Should Matter to U.S. Manufacturers 

U.S. OEMs and other companies that do business in the UK should be well aware of this list. Like the U.S., the United Kingdom has ramped up its trade sanctions in recent years, and recently established a new enforcement body and stiffer financial penalties for violators. 

Taiwan SHTC Entity List 

Taiwan’s Foreign Trade Act establishes a legal framework for regulating the trade of strategic high-tech commodities (SHTC). In addition to regulating imports and exports of SHTCs through the Bureau of Foreign Trade (BOFT), Taiwan also maintains an Entity List of individuals and companies that require a special license to trade with. 

Why It Should Matter to U.S. Manufacturers 

Controlling over two-thirds of the global semiconductor manufacturing market, Taiwan is an undisputed fulcrum for the international chips ecosystem and the many industries that rely on it. Understanding how the Taiwanese government regulates SHTCs and its related Entity List can be crucial to establishing long-term business relationships in the nation. 

Consolidated Canadian Autonomous Sanctions List 

Canada maintains a consolidated list of individuals and entities subject to sanctions under two different acts—the Special Economic Measures Act (SEMA) and the Justice for Victims of Corrupt Foreign Officials Act (JVCFOA). The Consolidated Canadian Autonomous Sanctions List, which is updated regularly by the Canadian government, can be accessed and searched on the government’s website. 

Why It Should Matter to U.S. Manufacturers 

Canada is the U.S.’s largest trading partner, with hundreds of billions of dollars worth of imports and exports in any given year. Adhering to the nation’s two trade acts—and the consolidated sanctions list that reflects them—is essential to maintaining this fruitful relationship. 

Tracking Crucial Domestic and International Sanctions 

The 14 sanctions lists outlined above can have a substantive impact on how U.S. companies source materials and parts, establish relationships with foreign suppliers, and build out their supply chains. Manually tracking your compliance to each list for expansions, revisions, and other changes, however, may simply be too cumbersome a task for some businesses. 

Z2Data’s supply chain risk management platform lets companies quickly cross-reference their Tier 1 and subtier suppliers against entity lists, making it easy to spot noncompliance. The platform also helps identify potential subtier suppliers that might end up on these lists, allowing companies to tackle existing risks and stay ahead of future ones. By providing an effective tool to track and manage supplier compliance, companies save time and resources they would otherwise spend pulling this information themselves.

The platform also helps identify potential subtier suppliers that might end up on these lists, allowing companies to tackle existing risks and stay ahead of future ones.

To learn more about how Z2Data’s solutions give you visibility into your suppliers, contact one of our product specialists to learn more.