AECA Debarred List
A State Department list of individuals and entities debarred from participating in the export or import of defense articles under the Arms Export Control Act — maintained by the Directorate of Defense Trade Controls.
Definition
The AECA Debarred List — formally the List of Statutorily Debarred Parties — is maintained by the U.S. Department of State's Directorate of Defense Trade Controls (DDTC) and identifies individuals and entities that have been debarred from participating in the export or import of defense articles and defense services controlled under the International Traffic in Arms Regulations (ITAR). Debarment is imposed following criminal convictions under the Arms Export Control Act (AECA) or the Export Administration Act, and it prohibits the debarred party from any involvement in ITAR-regulated transactions.
What Triggers AECA Debarment
AECA debarment is imposed by the State Department following a criminal conviction for violations of the Arms Export Control Act or the Export Administration Act. Unlike BIS denial orders — which can result from administrative proceedings — AECA debarment requires a criminal conviction. This makes the AECA Debarred List a list of parties who have been found guilty in a court of law of violating U.S. arms export laws.
Common violations that result in AECA debarment include unauthorized export of ITAR-controlled defense articles, trafficking in arms without a license, and conspiracy to violate the AECA. Both U.S. and foreign persons can be debarred.
What AECA Debarment Prohibits
Debarment under the AECA is broad. A debarred party is prohibited from participating, directly or indirectly, in any transaction involving the export, import, transfer, re-transfer, or manufacture of any defense article or defense service. This prohibition extends beyond being a direct exporter — a debarred party cannot serve as a freight forwarder, broker, consultant, intermediary, end user, or in any other capacity in an ITAR-regulated transaction.
ITAR-regulated companies must ensure that no debarred party is involved in any capacity in their export transactions. This requires screening not only direct customers but also freight forwarders, brokers, and other intermediaries.
AECA Debarred List vs. BIS Denied Persons List
Both lists prohibit covered parties from participating in U.S. export transactions, but they arise from different legal authorities and cover different regulatory regimes. The AECA Debarred List (State/DDTC) covers ITAR-regulated defense articles and arises from criminal convictions under the AECA. The BIS Denied Persons List (Commerce/BIS) covers EAR-regulated items and can arise from either criminal convictions or administrative proceedings under the EAR.
A comprehensive party screening program must check both lists — as well as the OFAC SDN List and other government watchlists. The U.S. Consolidated Screening List includes both the AECA Debarred List and the Denied Persons List, allowing a single search to cover both.
Duration and Waiver of Debarment
AECA debarment lasts for a period specified in the conviction — typically three years, though it can be longer. In some cases, the State Department may grant a waiver of debarment if it determines that doing so is in the national interest, typically to allow a debarred party to continue performing on existing U.S. government contracts. Waivers are narrowly granted and do not represent a full reinstatement of export privileges.
How TradeLasso Helps
The AECA Debarred List is included in every TradeLasso screening search through the U.S. Consolidated Screening List — giving ITAR-regulated exporters a single, documented record confirming that all 13 government watchlists, including the State Department's debarment list, were checked.
Frequently Asked Questions
Is the AECA Debarred List included in the Consolidated Screening List?
Yes. The AECA Debarred List is one of the State Department lists included in the U.S. Consolidated Screening List. A comprehensive CSL search covers the AECA Debarred List alongside the OFAC SDN List, BIS Entity List, BIS Denied Persons List, and other government watchlists.
How is the AECA Debarred List different from the BIS Denied Persons List?
Both lists identify parties prohibited from participating in U.S. export transactions, but they cover different regulatory regimes and arise from different legal authorities. The AECA Debarred List (State/DDTC) covers ITAR-regulated defense articles and results from criminal convictions under the Arms Export Control Act. The BIS Denied Persons List (Commerce/BIS) covers EAR-controlled items and can result from either criminal convictions or administrative proceedings.
Does AECA debarment affect domestic contracts?
AECA debarment specifically prohibits participation in the export or import of defense articles and services under ITAR. It does not automatically affect purely domestic contracts that do not involve ITAR-regulated transactions. However, many U.S. government defense contracts include ITAR obligations, and a contractor that is AECA-debarred cannot fulfill those ITAR-related obligations — which can effectively bar them from defense contracting.
Can a company continue operating after AECA debarment?
A debarred company can continue operating in non-ITAR business lines. However, any activity involving the export, import, transfer, or manufacture of ITAR-controlled defense articles or services is prohibited. In practice, for companies whose core business is defense manufacturing or export, debarment is often commercially devastating.