Denied Persons List
A BIS list of individuals and entities whose U.S. export privileges have been revoked — all transactions with DPL parties involving EAR-controlled items are prohibited.
Definition
The Denied Persons List (DPL) is a list maintained by the U.S. Department of Commerce's Bureau of Industry and Security (BIS) identifying U.S. and foreign individuals and entities whose export privileges have been revoked or denied as a result of administrative or criminal proceedings under the Export Administration Regulations (EAR). Transactions involving EAR-controlled items with any person on the DPL are prohibited without specific written authorization from BIS.
How the DPL Differs from the BIS Entity List
The Denied Persons List and the BIS Entity List are both maintained by BIS, but they have different legal consequences. The Entity List identifies foreign parties subject to additional license requirements — where a license is possible but presumptively denied. The Denied Persons List is categorically stricter: these are parties who have already violated U.S. export laws, been found guilty in administrative or criminal proceedings, and had their export privileges revoked entirely.
Exporting, re-exporting, or transferring EAR-controlled items to a denied party — or allowing a denied party to participate in an export transaction in any capacity (as buyer, freight forwarder, intermediate consignee, or end user) — is prohibited without specific BIS authorization. There is no "license application" pathway for most DPL parties.
What Triggers a Denial Order?
Denial orders are issued by BIS following administrative enforcement proceedings or in connection with criminal convictions under the EAR. Common violations that lead to denial orders include exporting without a required license, exporting to prohibited end users or end uses, making false statements on export documentation, and failing to file required Electronic Export Information (EEI).
Each denial order is published in the Federal Register and specifies the scope of the denial (which items and activities are covered), the duration (some are temporary; others are indefinite), and whether the denied party can apply for reinstatement after a specified period.
Scope of the Prohibition
The prohibition on transacting with denied parties extends beyond direct exports from the United States. It covers re-exports of U.S.-origin items from third countries, in-country transfers, and — through the foreign direct product rule — certain foreign-made items that incorporate U.S. technology above a threshold. Non-U.S. exporters dealing in U.S.-origin content may also be subject to DPL restrictions.
The prohibition also applies to indirect involvement. If a denied party is acting as a freight forwarder, distributor, or intermediary in a transaction — even if they are not the end user — the transaction may still violate the denial order.
How TradeLasso Helps
The Denied Persons List is included in every TradeLasso screening search through the U.S. Consolidated Screening List, alongside the BIS Entity List, OFAC SDN List, and 10 other government watchlists.
Frequently Asked Questions
Are there other "denied party" lists besides the BIS Denied Persons List?
The term "denied party" is often used colloquially to refer to parties on multiple government lists — not just the BIS DPL. In practice, "denied party screening" typically means a comprehensive check that includes the BIS Denied Persons List, the BIS Entity List, the OFAC SDN List, the State Department AECA Debarred List, and other government watchlists. The U.S. Consolidated Screening List consolidates all of these into a single database.
Can a denied party be reinstated?
Yes, in some cases. Denial orders often include provisions for the denied party to apply for reinstatement after a specified period, typically upon demonstrating compliance with U.S. export laws and remediation of the violations that led to the denial. Reinstatement is not automatic — it requires a formal application to BIS and is granted at BIS's discretion.
Does the Denied Persons List apply only to exports from the United States?
No. The DPL applies to exports, re-exports, and in-country transfers of items subject to the EAR. This includes foreign-made items that incorporate U.S.-origin content above the de minimis threshold and foreign-produced items that are the direct product of U.S. technology under the foreign direct product rule. Non-U.S. exporters dealing in U.S.-origin content may be subject to DPL restrictions.
How do I know if a denied party's denial order has expired?
Each entry on the Denied Persons List includes the expiration date of the denial order, if applicable. However, BIS can and does renew denial orders. The only reliable way to know if a denial order is still active is to check the current published DPL — not a cached or downloaded version. Always verify against the live list before making a compliance determination.