Denied Persons List

The Denied Persons List, or DPL, is the Bureau of Industry and Security's current compilation of persons subject to orders denying export privileges. The current EAR structure published on 25 March 1996 expressly incorporated the list and denial-order controls; individual orders carry their own later dates. The orders now arise under parts 764 and 766 of the Export Administration Regulations (EAR). The list supports enforcement and denial within Economic statecraft, but it is not an asset-freezing sanctions list.

Legal operation

Part 764 sets out enforcement provisions and sanctions for EAR violations. Part 766 provides administrative procedures, including temporary denial orders and proceedings affecting export privileges. A denial order states the respondent, scope, effective period and prohibited participation. Some orders are temporary, renewed or time-limited; others follow administrative settlements or adjudication.

The Bureau of Industry and Security (US Commerce) publishes the DPL for compliance use. Current names and expiry dates must be checked against the operative order on publication day. Presence on an old list or case summary does not prove that an order remained active on 30 July 2026.

Distinctions

The Entity List (15 CFR Part 744) imposes licence requirements and review policies concerning listed end users. It is not the DPL. The Unverified List concerns end-use-check limitations and has different consequences. OFAC's SDN List can block property under sanctions authority. A denial order restricts EAR-related privileges and participation; it does not automatically freeze assets or establish criminal guilt.

The United States denial order and settlements with ZTE (2016-2018) illustrate how denial authority, settlement, suspension and later compliance conditions can change over time. Case summaries are useful history, but the governing order and current list control legal status.

The DPL can disrupt procurement and deter intermediaries, yet effectiveness requires evidence of enforcement and substitution. Listing proves an administrative order. It does not prove that every associated transaction violated law or that a target was strategically degraded.

Sources

• BIS Denied Persons List, accessed 30 July 2026.
• eCFR, EAR part 764, accessed 30 July 2026.
• eCFR, EAR part 766, accessed 30 July 2026.
• BIS export-enforcement case summaries, accessed 30 July 2026.
• Federal Register, simplified Export Administration Regulations, 25 March 1996.