Unverified List

The Unverified List (UVL) is Supplement No 6 to Part 744 of the United States Export Administration Regulations. It identifies foreign parties whose bona fides the Bureau of Industry and Security has been unable to verify through an end-use check for reasons outside United States government control. UVL listing is not an Entity List designation and does not by itself impose the Entity List's licence requirement.

Operation

Section 744.15 removes licence-exception eligibility for exports, reexports and transfers involving a UVL party. For a transaction not otherwise requiring a licence, the exporter must obtain a UVL statement containing specified certifications and information. Export Electronic Information filing is required for covered exports, regardless of value or destination-based filing exemptions.

BIS can add a party when a pre-licence check or post-shipment verification cannot be completed satisfactorily. A listed party may seek removal, with the ability to complete an end-use check central to the process. Current membership, names and addresses must be taken from the eCFR list, not a historical count.

In October 2022, BIS added parties in China and stated that sustained host-government interference preventing end-use checks could lead to Entity List addition. In December 2022 it moved specified parties from the UVL to the Entity List after completing or remaining unable to complete checks. Those actions show an escalation pathway, not an automatic statutory sixty-day conversion for every UVL party.

Statecraft assessment

The UVL turns verification access into a regulatory pressure point. Its direct legal effects are narrower than an Entity List entry, but suppliers may refuse business because of documentation, diligence and escalation risk. That private de-risking should be separated from the rule.

Effectiveness depends on the party's need for items subject to the EAR, host-government cooperation, verification results and alternative suppliers. Removal after a successful check can also make the list a compliance incentive rather than only a denial instrument.

See also

Export Administration Regulations (EAR) · Entity List (15 CFR Part 744) · Denied Persons List · End-use and end-user controls · Over-compliance (de-risking)

Sources

1. Electronic Code of Federal Regulations, 15 CFR 744.15, checked 29 July 2026.
2. Electronic Code of Federal Regulations, Supplement No 6 to Part 744, Unverified List, checked 29 July 2026.
3. Bureau of Industry and Security, October 2022 UVL revisions and end-use-check policy, 87 Fed. Reg. 62186.
4. Bureau of Industry and Security, December 2022 Entity List additions and UVL removals, 87 Fed. Reg. 77505.