Denied Persons List (BIS)
The Bureau of Industry and Security list of persons stripped of their export privileges by a denial order, which bars anyone from dealing with them in an item subject to US export rules.
The Denied Persons List (DPL) is kept by the Bureau of Industry and Security (BIS) at the Department of Commerce. It lists persons, US or foreign, hit by a denial order that strips them of their export privileges: the sanction sits in part 764 of the Export Administration Regulations (EAR), the procedure in part 766. The order is either final, often for five, seven or ten years after a settlement or a conviction, or temporary (TDO, temporary denial order), issued without a hearing for 180 days, renewable, when a violation is imminent. The one against Aeroflot dates from April 7, 2022 and has been renewed since, including in September 2025 for one year. The denial reaches beyond the listed party. General Prohibition Four bars anyone from doing for the denied person what it can no longer do, and the standard order covers any action that facilitates its acquisition of an item subject to the EAR. The Entity List, in part 744, works differently: it imposes a license requirement for certain items going to a foreign entity, often under a presumption of denial, yet the deal remains possible under license. The DPL cuts everything off, and there is no license to apply for. For a cargo underwriter or an export credit insurer, the difference shows up in the file. A buyer, forwarder or shipper on the DPL taints any shipment containing an item subject to the EAR, and a claim payment in its favor can be read as facilitation. Screening limited to the SDN (Specially Designated Nationals) list leaves that gap open: the DPL belongs to Commerce and appears on the Consolidated Screening List, not in the files of OFAC (Office of Foreign Assets Control).
Textbook case: a cargo underwriter covers, under an open cover, a French manufacturer selling forty CNC (computer numerical control) milling machines CIF (Cost, Insurance and Freight), fitted with US-origin controllers classified under the EAR (Export Administration Regulations), to a distributor based outside the EU. The insurance certificate is endorsed to the buyer. Three days after loading, BIS (Bureau of Industry and Security) issues a temporary denial order against that distributor. Six machines arrive water-damaged, at EUR 60,000 each: 6 x 60,000 = EUR 360,000. The certificate holder is the listed party. The insurer, which has a New York branch, holds the payment and opens the analysis: would paying the distributor facilitate its acquisition of items subject to the EAR? The EUR 360,000 stays on hold while the order stands, and the seller, still unpaid, discusses taking the goods back with its own counsel.
DPL, denial order, temporary denial order, TDO, denied party, denial of export privileges, BIS denied persons
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