Denied Persons List

The Denied Persons List (DPL) is BIS's compilation of parties subject to orders denying export privileges under the Export Administration Regulations. The EAR structure published on 25 March 1996 incorporated denial-order controls and references to the list. That publication date is not the creation date of every order. Current authority and procedures appear in Parts 764 and 766. A denial order concerns EAR privileges and participation; it does not itself impose an asset freeze.

Legal operation

Section 764.3(a)(2) permits an order restricting a named person's access to items subject to the EAR or participation in exports, reexports and transfers. Denial may be a sanction or a protective administrative measure. Part 766 governs proceedings, settlements and related orders. Under section 766.24, BIS may seek a temporary denial order to prevent an imminent violation. Such an order need not rest on a completed criminal conviction. Its scope, duration and any suspension or renewal must be read from the applicable order.

The BIS list inspected on 26 October 2026 states that it was last updated on 23 October and includes information about suspended portions of denial periods. It is a compliance aid, not a substitute for the governing order. A historical listing, expired period or case summary cannot establish a party's current restrictions. This entry makes no assertion that an individual listed in a past edition remains denied privileges.

Distinctions and example

The Entity List (15 CFR Part 744) sets item-specific licence requirements and review policies for listed entries. The Unverified List applies a different verification framework under section 744.15. These mechanisms should not be conflated with denial of export privileges. The legal effect of an order must also be separated from a conclusion about criminal guilt or strategic damage.

The ZTE order of 13 July 2018 illustrates how status changes. It terminated the April 2018 activated denial order after the required payment and escrow conditions were met, and directed removal from the DPL. It expressly left the superseding settlement and order unchanged, including probationary conditions and the possibility of activating a suspended denial for non-compliance. This historical order does not determine ZTE's present status or every other restriction affecting it.

Statecraft assessment

Denial authority can constrain access and deter participation in prohibited supply relationships. That is a mechanism implied by the restrictions, not a measured effect established by listing. Whether it disrupts procurement or changes behaviour depends on enforcement, available substitutes and the target's exposure. The source record must distinguish the administrative decision, its implementation and the resulting strategic outcome.

Sources

• Bureau of Industry and Security, Denied Persons List, page updated 23 October 2026, accessed 26 October 2026.
• Bureau of Industry and Security, EAR Part 764, especially sections 764.3 and 764.6, and Part 766, especially sections 766.18, 766.23, 766.24 and 766.25, accessed 26 October 2026.
• Bureau of Industry and Security, EAR Part 744, sections 744.15 and 744.16, accessed 26 October 2026.
• Bureau of Export Administration, Simplification of Export Administration Regulations, Federal Register 61 (25 March 1996): 12714, including denial-order controls.
• Bureau of Industry and Security, Order Terminating Denial Order Issued on April 15, 2018, Against Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd., issued 13 July 2018, Federal Register 83 (23 July 2018): 34825-34826.