Reading Sanctions Lists — SDN, BIS Entity List, What's Actually Enforced
How to read OFAC's Specially Designated Nationals list, the BIS Entity List, and the difference between listing and enforcement
On May 16, 2019, the U.S. Department of Commerce's Bureau of Industry and Security added Huawei Technologies and 68 of its non-U.
S. affiliates to the Entity List, a U.S.
export-control measure that requires a specific license — generally denied — for the export, re-export, or in-country transfer of essentially all U.S.-origin goods, software, and technology to the listed entities.
The action was distinct from a sanctions designation in important ways. Huawei was not added to OFAC's SDN list at the time; U.S.
persons were not generally prohibited from transacting with Huawei in the way they would be with an SDN-listed party. What the Entity List addition did instead was to require a license for any transfer of U.S.
-origin items to Huawei — and to set the licensing policy at presumption-of-denial. The operational consequence over the following years was a multi-stage tightening of restrictions: in May 2020, BIS expanded the rule to cover non-U.S.
-produced semiconductor chips that had been designed or produced using U.S. technology, vastly extending the reach; in August 2020, additional restrictions were imposed; in subsequent years, a broader U.
S. semiconductor export-control architecture (October 2022 controls on advanced chips and chip-making equipment to China) built on the Entity List foundation.
That is the opening. Finishing a lesson is where it stops being interesting and starts being useful: the full lesson runs to 7 sections and ends with 6 practice questions. A free account is what opens the rest, and the other 255 lessons in the Academy with it. No card.
What this lesson covers
- 1Blocking versus denial versus restriction — three different mechanisms
- 2Reading an SDN entry — what the data actually tells you
- 3The four major U.S. restricted-party lists at a glance — what each prohibits
- 4The major U.S. restricted-party lists — what each does
- 5The Huawei Entity List addition, May 16, 2019 — what an Entity List action actually does
- 6Where to see this on the platform
- 7Summary