Does the US Entity List apply to UK companies?

It applies to a UK firm when the goods, software or technology it supplies are subject to the US Export Administration Regulations (EAR). Then exporting, re-exporting or transferring them to a party on the Entity List needs a licence from the US Bureau of Industry and Security (BIS), wherever the firm is based. A UK firm supplying only UK-made items with no US content is outside it.

What the Entity List is. A list kept by BIS of foreign companies, organisations, people and addresses that it judges to be acting, or at significant risk of acting, against US national security or foreign policy interests (15 CFR 744.11 and supplement no. 4 to part 744). Each entry says which items need a licence (often every item subject to the EAR) and how BIS will treat an application (often a presumption of denial).

When US rules reach a UK firm. Items subject to the EAR include US-made items wherever they are in the world, and foreign-made items that contain controlled US content above the de minimis level: more than 25% of the item's value for most destinations, or more than 10% for the countries in Country Group E:1 and E:2 (15 CFR 734.4). For some Entity List entries, foreign-made items produced with certain US technology are caught as well (the foreign direct product rules). A re-export from the UK, or a transfer within another country, counts as much as an export from the United States.

UK entries. On 10 October 2026 the Entity List had 3,419 entries in the official Consolidated Screening List; 46 have at least one UK address, 33 of them UK addresses only. BIS last changed the list on 21 August 2026.

Ownership counts from 10 November 2026. Unless the US extends its suspension, companies owned 50% or more by Entity List parties are treated as listed even though they are not named. See the guide to the 50% rule.

What to check and keep. Screen every party to the deal (buyer, consignee, end user and any intermediary) against the Entity List and the other US export lists, look for the warning signs in BIS's Know Your Customer guidance (supplement no. 3 to part 732), and keep a dated record of what you checked. Records the EAR requires are kept for five years (15 CFR 762.6). UK sanctions screening is a separate duty and still applies.

Certaby's export screening is £1.49 a check: the Entity List and five more US export lists, and the UK, UN, EU and US OFAC sanctions lists, on a dated record; a UK company checked by its number includes everyone recorded in its ownership. It is a screening record, not a licensing decision: whether you need a licence depends on the goods, the destination and the end use. This guide explains the rules; it is not legal advice.

Source: 15 CFR 744.11 and supplement no. 4 to part 744 (the Entity List), eCFR

Last updated 10 October 2026.