Choose the right UVL source
Screen the submitted identity
Compare a company or person name with Embargo's supported registry, then verify any potential match against the current official UVL.
A similar name is not proof of identity. No result is not legal clearance or proof that no applicable restriction exists.
What the UVL tells you—and what it does not
EAR section 744.15 permits BIS to add a foreign person when BIS, or federal officials acting for it, cannot verify the person's bona fides because an end-use check cannot be completed satisfactorily for reasons outside the US Government's control. Examples include an inability to demonstrate the disposition of items, inability to locate or authenticate the subject, and host-government non-cooperation.
That unresolved verification is material, but it is not itself a finding of diversion or wrongdoing and does not create a blanket prohibition. Requirements elsewhere in the EAR still apply. The operational response is to identify the party accurately, apply the UVL-specific rules, and assess every other item, destination, end-use, end-user, and party restriction.
The two UVL consequences are different
- No License Exceptions. EAR section 740.2(a)(17) bars License Exceptions for an export, reexport, or transfer involving a UVL person as a party described in section 748.5.
- UVL statement for transactions not otherwise licence-required. Section 744.15(b) requires the exporter, reexporter, or transferor to obtain the prescribed statement before proceeding with a covered transaction subject to the EAR that is not subject to a licence requirement.
The statement does not restore a License Exception and does not override another licence requirement. It includes certifications about the item's end use, end user and destination; cooperation with US Government checks; non-use for prohibited activities; onward disposition; and the signer's authority. Section 744.15 supplies the controlling text.
The 60-day policy is conditional—not a listing-age countdown
BIS announced a two-step enforcement policy in October 2022 for cases where host-government inaction prevents timely end-use checks. The policy calls for initiating the UVL process after 60 days and, after an additional period of continued inaction, initiating the interagency process for possible Entity List addition.
Do not calculate an automatic escalation date from the public UVL listing date. Section 744.15 covers several reasons a check may fail, while the 60-day policy specifically addresses foreign-government prevention. BIS also states that Entity List additions remain subject to End-User Review Committee approval. A completed check can instead support removal from the UVL.
A defensible UVL review
- Resolve identity. Compare legal name, aliases, address, country, and other identifiers rather than accepting a name-only hit.
- Confirm the current official entry. Record the UVL entry, applicable address, source version, and retrieval time.
- Map every party role. Section 748.5 roles matter; review applicant, purchaser, intermediate consignee, ultimate consignee, and end user as applicable.
- Determine the EAR path. Establish whether the item is subject to the EAR and whether another rule imposes a licence requirement.
- Apply the correct UVL consequence. Do not use a License Exception. If the covered transaction is not otherwise licence-required, obtain and review the complete UVL statement before proceeding.
- Preserve the decision record. Save the submitted identity, match reasoning, official evidence, classification and end-use analysis, statement, reviewer rationale, and escalation.
What Embargo can and cannot establish
Embargo can compare a submitted name with supported registry evidence, show published UVL-associated entries, link source evidence, and preserve a screening record. It can help a reviewer locate the relevant evidence faster.
Embargo does not determine identity from a similar name alone, establish item jurisdiction or classification, determine whether a licence is required, validate a UVL statement, predict BIS action, or provide legal advice. Confirm current status and legal effect with BIS and qualified trade-compliance counsel where needed.
Official BIS sources
- BIS end-user guidance and current Unverified List download
- EAR section 744.15: UVL requirements, criteria, and removal procedure
- EAR section 740.2(a)(17): License Exception restriction
- BIS announcement of the conditional 60-day enforcement policy
Frequently asked questions
What is the BIS Unverified List?
The UVL identifies foreign persons whose bona fides BIS or officials acting for BIS could not verify because an end-use check could not be completed satisfactorily for reasons outside the US Government's control. Listing is not itself a finding of wrongdoing or a blanket prohibition.
Can a License Exception be used for a UVL transaction?
No. EAR section 740.2(a)(17) bars use of License Exceptions for an export, reexport, or transfer involving a UVL person as a party described in section 748.5. Other EAR requirements may separately require a licence.
When is a UVL statement required?
Under EAR section 744.15(b), the exporter, reexporter, or transferor must obtain a UVL statement before a transaction subject to the EAR that is not subject to a licence requirement and involves a listed person in a role described by section 748.5. The rule specifies the statement's required certifications.
Does a UVL party automatically move to the Entity List after 60 days?
No. BIS's 2022 enforcement policy uses 60-day periods when host-government inaction prevents an end-use check, but a UVL listing date is not a universal public countdown. Continued non-cooperation can lead BIS to initiate the interagency Entity List process; additions still require End-User Review Committee approval.
Does a clean name search clear the transaction?
No. A name search is one identity-screening step. Review aliases, addresses, countries, party roles, item jurisdiction and classification, end use, destination controls, other restricted-party lists, and the current official UVL before deciding.