BIS Military End User List Search and Rule Review

The MEU List and section 744.21 answer different questions

Supplement no. 7 names certain parties BIS has determined are military end users. For a listed Burmese, Cambodian, Chinese, Nicaraguan, or Venezuelan entity acting as a purchaser, intermediate consignee, ultimate consignee, or end user, section 744.21 imposes a licence requirement on the items listed in supplement no. 2.

The underlying rule is broader than the names in supplement no. 7. Paragraph 744.21(a) can apply when the exporter, reexporter, or transferor has regulatory “knowledge” that a covered item is intended, entirely or in part, for a defined military end use or military end user. A list match resolves neither that knowledge inquiry nor the transaction's complete legal treatment.

Two country and item scopes—not one seven-country rule

• Burma, Cambodia, China, Nicaragua, and Venezuela. Section 744.21(a)(1) covers items identified in supplement no. 2 for a covered military end use in those destinations or for their military end users, including certain listed parties outside those destinations.
• Belarus and Russia. Paragraph (a)(2) reaches any item subject to the EAR for a military end use in Belarus or Russia or for a Belarusian or Russian military end user. Named parties outside those countries are handled through Entity List footnote 3 rather than the MEU List pathway described above.

“Seven covered countries” is therefore only a shorthand. A defensible decision records which paragraph applies, the item's EAR status and classification, the relevant destination and party nationality, and every separate licence requirement.

Military end use and military end user are separate routes

Paragraph 744.21(f) defines military end use through incorporation into specified military items or support for their operation, installation, maintenance, repair, overhaul, refurbishing, development, or production. Paragraph (g) separately covers armed services, national guard and police, certain government intelligence or reconnaissance organizations, and persons whose actions or functions are intended to support those military end uses.

The test is factual and transaction-specific. A customer's state ownership, defence-sector marketing, facilities, contracts, products, and relationships may be evidence requiring further inquiry, but the regulatory definition is not simply an ownership percentage test.

The 2025 Affiliates Rule is presently stayed

BIS published amendments in September 2025 that would extend certain Entity List, MEU List, and section 744.8 requirements to qualifying foreign affiliates based on aggregated ownership. BIS then stayed those amendments for one year. As of this page's 16 August 2026 review date, the stay runs through 9 November 2026 unless BIS changes it.

This is a date-sensitive boundary. Do not apply the suspended automatic rule as current law, but do not ignore ownership evidence or separate end-use, end-user, Entity List, OFAC, or other restrictions. Recheck the current EAR and Federal Register before relying on this page after its review date.

A defensible MEU review

1. Resolve identity and roles. Compare names, aliases, addresses, countries, and identifiers, then map every section 748.5 party.
2. Check official named lists. Review supplement no. 7, the Entity List including footnote 3, and other applicable US and non-US lists.
3. Classify the item and destination path. Determine whether the item is subject to the EAR, whether supplement no. 2 applies, and which paragraph of section 744.21 governs.
4. Test both definitions. Assess the proposed end use and the specific end user's actions and functions against paragraphs (f) and (g).
5. Resolve knowledge and red flags. Investigate inconsistent orders, opaque intermediaries, unexplained technical requirements, military-adjacent facilities, and other abnormal facts rather than stopping at a clean name result.
6. Confirm authorization and preserve evidence. Apply current licence, exception, and review-policy text; save the submitted identity, sources, classification, reasoning, reviewer, and escalation.

What Embargo can and cannot establish

Embargo can compare a submitted name with supported registry evidence, show published MEU List-associated entries, link available source evidence, and preserve a screening record. It can help a reviewer find named evidence faster.

Embargo does not determine an item's EAR status or ECCN, infer a military end use or end user from a name, establish regulatory knowledge, resolve the currently stayed Affiliates Rule, or provide a licence decision. Those conclusions require current official sources, transaction facts, and qualified trade-compliance review.

Official BIS sources

• EAR section 744.21: current prohibition, definitions, and country scopes
• Supplement no. 7: current Military End-User List
• Supplement no. 2 to part 744: covered items
• BIS Know Your Customer and red-flags guidance
• Federal Register: one-year stay of the 2025 Affiliates Rule

Frequently asked questions