This Guidance does not create any privileges, benefits, or rights, substantive or procedural, enforceable by any individual, organization, party, or witness in any administrative, civil, or criminal matter.



Yes, if you can ensure that the entity acting as your agent does not have access to the item(s) prohibited by the Entity List’s licensing requirements and policies.  Note that BIS recommends that, as a "red flag" is associated with such transactions, you exercise caution and strong oversight if you opt to engage a sales agent that is, or is owned by, a listed entity. Note that the licensing requirements specified on the Entity List will apply if the sales agent has access to the restricted item being exported, reexported or transferred (in-country), including items that the sales agent would, in the normal course of business, use for product demonstrations. Further, you should check other lists maintained by the U.S. Government as sanctions or other restrictions may apply to transactions with the particular listed entity.

© BIS 2020