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Export Controls Practice ›

BIS Restricted Party List Removal

Meshkat Law represents companies and individuals seeking removal from the U.S. Department of Commerce, Bureau of Industry and Security’s (BIS) restricted party lists—particularly the Entity List and Unverified List (UVL)—and advises on export compliance obligations arising from such listings. The firm leads the administrative reconsideration process, from initial assessment and petition strategy to advocacy before BIS and, where relevant, related litigation challenging BIS actions or unreasonable delays in federal court.

Understanding BIS Restricted Party Listings and Removal from the Entity List and UVL

BIS restricted party listings can disrupt access to U.S.-origin items and cause counterparties to pause or terminate business relationships. Within this framework, the Entity List typically imposes broad license requirements—often under stringent review policies—while the Unverified List (UVL) adds verification and documentation burdens that many suppliers and financial institutions treat as significant risk.

Although the procedures differ by list, BIS provides administrative avenues to seek removal or modification. Entity List parties may petition under the EAR’s reconsideration procedures, while UVL parties generally focus on demonstrating their “bona fides” and enabling satisfactory end-use checks to support delisting.

Meshkat Law helps listed parties understand the implications of their BIS restricted party status, assess available paths to removal, and identify practical remedial and compliance measures that can strengthen requests for relief.

Our BIS Restricted Party List Removal Services

Meshkat Law assists companies and individuals listed on BIS restricted party lists—particularly the Entity List and Unverified List (UVL)—at every stage of the administrative reconsideration process. The firm investigates and analyzes the basis for listing, identifies potential paths to removal or modification, and represents listed parties before BIS throughout that process.

For Entity List matters, Meshkat Law prepares and submits petitions for removal or modification pursuant to BIS’s Export Administration Regulations (EAR), including investigating the basis for the listing, drafting supporting narratives and evidentiary materials, and engaging with BIS and the End-User Review Committee (ERC) as they evaluate the request. For UVL matters, the firm helps listed parties investigate the reasons for their listing, gather information and documentation demonstrating their “bona fides,” and pursue end-use checks, evidentiary submissions, and other strategies aimed at securing removal from the list.

Where appropriate, Meshkat Law also represents clients in litigation challenging BIS actions or unreasonable delays in acting on removal requests, and coordinates with outside criminal defense counsel in matters involving parallel criminal investigations or prosecutions.

Attorney Kian Meshkat has successfully represented companies identified on BIS-administered restricted party lists in securing their removal.

Prior results do not guarantee a similar outcome.

Frequently Asked Questions

Can I petition the U.S. government to remove my business from the BIS Entity List?

Yes. The U.S. Department of Commerce’s Bureau of Industry and Security’s (BIS) Export Administration Regulations (EAR) have an administrative process in place for any entity listed on the Entity List to request removal or modification of its listing. To initiate the process, requests are submitted in writing to the End-User Review Committee (composed of representatives from various U.S. government agencies), which reviews them in accordance with certain regulatory procedures in arriving at its final decision. Check out our blog post for more information on How to Go About Removal from the BIS Entity List. 

What trade restrictions are imposed on persons identified on the U.S. Department of Commerce’s Bureau of Industry and Security’s (BIS) Unverified List?

For any exports, reexports, or transfers (in-country) of items subject to BIS’s Export Administration Regulations (EAR) involving persons on the Unverified List (UVL), the following restrictions and requirements apply in addition to any other licensing requirements under the EAR: 

  • Obtain a UVL statement from the listed person consistent with 15 C.F.R. § 744.15(b); 
  • No BIS License Exceptions may be used; and
  • Electronic Export Information (EEI) must be filed to the U.S. Census Bureau’s Automated Export Systems (AES), regardless of the underlying transactional value or destination of the export/reexport. 

Check out our related blog post for more information on the regulatory removal process from the UVL.

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CONTACT US

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