Project 2025 Tracker / What’s done, what’s next

21. Department of Commerce · Notable

Put export-control violators on the Denied Persons List and sanction them

Not started

674 21. Department of Commerce

“Entity List parties that violate export controls should be placed on the BIS Denied Persons List (and thereby lose export privileges) and, if the violations are significant enough, they should also be sanctioned by the Department of Treasury.”

What has happened

  1. Not started

    Nothing found. BIS issued dozens of denial orders in the window, but every one of them denies export privileges to an individual or firm convicted of an export or smuggling offence under 15 CFR 766.25 or subject to a temporary denial order — the long-standing practice. None places an Entity List party on the Denied Persons List for violating export controls, and no Treasury sanction was imposed on such a party in tandem.

    No action found yet. This entry is the starting point, not a finding.

Research log

What was searched, and what didn’t count as evidence

Research notes

Cluster negative search BIS-1 (chapter log): a jq pass over all 154 in-window Federal Register records whose agency is the Industry and Security Bureau — every Entity List, Unverified List, Denied Persons, Section 232 and licensing document of the window — plus quoted-phrase Federal Register full-text searches since 2025-01-20, plus the Bureau’s whole active Unified Agenda on reginfo.gov (agencyCd 0600, DOC/BIS: seventeen RINs, each opened and read). The Denied Persons material in the window was read in full: roughly forty orders denying export privileges (2025-05-22, 2025-08-28, 2025-11-26, 2025-12-17 batches), eight temporary denial orders and renewals against Russian airlines, and one contested administrative case decided on the merits (Hans De Geetere, Final Decision and Order, 2026-05-29). All are the ordinary criminal- and TDO-based route into the Denied Persons List, which predates the window.

"Denied Persons List" as a phrase returns three in-window documents, one of them a DFARS rule. Cross-checked against Treasury: home.treasury.gov/news-data/press-releases/search/2025.json and 2026.json (the machine-readable index named in source-apis.md) carry no designation tied to an Entity List export-control violation.

Under §3b a continuing pre-window practice is not progress on this ask, whose content is the link between Entity List violation, Denied Persons listing and Treasury sanction.

Reginfo agenda sweep, 2026-09-01 (§3b). The seventeen active RINs of the DOC/BIS slice of the 2026 Unified Agenda (agencyCd=0600, pubId=202510, published in the Federal Register 2026-08-14) were re-read against the rule settled 2026-09-01 — a dated agenda entry naming the ask’s object is attempted. No entry names the Denied Persons List or 15 CFR parts 764 or 766. Two name the Entity List — RIN 0694-AK42 Revisions to the Entity List (Final Rule Stage, final action 07/2026) and RIN 0694-AK11 Expansion of End-User Controls To Cover Affiliates of Certain Listed Entities (Final Rule Stage) — but both add to or extend the reach of the Entity List rather than moving Entity List violators onto the Denied Persons List, which is what this Quote asks. Subject area only — Status unchanged.

Action
restrict
Object
BIS Denied Persons List
ID
1864