Entity List Additions Cool to Their Slowest Pace Since 2008

The lack of additions to the Entity List since October 2025 marks a sharp break from years of U.S. geoeconomic strategy. Because procurement networks continually shift to new intermediaries, a list that stops expanding tracks fewer of the relevant actors, eroding its value as a control. 

  1. The Bureau of Industry and Security’s (BIS) Entity List imposes highly restrictive export licensing requirements on foreign entities that pose a risk to U.S. national security or foreign policy interests. The Entity List is among the most powerful tools in U.S. export enforcement—all but one of the seven export enforcement actions in 2026 thus far stem from Entity List violations. From 2018 to 2024, BIS made additions every 35 days on average; since October 2025, it has made none. As of June 26, eight months have passed without an addition, the longest such period since 2008.  
  2. Entity List additions previously served as a key pillar of U.S. geoeconomic strategy. Previous administrations used the list to augment semiconductor technology controls on China, and to restrict the diversion of dual-use goods to Russia and Iran. Routine updates to the Entity List were used to catch evolving procurement networks and companies changing names to avoid restrictions. For example, Tenco Technology Company was added to the Entity List in 2019 for attempting to procure U.S.-origin electronics for Iranian weapons. BIS then modified the listing when Tenco changed its name in 2022 and again in 2024, when Tenco renamed itself to seemingly unrelated names. 
  3. An effort to enhance the efficacy of the Entity List led to retaliation from China. In September 2025, BIS expanded the scope of the list, extending restrictions to any entity owned 50 percent or more by one or more listed entities. The so-called “affiliates rule” added controls on an estimated 20,000 companies in China alone. However, after the Trump-Xi October Busan summit led to a détente in the trade war, Commerce paused export control actions affecting China and suspended the affiliates rule for one year.  

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Economic Security, Global Markets, Technology, Intelligence, and Trade and International Business
Kate Koren

Kate Koren

Deputy Director, Economics Program and Scholl Chair in International Business

Brad Spicher

Research Intern, Economics Program and Scholl Chair in International Business

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