The Entity List
The BIS Entity List names 3,435 organizations across 85 countries. Exporting controlled items to any of them requires a licence.
Active
3,420 designations remain active; the 15 removed or expired are the faint marks at the far corner.
Reaching tracked compute
Screened against tracked compute (facilities, chip classifications, supply-chain relationships; four matching layers and an affiliate-closure cascade), 166 designations reach it: 4.9% of the active list, through 176 matches, of which 173 pair the designation with a tracked organization that has supply-chain relationships on record — 1,544 relationships in all.
Confirmed
108 identify at high confidence: a name match at 0.85 or above, or a fully documented ownership chain. These rows are citable as matches.
Screening lead
58 are screening leads between 0.60 and 0.85; verify against the underlying designation before citing.
Under review
0 sit below the screening bar, where a chain has a stale, conflicting or joint-venture hop; they stay in the register, marked.
Plate I. One mark per Entity List designation, every mark the same size, so areas are proportional to counts. The compute-matched cluster sits at the lower-left corner and the removed handful at the upper-right; inside the cluster, shade is the strongest standing a designation’s matches hold.
3,254 active designations show no match into the compute dataset; the 166 that do are reached through 176 distinct matches, because one designation’s cascade can reach several tracked organizations. A designation can only match compute infrastructure this dataset already holds, so the unmatched remainder measures the dataset’s coverage rather than the designated entities’ distance from compute: a non-match records an absence of evidence at the screening bar, and does not establish that the designated entity touches no compute.
75 further countries appear in the designation corpus with no match into Scrutica’s compute dataset.
| Country | Standing | |||
|---|---|---|---|---|
| Northwestern Polytechnical University | CN | 100% exact match | Confirmed | 1 |
| CloudWalk Technology → CloudWalk Technology A | CN | 100% token overlap | Confirmed | 5 |
| Suzhou Huawei Investment Co., Ltd. → Huawei Investment & Holding Co., Ltd | CN | 100% token overlap | Confirmed | 6 |
| SMIC Holdings Limited → SMIC | CN | 100% token overlap | Confirmed | 130 |
| Piotech | CN | 100% exact match | Confirmed | 3 |
| Piotech (Beijing) Co., Ltd. → Piotech | CN | 100% token overlap | Confirmed | 3 |
| Beijing Sensetime Technology Development Co., Ltd. → SenseTime Group B | CN | 100% token overlap | Confirmed | 1 |
| Skolkovo Institute of Science and Technology → Skolkovo Institute Of Science And Technology | RU | 100% exact match | Confirmed | 1 |
| Semiconductor Manufacturing International (Tianjin) Corporation → SMIC | CN | 100% override | Confirmed | 130 |
| Nanjing Guosheng Electronics → GuoSheng | CN | 100% token overlap | Confirmed | 1 |
| 4Paradigm Technology Co., Ltd → 4paradigm | CN | 100% token overlap | Confirmed | 1 |
| Beijing Biren Technology Development Co., Ltd. → Biren Technology | CN | 100% token overlap | Confirmed | 5 |
| Peng Cheng Laboratory | CN | 100% exact match | Confirmed | 1 |
| Beijing E-Town Semiconductor Technology Co., Ltd. → Beijing E-Town Semiconductor A | CN | 100% token overlap | Confirmed | 1 |
| Beijing Lingxin Intelligent Technology Co., Ltd. → Beijing Lingxin Intelligent Technology Co | CN | 100% token overlap | Confirmed | 1 |
| Hangzhou Huawei Digital Technology Co., Ltd. → Huawei Technologies | CN | 100% token overlap | Confirmed | 42 · 5 facilities |
| Dahua Technology | CN | 100% exact match | Confirmed | 1 |
| Yangtze Memory Technologies Co., Ltd. | CN | 100% exact match | Confirmed | 2 |
| HiSilicon Technologies Co., Ltd (HiSilicon) → HiSilicon | CN | 100% token overlap | Confirmed | 6 |
| QuantumCTek Co., Ltd. → Quantumctek A | CN | 100% token overlap | Confirmed | 6 |
The newest 5 of 176 match events in the window; a match event is a designation newly joined to, or dropped from, a tracked organization. The Entity List’s own additions and removals are on the change log.
On 13 May 2025 BIS announced that it would not enforce the Biden-era AI Diffusion Rule (the three-tier country framework, effective 13 January 2025 with compliance due from 15 May) and would rescind it by regulation; no replacement rule has been recorded. The October 2022 and October 2023 advanced-computing rules remain in force. The January 2026 rule opened case-by-case review for qualifying exports from the United States to China and Macau, bounded by TPP and DRAM-bandwidth ceilings that the H200 and MI325X fall under; chips above them, the Blackwell class included, stay under a presumption of denial. The UAE moved from Country Groups D:3 and D:4 to A:5 on 10 July 2026, with licence relief for advanced-computing items where the ultimate consignee and every end user hold supplement no. 8 approval, and Part 744 controls intact.
In May 2025 the Commerce Department announced that it would not enforce the 2025 AI Diffusion Rule, the three-tier country framework, and would formally rescind it; no replacement has been issued. The October 2022 and October 2023 restrictions remain in force: the most capable AI chips need a licence to go to China, and for chips above the ceilings set in January 2026, the Blackwell generation included, licences are expected to be refused, a presumption of denial rather than a prohibition. Chips under those ceilings, the H200 and MI325X among them, have been reviewed case by case since January 2026. The United Arab Emirates moved in July 2026 to the country group covering close allies, with licence relief for a named list of approved recipients where every end user is approved.
The subsidiary-extension rule (50% ownership threshold, dated 29 September 2025 in the rule and published 30 September 2025 as FR doc 2025-19001, suspended for one year effective 10 November 2025 and published 12 November 2025, FR doc 2025-19846) is structurally vulnerable to rebranding when a designated parent holds slightly less than half of a US-incorporated subsidiary. The worked example is Aivres Systems — "Inspur Systems" until May 2023, two months after parent Inspur Group was designated — which a licensed corporate-ownership entity tree (2026-05-14) still surfaces under its pre-rebrand name as a direct subsidiary of IEIT Systems Co., Ltd.
IEIT Systems (000977-CN), the parent, discloses 33.26% "Private Company" insider ownership on its A-share listing, while the sister listing (Inspur International, 596-HK) records 50.88% "Government" insider ownership for the same group. The Culper Research short thesis (2026-05-13, Tier 3 analyst publication) surfaced the pattern and reads that asymmetry as leaving Aivres outside the 50% threshold and outside the restrictions Nvidia applies to Chinese buyers; the ownership and listing records beneath it are independently documented in a licensed corporate database (Tier 2).
Four-layer matching (exact, alias, token Jaccard, fuzzy trigram) with generic-token blacklisting of corporate suffixes, geographic singles, and industry-generic words, plus country filtering. This layer emits no match below 0.7.
Every row in the register, from this layer or the cascade beside it, takes one of three standings by its score. Confirmed, 0.85 and above: the name match is treated as settled and the designation behind it is the primary record. Screening lead, 0.60 to 0.84: this layer’s matches between 0.70 and 0.84 and the cascade’s medium-confidence chains, which it scores at 0.70; verify against the underlying designation before citing. Under review, below 0.60: the cascade’s low-confidence chains, scored 0.55 where a hop is stale, conflicting or a joint venture; they are retained and marked, because a weak link is still evidence of reach and dropping the row would record none. The Ownership Investigator applies a stricter bar of 0.90 before it will assert that an entity is itself directly designated. 74 active matches come from this layer.
For each designated entity, the downward affiliate-graph closure is computed from a licensed corporate-ownership database’s 6.5M-row corporate-structure relation table — children, subsidiaries, joint ventures, affiliates, up to four hops. Tracked entities reachable through that closure are flagged as covered by the designation’s enforcement reach via 15 CFR Part 744. 102 active matches, reaching 10 organizations from 101 designations.
Cascade confidence: high, every hop a documented parent or subsidiary relation (58); medium, the chain includes a JV or affiliate edge or a one-hop ownership-chain extension (44); low, stale or conflicting records, marked under review (0).
One chain, hop by hop: Future Systems Pvt. Ltd. to Systems (Pakistan) (2 hops, medium confidence, graph refresh 2026-04-24). Each hop names the entity it starts from, then the relation it follows and where that relation came from, then the entity it reaches:
Every cascade row’s chain is included in the register export in this form: relation, origin, and standing per hop, with licensed-graph intermediaries withheld by name.
