Screen the entire transaction—not just the supplier’s name. A sound first-pass review identifies the hardware and its export classification, checks every relevant party against current U.S. government lists, traces ownership and headquarters, verifies the ultimate user and use, and investigates delivery and diversion risks before deciding whether authorization is required. A clean name search is only one part of that review.
The U.S. rules discussed here include sanctions administered by the Treasury Department’s Office of Foreign Assets Control (OFAC) and export controls under the Export Administration Regulations (EAR), administered by the Bureau of Industry and Security (BIS). Other countries’ rules may also apply depending on the parties, product, and transaction. This workflow can help identify issues; it cannot determine whether a particular transaction is lawful without its facts and applicable rules.
What should a company screen?
Screen the transaction as a network of parties, goods, locations, and intended activities. The supplier matters, but so do the purchaser, any license applicant, intermediate and ultimate consignees, end user, intermediaries, and—in a resale or infrastructure-as-a-service (IaaS) arrangement—the customer or remote user that will ultimately access the computing capacity.
BIS explains that restrictions can apply when a listed party is a party to the transaction, not only when that party is the end user. It also notes that end-use controls may require a license even when the item’s classification or destination alone would not. A “no hit” against a company name therefore does not establish that the item, route, end use, or transaction is unrestricted.
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How to screen an AI hardware transaction
Use the following as a documented first-pass workflow. If key facts are missing or inconsistent, pause and escalate rather than treating the gap as a pass.
1. Define the item and transaction
Record what is being acquired, supplied, exported, reexported, or transferred. Identify the specific hardware and any related software or technology, the origin and destination, and the proposed transaction structure. Ask the supplier or exporter for the item’s export classification—an Export Control Classification Number (ECCN), if applicable—or its EAR99 status, along with supporting product details.
Determine whether the item is subject to the EAR and establish its classification before analyzing licensing requirements. “AI hardware” is not an export classification. For example, BIS’s May 2025 industry guidance identifies certain items classified under ECCNs 3A090.a and 4A090.a, and certain “.z” items in Categories 3, 4, and 5, including some servers, as examples relevant to advanced-computing controls. Those examples do not classify a particular product; confirm the actual item and current rules.
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2. Identify every relevant party and role
Collect each party’s full legal name, aliases, address, registration details, and role. Include the supplier, purchaser, applicant, intermediate and ultimate consignees, end user, freight forwarders, other intermediaries, and known remote users where relevant. If a customer will resell the equipment, operate it for another party, or provide IaaS, ask who that next customer or user is and what access they will have.
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Use the U.S. government’s Consolidated Screening List (CSL) for consolidated screening, then consult the underlying agency list and applicable rule to understand what a potential match means. The CSL brings together lists from Commerce, State, and Treasury. BIS identifies the Entity List, Denied Persons List, Unverified List, and Military End-User List among its restricted-party lists. They do not all have identical consequences, and the Military End-User List is not exhaustive.
Also check OFAC’s sanctions lists, including the Specially Designated Nationals (SDN) List and other lists that may impose non-blocking restrictions. Do not treat every entry as the same kind of prohibition: establish which list and sanctions program apply, then analyze the specific restriction.
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A possible match is a lead for review, not a decision based on name similarity alone. Compare available identifiers such as address, country, registration information, aliases, and other distinguishing details under your organization’s procedures. Record the list searched, search date, names and aliases queried, identifiers compared, potential matches, disposition and rationale, reviewer, and any escalation. Refresh checks when a relevant party, ownership, destination, end use, or transaction changes, and at appropriate transaction milestones under risk-based procedures; lists and restrictions can change.
4. Trace ownership and headquarters
Obtain a current ownership chart or equivalent evidence showing direct and indirect owners and the ultimate parent. Establish the headquarters of the supplier, ultimate parent, end user, and relevant counterparties; do not assume that the shipping address or place of incorporation answers the headquarters question.
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Under OFAC’s 50 Percent Rule, an entity is treated as blocked if one or more blocked persons own, directly or indirectly, at least 50 percent of it in aggregate, even if the entity is not separately named on an OFAC list. A control relationship below that ownership threshold is not automatically the same thing as meeting the rule; assess it under the applicable sanctions program and obtain advice where needed.
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For covered advanced-computing items, BIS guidance dated May 31, 2026 states that a license requirement continues for exports to entities headquartered in Country Group D:5 or Macau, or whose ultimate parent is headquartered there, even if the recipient is located elsewhere. BIS says exporters should continue seeking required licenses unless a specified license exception is available. Confirm the current EAR, destination group, item scope, and transaction facts before applying this guidance. BIS distinguished this continuing requirement from portions of the AI Diffusion Rule whose new compliance requirements it said it would not enforce.
5. Verify the end user, end use, and physical path
Ask what the customer will do with the hardware: use it itself, hold it in stock, resell it, install it at a named site, or provide computing services to others. Identify the intended applications, quantities, users, and access arrangements. Compare the answers with the customer’s line of business and the capabilities it is purchasing. BIS’s May 2025 guidance recommends evaluating whether the customer’s business is consistent with the ordered items and obtaining detailed information about transaction parties and intended end use.
Establish where the equipment will be delivered, installed, and operated, and map any intermediaries and onward shipment. For servers containing advanced computing integrated circuits (ICs), assess whether the named data center has the power, cooling, and space to operate the equipment. BIS recommends written data-center attestation and identifies inability to affirm capacity as a red flag. Its May 2025 guidance says sites with capacity to operate more than 10 megawatts of servers containing advanced ICs merit additional scrutiny because they may provide access to large quantities of such ICs. This is a screening recommendation in that guidance, not a universal legal threshold.
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6. Investigate red flags and document how they are resolved
Examples that warrant further inquiry include:
- An unknown ultimate owner, user, or remote customer, or incomplete and inconsistent ownership information.
- A newly formed or opaque customer whose business does not explain the type or quantity of hardware ordered.
- Unusual routes, virtual or shared addresses, or intermediaries whose role does not fit the transaction.
- A delivery or installation site with weak evidence of adequate capacity, or co-location with a restricted party.
- Uncertain prior license history, or overlap between a new customer’s leadership and an Entity List party.
BIS identifies these and similar circumstances as diversion indicators. An indicator is a reason to investigate, not automatic proof of a violation. In the circumstances described in BIS guidance, uncertainty about the ultimate owner or user, or about license history, must be resolved before proceeding. Keep the evidence that resolved each flag and record who approved the disposition. If material facts remain uncertain, pause and seek qualified export-control or sanctions counsel or guidance from the competent authority.
7. Make the authorization decision and retain the file
Assess the item’s EAR status and classification together with destination, transaction parties, ownership, end use, and applicable restrictions to determine whether a license or other authorization is required. A classification or destination that does not by itself trigger a license does not rule out an end-user or end-use control. Whether a specific transaction needs authorization is fact-dependent.
Keep the classification basis, list-check records, ownership evidence, end-user and end-use certifications, delivery and site evidence, licensing analysis, escalations, approvals, and rescreening history together. For relevant advanced-computing transactions, BIS recommends an end-user certification with detailed information about proposed transaction parties and intended end use, and written data-center attestation where applicable.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How to interpret screening results
| Screening source or issue | What it tells you | What to do next |
|---|---|---|
| Consolidated Screening List | Consolidates U.S. government lists from Commerce, State, and Treasury. | Resolve potential matches against identifying details and consult the underlying list and applicable rule. |
| BIS restricted-party lists | Include the Entity List, Denied Persons List, Unverified List, and Military End-User List; restrictions differ by list and rule. | Determine the specific consequence for the item, transaction, and parties. Absence from the Military End-User List is not proof that no concern exists. |
| OFAC sanctions lists | Include the SDN List and other lists with restrictions that are not all identical. | Identify the relevant program and restriction; separately analyze ownership under the 50 Percent Rule. |
| No apparent name match | Shows only that the names searched did not produce an identified match under that check. | Continue the item, ownership, end-user, end-use, destination, and authorization review. |
When should a company use screening software?
Commercial sanctions-screening software may help teams handle repeated checks and maintain records, especially as transaction volume or operational complexity grows. OFAC describes commercial software as an option to consider in light of a business’s scale, sophistication, and risk profile; it also says there is no single compliance solution suitable for every circumstance. Software can support name screening and workflow, but it cannot independently establish a product classification, determine the legal effect of a potential match, validate an end use, or make the authorization decision.
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Escalate a potential true list match, blocked-ownership issue, unclear application of a sanctions program, uncertain EAR classification or license requirement, D:5 or Macau headquarters question involving covered advanced-computing items, or unresolved diversion indicator. Also seek qualified review when the parties cannot substantiate the end user, end use, ownership, or physical destination. The U.S. sources described here do not resolve obligations under other jurisdictions’ laws, which may apply to the same transaction.
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