Screening the US Entity List and UK sanctions in one API call

If you build software that ships goods out of the UK (an order system, an ERP module, a marketplace, a freight booking flow, a trade-finance check), your users need to know who they are dealing with before anything leaves the warehouse. Two sets of lists matter, and most screening tools only cover one of them: the sanctions lists a UK firm is bound by, and the US export-control lists that follow US-origin goods wherever they go.

Why a UK firm cares about US lists

The US Export Administration Regulations follow items made in the US, and items made elsewhere with enough US content (above the de minimis level, 25% for most destinations). A UK exporter re-exporting such an item to a party on the US Entity List needs a US licence, and for most Entity List parties the licence policy is a presumption of denial. The US Commerce Department recommends that exporters screen the parties to a transaction against the list.

On 12 October 2026, 46 entries on the Entity List had a UK address, and 109 across the six US export lists. None of them is on a UK, UN or EU sanctions list, so a sanctions-only screen passes every one.

Why a US list alone is not enough

For a UK firm the binding lists are the UK's own. Trade sanctions breaches (exporting restricted goods to a sanctioned country, directly or through a third country) are enforced by the Office of Trade Sanctions Implementation, with civil penalties that do not need intent. A US-only tool, or the US government's own search, leaves out the UK Sanctions List. So the useful screen for UK software is both, in one call, with each list named in the answer.

One call

Our Export Controls Screening API checks a name against six US export-control lists (the Entity List, Military End User List, Unverified List and Denied Persons List from BIS, and the State Department's ITAR Debarred and Nonproliferation Sanctions lists) and four sanctions lists (UK, UN, EU and US OFAC). Passing a country cuts false positives, and reference carries your own order or file number into the record:

const r = await fetch(
  'https://api.stratumapis.com/v1/export-screening/screen?' +
    new URLSearchParams({ name: 'Niki Panteli Kyriakou', country: 'GB', reference: 'order-4471' }),
  { headers: { 'X-Stratum-Key': process.env.STRATUM_KEY! } },
);
const result = await r.json();

The answer (trimmed):

{
  "reference": "order-4471",
  "result": "possible_match",
  "count": 1,
  "matches": [{
    "list": "us_el",
    "listLabel": "US Entity List (BIS)",
    "name": "Niki Panteli Kyriakou",
    "countryMatch": "match",
    "listedOn": "2011-08-15",
    "federalRegister": "76 FR 50407 (8/15/2011)",
    "licencePolicy": "Presumption of denial"
  }],
  "listsScreened": [ "...ten lists, each with the date its publisher last changed it and the date we checked it..." ],
  "listsNotScreened": []
}

Two fields do the work for an audit trail. listsScreened names every list with both dates, and listsNotScreened names any list that could not be checked that day, so a stale list is never reported as a clear result. Up to 100 names go in one request to POST /bulk.

The 50% rule, and a UK customer's owners

The US Affiliates Rule (90 FR 47201) extends Entity List and Military End User restrictions to any company owned 50% or more by listed parties, whether or not it is named. It was suspended for a year in November 2025 (90 FR 50857); the suspension ends on 9 November 2026 unless the US extends it. A name screen cannot see this: the company itself is not on any list.

For a UK company, much of the ownership is public at Companies House. One call reads it, follows UK holding companies upwards, screens every recorded owner against the ten lists and says whether a listed party is recorded as owning 50% or more:

const own = await fetch(
  'https://api.stratumapis.com/v1/export-screening/ownership/08991238',
  { headers: { 'X-Stratum-Key': process.env.STRATUM_KEY! } },
).then((r) => r.json());

own.ownership.level;   // 'listed_party_in_ownership'
own.ownership.message; // who, on which list, recorded with what holding

Companies House records share bands rather than exact percentages, and it stops at a foreign holding company. The answer says both, rather than guessing.

Watching a customer list

Lists change in batches: BIS adds dozens of entities in one Federal Register notice. Add buyers, consignees and suppliers to a watchlist with POST /monitored; each is re-screened every morning, and GET /monitored/changes tells you when one gains a match. The day-by-day changes to the six US lists are at GET /changes.

What screening does not decide

A screen tells you who is on a list. It does not classify your goods, decide whether you need a licence, or replace the licensing authority. Every answer says so: it is a screening record, not a licensing decision. In the UK, whether goods are controlled is answered by the Export Control Joint Unit's checker tools; licences come from the same unit.

Prices

Plans start at £59 a month for 2,000 checks, with a 14-day free trial; the details and the OpenAPI file are on the Export Controls Screening API page and in the docs.