The Consolidated Screening List, fully unpacked.

The Consolidated Screening List (CSL) is a single search interface, maintained by the International Trade Administration at the Department of Commerce. It aggregates 14 separate restricted-party lists from three U.S. agencies. It exists because exporters historically had to query each list independently, a procedural gap that produced both compliance failures and unnecessary license filings.

Critical clarification: the CSL is a search tool, not itself a regulatory list. A name appearing on the CSL means the name is on one of the 14 underlying lists, which carry the legal weight. Inclusion in CSL creates no new prohibition. The legal consequence depends entirely on which underlying list applies.

Denied Persons List (DPL), Commerce / BIS

Persons denied export privileges. Absolute prohibition on transactions involving items subject to the EAR. 15 CFR 766 supplement.

Unverified List (UVL), Commerce / BIS

Parties whose bona fides BIS could not verify. Triggers enhanced due-diligence and no use of license exceptions, but not an absolute prohibition. 15 CFR 744 Supplement No. 6.

Entity List (EL), Commerce / BIS

Parties subject to specific license requirements for the export, reexport, or in-country transfer of items subject to the EAR. License presumption typically denial. 15 CFR 744 Supplement No. 4.

Military End User (MEU) List, Commerce / BIS

Foreign parties identified as military end users for purposes of the China, Russia, Venezuela, and Burma military end-use rule. 15 CFR 744 Supplement No. 7.

Nonproliferation Sanctions, State / ISN

Persons sanctioned under nonproliferation statutes (Iran, North Korea, Syria Nonproliferation Act; Iran-Iraq Arms Non-Proliferation Act; Chemical and Biological Weapons Control Act).

AECA Debarred List, State / DDTC

Persons debarred from defense-trade transactions under the Arms Export Control Act.

Specially Designated Nationals (SDN), Treasury / OFAC

Blocks all property and interests in property of designated persons. The largest and most-cited OFAC list. Applies the OFAC 50 Percent Rule for ownership.

Foreign Sanctions Evaders (FSE), Treasury / OFAC

Foreign individuals and entities that have engaged in evasive transactions on behalf of sanctioned parties.

Sectoral Sanctions Identifications (SSI), Treasury / OFAC

Restricted dealings with persons in identified Russian sectors. Sanctions are activity-specific (debt, equity, drilling support), not asset-blocking.

CAPTA, Treasury / OFAC

Foreign financial institutions subject to correspondent or payable-through account sanctions pursuant to specific authorities (Ukraine Freedom Support Act of 2014, etc.).

Non-SDN Menu-Based Sanctions (NS-MBS), Treasury / OFAC

Sanctioned persons subject to a menu of restrictions short of full SDN blocking.

Non-SDN Chinese Military-Industrial Complex Companies (NS-CMIC), Treasury / OFAC

Restrictions on U.S. persons trading securities of designated Chinese companies.

Non-SDN Palestinian Legislative Council (NS-PLC), Treasury / OFAC

Specific restrictions on transactions with designated PLC members.

Plus one additional OFAC list

OFAC continues to evolve its list set. The ITA aggregator refreshes the constituent set as Treasury adds or sunsets a sub-list. Verify the current count at trade.gov/consolidated-screening-list before publishing any specific number for compliance documentation.

A hit on the CSL is not a hit. It is a hit on one of the 14 underlying lists, each with its own legal consequence. The severity hierarchy below reflects DiligenceDesk's editorial reading of the underlying authorities; legal consequences in any specific transaction depend on the controlling regulation. Cited at the BIS level, the ranking DPL > Entity List > UVL is explicit; placement of the other lists is interpretive.

Absolute prohibition

DPL, OFAC SDN. No transaction. Blocking required for SDN. No license available for DPL.

License-required, presumption of denial

Most Entity List entries, AECA Debarred. License required for any covered transaction; outcomes case-by-case.

Conditional or sectoral

SSI, NS-MBS, NS-CMIC, MEU, CAPTA, FSE. Restrictions apply to specific transaction types or items only.

Diligence flag, not prohibition

UVL. "Red flag", additional verification required; no automatic denial.

Specialized / narrow

Nonproliferation, NS-PLC. Activity-specific or list-specific narrow restrictions.

The CSL contains seven OFAC lists (SDN, FSE, SSI, CAPTA, NS-MBS, NS-CMIC, NS-PLC). But OFAC also publishes its own Consolidated Sanctions List, which is a different aggregation focused exclusively on Treasury-administered sanctions. They overlap but are not identical.

The SDN List itself is the most consequential of the OFAC lists. Per OFAC's own FAQ guidance, SDNs are "individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries," plus "individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific." Their assets are blocked, and U.S. persons are generally prohibited from dealing with them.

OFAC 50 Percent Rule

OFAC blocking applies to entities owned 50 percent or more, directly or indirectly, by one or more SDN-listed persons, even if the related entity is not itself listed. CSL search will NOT surface ownership-derived blocking. This is the largest gap in any CSL-only screening workflow. See the canonical Treasury document: Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked, issued August 13, 2014.

OFAC statutory authority

SDN designations are issued under the Trading With the Enemy Act, the International Emergency Economic Powers Act (IEEPA), the Anti-Terrorism and Effective Death Penalty Act, and the Foreign Narcotics Kingpin Designation Act. Different statutes carry different sub-prohibitions; the same SDN entry may invoke multiple authorities.

BIS statutory authority

The BIS Denied Persons List sits at 15 CFR Part 764, Supp. No. 2 (entities denied export and reexport privileges). The BIS Entity List sits at 15 CFR Part 744, Supp. No. 4(foreign end users posing an unacceptable diversion risk; exports may require a license). Per OFAC: "The foreign policy objectives and legal requirements of OFAC's lists are significantly different from those of the BIS lists. The unique goals of the OFAC and BIS programs preclude the creation of a combined OFAC and BIS list."

Other OFAC lists beyond SDN

OFAC also administers the Foreign Sanctions Evaders (FSE) List and the Sectoral Sanctions Identifications (SSI) List. U.S. persons are not required to block property of FSE or SSI entries unless those targets also appear on the SDN List, but separate prohibitions and investment restrictions still apply.

Distinct enforcement jurisdictions

Sanctions enforcement (OFAC, civil and criminal) is distinct from export-control enforcement (BIS). A single match may trigger one or both jurisdictions.

Operational rule of thumb: a CSL hit on an OFAC SDN entry is an OFAC matter. A CSL hit on a BIS Entity List entry is a BIS matter. The CSL doesn't replace either jurisdiction; it just helps you find the name.

The CSL is U.S.-issued and export- or sanctions-focused. Critical gaps for a federal procurement diligence workflow:

• DOD CCMC List / DOD 1260H List (Section 1260H FY 2021 NDAA "Chinese Military Companies")
• SAM.gov Exclusions, federal procurement debarments, separate scope, separate database. See our SAM exclusions field-by-field guide.
• FBI Most Wanted / Specially Designated Terrorists (overlap with SDN but published independently)
• Foreign government sanctions: UK OFSI consolidated list, EU consolidated list, UN Security Council 1267
• State-level debarments and suspended-vendor lists
• Politically Exposed Persons (PEP) data, CSL is not an AML tool

A CSL-only screen is necessary but not sufficient for global counterparty screening. For Section 889 specifically, see Section 889 vendor screening and the FAR 52.204-25 walkthrough.

The endpoint is at developer.trade.gov (current path: https://api.trade.gov/gateway/v1/consolidated_screening_list/search, verify against developer.trade.gov, ITA has rotated paths historically). Free. Requires an API key obtained at developer.trade.gov. Returns JSON. Daily refresh at 5:00 AM EST/EDT. Downloadable CSV / TSV / XML files also published.

Fuzzy name search is supported via a fuzzy_name=true parameter and returns a score field (0–100). The threshold for action is a policy decision, not a regulatory one. Auditable screening requires logging the query, the timestamp, the score, and the disposition. Most homegrown integrations skip the score logging, which is a frequent gap in OFAC examination findings.

The CSL is one of the eight federal sources in our verdict ladder. Every counterparty is screened against the CSL via api.trade.gov on every refresh; we normalize hits to the severity tiers above and attach the issuing-agency citation; we log the full response for audit.

Critically, and this is what makes the page do work: we also screen against SAM.gov exclusions, DOD 1260H, and UK OFSI / EU consolidated lists in parallel because, per Section 5, CSL alone is not coverage. For the broader workflow see Step 4 of the contractor due-diligence checklist.