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ARTICLE · 02 OCTOBER 2025

BIS Issues "Affiliates Rule" To Dramatically Expand Applicability Of Entity And Military End-User Lists

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In issuing the Affiliates Rule with immediate effect, the U.S. Department of Commerce Bureau of Industry and Security (BIS) drastically expanded the number of entities subject...

GlobalInternational Law
Scott Wise
Scott Wise
Jeremy Iloulian
Jeremy Iloulian
Chandler Leonard
Chandler Leonard
Jacqueline (Jackie) Schaeffer
Jacqueline (Jackie) Schaeffer
Rachel Bogin
Rachel Bogin
Dmitry Bergoltsev
Dmitry Bergoltsev

What You Need to Know

  • Key takeaway #1 Entity List and Military End-User Restrictions Now Apply to 50-percent Owned Affiliates In issuing the Affiliates Rule with immediate effect, the U.S. Department of Commerce Bureau of Industry and Security (BIS) drastically expanded the number of entities subject to the BIS' most restrictive export tools by applying the same trade prohibitions to any entities that are owned, directly or indirectly, 50 percent or more by one or more entities listed on BIS' Entity List, Military End-User (MEU) List or certain SDN entities. The Entity List alone has over 3,000 listed entries, thus the ripple effects for these restrictions on all affiliates and subsidiaries owned 50 percent or more by Entity List entities will have a global impact as companies adjust to the plethora of entities now subject to very restrictive export controls. There is a 60-day general license for exports, reexports, exports from abroad, and deemed exports to

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