BIS Expands List-Based Controls Through Implementation Of "50 Percent Rule"

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued an interim final rule (IFR) that expands the coverage of list-based requirements and restrictions imposed by the Entity List, Military End User (MEU) List, and Section 744.8 of the Export Administration Regulations (EAR), which restricts exports, reexports, and transfers (in-country) when a person who is designated on the Specially Designated Nationals and Blocked Persons List with certain specified program identifiers (SDN List) is a party to the transaction. Known as the "Affiliates Rule," the IFR extends the requirements and restrictions under the EAR to entities that are owned 50 percent or more — directly or indirectly, individually or in aggregate — by (a) parties identified on the Entity List, MEU List, or SDN List and/or (b) entities that are themselves subject to those restrictions due to their ownership structure, and, as a result, such impacted entities