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ARTICLE · 07 OCTOBER 2025

BIS Expands Restrictions: 50% Rule Explained

Buchanan Ingersoll & Rooney
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On September 30, 2025, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) issued an interim final rule (Affiliates Rule) that significantly expands the scope of controls to cover certain affiliated...

United StatesInternational Law
Daniel B. Pickard
Daniel B. Pickard
Keil J. Ritterpusch
Keil J. Ritterpusch
Natan P.L. Tubman
Natan P.L. Tubman
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On September 30, 2025, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) issued an interim final rule (Affiliates Rule) that significantly expands the scope of controls to cover certain affiliated parties on the BIS Entity List and Military End Users List (MEU List). The Affiliates Rule applies restrictions to entities that are at least 50% owned by entities that are listed on either the BIS Entity List or the MEU List. The 50% ownership standard established in the Affiliates Rule is designed to be consistent with longstanding U.S. Department of the Treasury Office of Foreign Assets (OFAC) practices. The Affiliates Rule became effective immediately on September 29, 2025. As a result, it is critical that companies understand and comply with the scope of the Affiliates Rule immediately.

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