Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 07 OCTOBER 2025

BIS Issues New 50 Percent Rule On Affiliation

Lewis Brisbois Bisgaard & Smith LLP
Explore more from Lewis Brisbois Bisgaard & Smith LLP

On September 29, 2025, the Commerce Department's Bureau of Industry and Security (BIS) issued a new interim final rule (Affiliates Rule) subjecting any entity that is at least 50...

United StatesInternational Law
Maria Shockley
Maria Shockley
Andrew Pidgirsky
Andrew Pidgirsky
Jane Luxton
Jane Luxton
Author LinkedIn connections

Washington, D.C. (October 2, 2025) - On September 29, 2025, the Commerce Department's Bureau of Industry and Security (BIS) issued a new interim final rule (Affiliates Rule) subjecting any entity that is at least 50 percent owned by one or more entities on the Entity List or Military End-User List (MEU) to the same restrictions applicable to the listed entity. BIS previously used a "legally distinct" standard in applying restrictions to affiliates on the Entity List, but the new rule aligns the BIS approach with that used by the Treasury Department's Office of Foreign Assets Control.

The Affiliates Rule extends licensing restrictions to entities that:

  • Are at least 50 percent owned by a single entity that is on the Entity List or MEU; or

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

See more popular content from

Article

Trump Administration Waives New Russia Sanctions And Tariffs Under Graham Act

President Trump issued an executive order implementing the Graham Act, which establishes substantial new tariffs on Russian goods and countries purchasing Russian energy, but simultaneously waives their application. The order creates a monitoring framework that leaves open the possibility of future enforcement while maintaining existing Russia sanctions regimes.
GlobalInternational Law
Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
Article

U.S.-China Trade Truce Extended Two Months: BIS Affiliates Rule Suspension Follows

The U.S.-China trade truce has been extended through January 10, 2027, pushing back the effective date of the Bureau of Industry and Security's Affiliates Rule. While the suspension delays immediate compliance obligations, the rule remains in place and companies should use this additional time to prepare their compliance programs before the suspension potentially expires.
GlobalInternational Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

The Lindsey Graham Sanctions Act: What Businesses Need To Know About The New Tariffs

President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act into law on September 18, 2026, establishing mandatory tariffs of up to 500% on Russian goods and up to 100% on goods from countries that continue to buy Russian energy. The Act targets major importers like China, India, and Turkey, with limited relief mechanisms including natural gas exceptions, presidential waivers, and a 270-day winddown period for entities divesting from Russian operations.
GlobalInternational Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

Updates On Export Controls Impacting AI & Advanced Computing

The U.S. Department of Commerce's Bureau of Industry and Security issued guidance on May 31, 2026, clarifying licensing requirements for advanced computing items and AI technologies. The guidance maintains export restrictions for entities in certain countries while providing limited relief for data center operators, though questions remain about future regulatory direction. Companies must now strengthen their compliance programs and supply-chain due diligence as BIS continues to prioritize national security
GlobalInternational Law
Finnegan, Henderson, Farabow, Garrett & Dunner LLP
Finnegan, Henderson, Farabow, Garrett & Dunner LLP