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ARTICLE · 07 OCTOBER 2025

BIS Publishes 50% 'Affiliates Rule'

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On September 29, 2025, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) posted, for public inspection, an interim final rule titled "Expansion of End-User Controls to Cover Affiliates of Certain...

United StatesInternational Law
Opher Shweiki
Opher Shweiki
Shiva Aminian
Shiva Aminian
Anne Borkovic
Anne Borkovic
Tyler D. Grove
Tyler D. Grove
Ryan P. Fayhee
Ryan P. Fayhee
Jaelyn Edwards Judelson
Jaelyn Edwards Judelson
Jingli Jiang
Jingli Jiang
Steven C. Emme
Steven C. Emme
Mahmoud (Mac) Fadlallah
Mahmoud (Mac) Fadlallah
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On September 29, 2025, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) posted, for public inspection, an interim final rule titled "Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities" (the Affiliates Rule). Effective immediately, the rule has significant implications for compliance due diligence and related procedures.

Key Takeaways

  • The Affiliates Rule significantly modifies the Export Administration Regulations (EAR) by extending the license requirements that previously applied only to parties specifically listed on the EAR's Entity List (Entity List) and Military End User (MEU) List to parties that are owned 50% or more, directly or indirectly, individually or in the aggregate, by parties listed on the Entity List or MEU List, or owned by parties that are otherwise subject to Entity List or MEU List restrictions by virtue of their ownership. The Affiliates Rule makes similar changes with respect to certain

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