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ARTICLE · 06 OCTOBER 2025

Commerce Expands EAR End-User Controls With New "50 Percent Rule"

Wiley Rein
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On September 30, 2025, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) published an interim final rule (IFR) that significantly expands the number...

United StatesInternational Law
Hon. Nazak Nikakhtar
Hon. Nazak Nikakhtar
Lori E. Scheetz
Lori E. Scheetz
John R. Shane
John R. Shane
Matt Lapin
Matt Lapin
Paul J. Coyle
Paul J. Coyle

On September 30, 2025, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) published an interim final rule (IFR) that significantly expands the number of foreign entities subject to license requirements and other restrictions based on Entity List and "Military End-User" (MEU) List designations as well as certain sanctions designations. The IFR amends the Export Administration Regulations (EAR) such that any foreign entity that is at least 50% owned by one or more entities on the Entity List or MEU List is itself automatically subject to Entity List or MEU List restrictions, respectively. BIS also concurrently released a revised set of "Entity List FAQs" providing additional guidance.

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