BIS 50% Affiliates Rule returns November 10 unless extended

The Bureau of Industry and Security’s Affiliates Rule, an interim final rule published September 30, 2025, extends Entity List restrictions to foreign companies owned 50% or more, directly or indirectly, individually or in the aggregate, by listed parties. It covers parties on the Entity List and the Military End-User List and certain sanctioned parties.

BIS suspended the rule for one year from November 10, 2025, as part of the U.S.-China trade arrangement, and the suspension is set to end on November 9, 2026. On September 23, 2026, Treasury Secretary Scott Bessent announced a two-month extension of that arrangement through January 10, 2027, which is expected to extend the suspension as well. BIS had not published a notice changing the date when we checked on November 3, so November 10 remains the date in the regulations.

Either way, the rule stays on the books. When it applies, an exporter that knows a foreign customer is partly owned by a listed party has to establish the ownership percentage, and if it can’t, it has to obtain a license before going ahead.

What it means for data: screening names against lists no longer covers the risk. Exporters need ownership percentages for each foreign customer, distributor and end user, added up across listed owners and traced through each level of the chain, with the source and date of every figure. In our experience, manufacturers that sell through acquired business units hold the same customer under different names in several ERP systems, so the first task is one customer record with its ownership hierarchy attached, and a screening process that reads from it.