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.
Learn more about the Affiliates Rule, including key takeaways that are critical for companies to understand, including the difference between the previous standard and the new standard, compliance challenges, and possible paths forward.
Author(s):
Daniel B. Pickard, Shareholder, International Trade & National Security Practice Group Leader
Email: daniel.pickard@bipc.com
Keil J. Ritterpusch, Shareholder
Email: keil.ritterpusch@bipc.com
Natan P.L. Tubman, Associate
Email: natan.tubman@bipc.com