Not Guilty (Yet): The Export-Related Affiliates Rule Is Postponed by One Year

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The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) is suspending the new Affiliates Rule (read our October 3, 2025 alert to learn more about the rule) until November 9, 2026. The BIS will formally publish the suspension on November 12, 2025, with an effective date of November 10, 2025.

This suspension provides additional time for companies to assess ownership, governance, and supply chain relationships that may trigger compliance obligations once the rule takes effect again on November 10, 2026.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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