News & Analysis as of

Affiliates

Ervin Cohen & Jessup LLP

Warning: Your Sister Company Might Be Your Joint Employer Liability Partner

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The U.S. Department of Labor (DOL) recently issued an Opinion Letter (FLSA2025-05), offering important clarification for employers operating multiple, related legal entities regarding their responsibilities under the Fair...more

Royer Cooper Cohen Braunfeld LLC

Unaffiliate the Affiliated: Liability Considerations for Multi-Entity Businesses

Creating a robust business profile of multiple legal entities is a foundational strategy for asset protection and risk management within a larger affiliated business group. ...more

Fenwick & West LLP

BIS Suspends the Affiliates Rule, Lifting Restrictions on Restricted Party Affiliates

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On November 10, 2025, the United States Department of Commerce, Bureau of Industry and Security (BIS) announced a one-year suspension of the “Affiliates Rule,” which imposed U.S. export control restrictions on entities 50...more

Benesch

NEW BIS 50% Screening Rule Now Delayed One Year: China Deal Changes for Trade Compliance

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Trade compliance professionals faced a new challenge when BIS launched the new Affiliates Rule that required screening of all parties with 50% interest. Now the new U.S. trade deal with China pauses this increase in export...more

Goodwin

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. ...more

Miller Canfield

White House Suspends BIS Affiliates Rule for One Year

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On November 1, 2025, the White House issued a Fact Sheet announcing a one-year suspension of the “Affiliates Rule” effective November 10, 2025. The Bureau of Industry and Security (“BIS”) will implement the one-year...more

Whiteford

Client Alert: PPP Affiliation Pitfalls: How Employee Headcount Errors Can Lead To False Claims Act Troubles For Business Owners

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The Paycheck Protection Program was a lifeline for small businesses struggling to keep their employees paid during the COVID-19 pandemic. But for business owners who failed to include all applicable employees in their size...more

Miller Canfield

BIS Expands Export Controls with New Affiliates Rule

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On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a pivotal interim final rule under the U.S. Export Administration Regulations (“EAR”) significantly broadening the scope...more

Miles & Stockbridge P.C.

Commerce Department Expands End-User Restrictions with New ‘Affiliates Rule’

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The Department of Commerce’s Bureau of Industry and Security (BIS) has issued an interim final rule (IFR) that extends end-user restrictions to entities owned 50% or more by parties identified on the Entity List and the...more

Paul Hastings LLP

BIS Extends Export Control Restrictions to Transactions Involving Subsidiaries of Listed Parties

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On Sept. 29, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an Interim Final Rule (the Rule) extending export controls applicable to transactions involving parties restricted pursuant to the...more

Tucker Arensberg, P.C.

No Right to Jury Trial in ERISA Withdrawal Liability Case Involving Veil-Piercing and Evade-or-Avoid Theories, District Court...

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In Board of Trustees of the PAMCAH-UA Local 675 Pension Fund v. SMAC Hawaii, Inc., 2025 U.S. Dist. LEXIS 192966 (D. Haw. Sept. 30, 2025), the pension fund sought to collect over $610,000 in ERISA withdrawal liability from...more

Conyers

Bermuda Supreme Court Rejects Regulatory Claims: A Landmark Ruling on the Singapore Take-over Code and Kingboard

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On 18 August 2025, the Supreme Court of Bermuda delivered its judgment in the case of Annuity & Life Re Ltd and Pope Asset Management LLC v Kingboard Copper Foil Holdings Ltd and Others [2025] SC (Bda) 88 Civ. This marked the...more

Holland & Knight LLP

BIS Expands Impact of U.S. Export Controls with 50 Percent Rule

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The U.S. Department of Commerce Bureau of Industry and Security (BIS) published a much-anticipated interim final rule (IFR) on Sept. 30, 2025. The IFR makes foreign entities that are owned 50 percent or more, directly or...more

Troutman Pepper Locke

Dissecting the Nuances of BIS’s New Affiliates Rule

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The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) recently implemented the long-anticipated 50% ownership standard (or Affiliates Rule) to extend the licensing requirements under the Export...more

Goodwin

Guilty by Association: Export Controls Just Got More Inclusive

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On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a rule, effective immediately, that amended the Export Administration Regulations to address diversion concerns regarding...more

Hogan Lovells

U.S. Commerce Department significantly expands the Entity List under new Affiliates Rule

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Pursuant to the new “Affiliates Rule,” the Entity List license requirements now apply to any foreign entity that is owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more listed...more

Dorsey & Whitney LLP

Commerce Extends U.S. Export Control Restrictions to Affiliates of Parties on the Entity List

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On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (“BIS”) announced it was extending restrictions imposed by its Entity List and its Military End User (“MEU”) List to organizations...more

Venable LLP

BIS Adopts New "Affiliates Rule" Standard for Entity List and Other Restricted End User Lists

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In response to national security concerns regarding shipments of export-controlled items diverted to entities on the Entity List and other U.S. restricted parties lists, the U.S. Department of Commerce, Bureau of Industry and...more

Pillsbury - Global Trade & Sanctions Law

Commerce Department Issues “Affiliates Rule,” Extends Entity List Restrictions to Majority-Owned Foreign Entities

On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a long-anticipated interim final rule (IFR) amending the Export Administration Regulations (EAR) to extend Entity List and...more

Orrick, Herrington & Sutcliffe LLP

BIS Expands End User Export Controls with 50% Rule

The U.S. Commerce Department has expanded export control sanctions by extending them to 50% or more-owned affiliates of restricted parties. This development has a particularly significant impact on China-related export...more

WilmerHale

Beware of Affiliates: BIS Expands Controls with 50% Ownership Rule, New Diligence Obligations

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The Department of Commerce’s Bureau of Industry and Security (BIS) has published an interim final rule (the Affiliates Rule) expanding the standard for entities captured under BIS export restrictions to include entities with...more

Morgan Lewis

BIS Adopts ‘50% Rule’: Key Takeaways for Trade Compliance

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The Affiliates Rule automatically extends the US Department of Commerce’s Entity List and Military End-User (MEU) List to entities owned 50% or more by entities on either list. On September 29, 2025, the US Department of...more

Fenwick & West LLP

BIS Expands Entity List and MEU List Restrictions to Owned Entities with New ‘Affiliates Rule’

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On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule expanding restrictions on Entity List and Military End-User (MEU) List parties to automatically apply...more

Morgan Lewis

New Interpretations from China's Supreme People’s Court: What Multinational Employers Need to Know

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The highest court in China recently released new interpretations regarding the application of laws in labor dispute cases, which took effect on September 1, 2025. These bring clarity to a range of employment issues in China,...more

Lowenstein Sandler LLP

The Importance of Complying with Private Fund Documents for Affiliate Transactions

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Private fund advisers continually balance their ongoing responsibility to ensure that the funds they advise comply with such funds’ governing documents and their responsibility to ensure their own compliance with applicable...more

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