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Bureau of Industry and Security (BIS) Due Diligence

Holland & Knight LLP

Aviation Finance: 2025 Sanctions Update and 2026 Outlook

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Export controls and economic sanctions have remained an active and evolving area of laws and regulations that continue to impact the aviation industry in 2025 – both contributing to and arising as a result of an increasingly...more

ArentFox Schiff

Top Five Export Controls and Sanctions Areas to Watch in 2026

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Last year saw a number of significant developments in US export controls and sanctions....more

American Conference Institute (ACI)

[Event] 3rd Advanced Forum on Global Export Controls - February 24th - 25th, Arlington, VA

If you are a trade and legal compliance decision-maker, where can you go to learn, expand your export controls brain trust, and strengthen your strategy? At ACI’s Advanced Forum on Global Export Controls, you’ll connect...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - December 2025 - Overview of BIS’s Interim Final Rules, Export Controls for Advanced Computing,...

On November 10, 2025, the U.S. Bureau of Industry and Security (“BIS”) delayed the effective date of its new Affiliates Rule for a one-year period, until November 9, 2026, after U.S. and China trade talks. The Affiliates...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

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

Perkins Coie

BIS Expands Entity List and Military End-User List Restrictions to Affiliates

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Key Takeaways In a significant—but anticipated—change to the U.S. export control regime, the Bureau of Industry and Security (BIS) released an interim final rule amending the Export Administration Regulations (EAR) by...more

K&L Gates LLP

BIS Rule Significantly Expands Reach of Entity List Export Controls; Includes Temporary General License

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The US Commerce Department’s Bureau of Industry and Security (BIS) has introduced a major revision of the Export Administration Regulations (EAR), 15 C.F.R. Part 730 et seq., through an Interim Final Rule (IFR) extending...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

Alston & Bird

BIS Applies 50 Percent Ownership Rule to Entities on Entity List and Military End User List

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On September 29, 2025, the Bureau of Industry and Security (BIS) published a new “50 percent rule” expanding export controls under the Export Administration Regulations (EAR). This rule subjects any foreign entity that is 50%...more

DLA Piper

Expansion of end-user controls to cover affiliates: BIS adopts 50 percent ownership rule for Entity List, Military End User List,...

DLA Piper on

On September 30, 2025, the Bureau of Industry and Security (BIS) published an interim final rule (IFR) amending the Export Administration Regulations (EAR) to expand end-user controls and address diversion risks associated...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

Akin Gump Strauss Hauer & Feld LLP

BIS Publishes 50% 'Affiliates Rule'

On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) posted, for public inspection, an interim final rule titled “Expansion of End-User Controls to Cover Affiliates of Certain Listed...more

Latham & Watkins LLP

US Commerce Department Adopts Affiliates Rule Expanding Export Restrictions

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This measure significantly expands the scope of Entity List and Military End-User List restrictions, imposing heightened diligence obligations and complicating EAR compliance....more

Katten Muchin Rosenman LLP

U.S. Bureau of Industry and Security Amends Export Administration Regulations to Add 50% "Affiliate" Rule for Entity and Military...

On Sept. 29, 2025, the U.S. Department of Commerce's Bureau of Industry and Security ("BIS") issued a new interim final rule (the "Rule") that amends the Export Administration Regulations ("EAR"). Under the Rule, any foreign...more

Holland & Hart LLP

BIS Expands End-User Controls through Adoption of 50 Percent Rule

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On September 30, 2025, the Bureau of Industry and Security (“BIS”) published an Interim Final Rule (“IFR”) entitled “Expansion of End-User Controls To Cover Affiliates of Certain Listed Entities.” This rule expands end-user...more

Eversheds Sutherland (US) LLP

Commerce Department Expands Scope of Entity List and MEU List to Apply to 50%-owned Subsidiaries

As anticipated, the US Department of Commerce Bureau of Industry and Security (BIS) issued an interim final rule to expand certain end-user restrictions under the Export Administration Regulations (EAR) to entities that are...more

Mayer Brown

New US Commerce Department Global License Requirements for Transactions Involving Affiliates of Listed Entities

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The US Department of Commerce, Bureau of Industry and Security (BIS) on Monday, September 29, 2025, released the Affiliates Rule, which draws unnamed entities around the world into BIS’s entity-specific controls. BIS intends...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

The Volkov Law Group

BIS Expands Entity List Controls to Cover Affiliates of Listed Parties

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On September 30, 2025, the Bureau of Industry and Security (“BIS”) issued an interim final rule (“IFR”) that significantly revises the scope of the Export Administration Regulations (“EAR”) by extending Entity List...more

Jones Day

United States Expands Reach of Export Controls Entity List

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On September 29, 2025, the United States significantly expanded the reach of export controls. The U.S. Department of Commerce's Bureau of Industry and Security ("BIS") released an interim final rule, that applies Entity List...more

Lowenstein Sandler LLP

BIS 50 Percent Rule: Starting This Week, Companies Must Research the Ownership of All Foreign Customers

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On Monday, September 29, the Department of Commerce’s Bureau of Industry and Security (BIS) released an interim final rule that adopts a 50 percent ownership standard to extend Export Administration Regulations (EAR) end‑user...more

Bass, Berry & Sims PLC

BIS Closes Loophole: New Rule Expands Export Controls to Affiliates of Listed Entities

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On September 29, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued a new interim final rule that significantly expands the scope of U.S. export controls. Entitled Expansion of End-User Controls to...more

White & Case LLP

BIS Implements “Affiliates Rule” (a 50% Rule) Applicable to Entity List and Military End User List

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The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an interim final rule (the “Affiliates Rule”), effective September 29, 2025, automatically imposing corresponding restrictions on entities 50%...more

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