U.S. Department of Commerce’s BIS Adopts “50 Percent Rule”

On September 29, 2025 the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published an Interim Final Rule known as the “Affiliates Rule” amending the Export Administration Regulations (EAR) to significantly expand the scope of applicable export restrictions to entities that are 50 percent or more owned by one or more entities on the Entity List (Supplement No. 4 to Part 744), the “military end-users” list (MEU List) (Supplement No. 7 to Part 744), and to certain persons designated on the Specially Designated Nationals and Blocked Parties List (SDN List) pursuant to § 744.8(a)(1).