On November 5, the Bureau of Industry and Security (BIS) at the Department of Commerce released a final rule extending the suspension of its Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities rule (the Affiliates Rule) through January 10, 2027.

Affiliates Rule Overview:

The Affiliates Rule, published September 30, 2025, expands the reach of export control restrictions to foreign affiliates of parties designated on the Entity List or the Military End-User List. Entities that are owned 50 percent or more (directly or indirectly, individually or in the aggregate) by designated parties will automatically be subject to the same license requirements and restrictions as the listed party.

This new mechanism significantly expands the number of companies subject to export control restrictions and imposes additional due diligence requirements on exporters.

Updated Timeline:

The original one-year suspension, which took effect November 10, 2025, and was scheduled to expire November 9, 2026, has been extended through January 10, 2027. This new timeline mirrors a September agreement between the United States and China to extend their trade truce to January.

Next Steps for Exporters and Compliance Teams:

  • Review transactions to determine whether your company may be transacting with affiliates of listed entities.
  • Assess available ownership information and identify relationships where information is lacking.
  • Identify potential licensing requirements that may apply when the Affiliates Rule comes into effect.
  • Update screening and due diligence procedures to ensure the expanded scope of designations is addressed.
  • Monitor for additional BIS announcements regarding further extensions or changes.

 

For further guidance on navigating export controls and preparing for regulatory changes, consult with your global trade compliance advisors.