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ICYMI: BIS Imposes New Affiliates Rule
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ICYMI: BIS Imposes New Affiliates Rule
Enforcement, Export, International Trade, U.S. Bureau of Industry and Security (BIS), U.S. Department of Commerce (DOC)

ICYMI: BIS Imposes New Affiliates Rule

[Update November 10, 2025]: BIS imposed a one-year suspension of the interim final rule. The suspension is set to end November 9, 2026, absent a future extension.

On September 30, 2025, the Bureau of Industry and Security (BIS) released an interim rule regarding “Affiliates.” Under the rule, any entity that is at least 50% owned by one or more entities on the Entity List or the Military End-User (MEU) List will itself automatically be subject to Entity List/MEU restrictions. This is a significant change from the current standard, which excludes entities that are not specifically included on the Entity List or MEU List, regardless of any affiliation with Entity List or MEU List organizations.

This rule is effective September 29, 2025.

Entity, MEU List Background

The Entity List identifies persons (including businesses, research institutions, government and private organizations, individuals, and other types of legal persons) reasonably believed to be involved, or to pose a significant risk of being or becoming involved, in activities contrary to the national security or foreign policy interests of the United States. These persons are subject to specific license requirements for the export, reexport, and/or transfer (in-country) of specified items.

BIS first published the Entity List in 1997. Since its initial publication, grounds for inclusion on the Entity List have expanded to activities sanctioned by the State Department and activities contrary to U.S. […]

By Jennifer Diaz|2025-11-10T18:59:28-05:00October 17, 2025|Enforcement, Export, International Trade, U.S. Bureau of Industry and Security (BIS), U.S. Department of Commerce (DOC)|0 Comments

BIS Publishes First Military End User List

In a Final Rule, published on December 23, 2020, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”) by creating a “Military End User (MEU) List”. The list includes the first tranche of 103 entities consisting of 58 military end-users in China and 45 in Russia. BIS determined that these companies are ‘military end users’ for purposes of the ‘military end user’ control in the EAR that applies to specified items for exports, reexports, or transfers (in-country) to China, Russia, and Venezuela when such items are destined for a prohibited ‘military end user.’

Prior to this final rule, exporters, reexporters, or transferors were responsible for identifying these entities as ‘military end users’ themselves, assuming they were not otherwise individually informed. The MEU List (which is now searchable on the consolidated screening list) allows the public to be informed of BIS’s determination so all potential exporters are informed simultaneously.

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By Jennifer Diaz|2022-07-07T15:03:05-04:00January 28, 2021|Export, Import, ITAR, U.S. Bureau of Industry and Security (BIS), U.S. Office of Foreign Assets Control (OFAC)|0 Comments