The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule, known as the Affiliates Rule, which took effect on September 29, 2025. This rule imposes restrictions on entities that are 50% or more owned, either directly or indirectly, by one or more entities listed on the Entity List, Military End-User List, or certain entities on the Specially Designated Nationals List.
This Rule highlights the need for (enhanced) due diligence on the ownership aspect of entities involved in collaborations and transactions involving items subject to the U.S. Export Administration Regulations (EAR).
This session is a brainstorm amongst EECARO Members how to approach this new Rule.