The BIS Affiliates Rule and small exporters
Updated · Rotomal
The Affiliates Rule makes any company owned 50 percent or more by Entity List parties subject to Entity List restrictions, and applies similar restrictions to companies 50 percent or more owned by listed military end users and certain sanctioned parties, even when those companies are not on any list. BIS suspended it for one year from 10 November 2025. On 5 November 2026 BIS filed a final rule, scheduled for Federal Register publication on 9 November 2026, that extends the suspension until 10 January 2027. The rule is paused, not withdrawn: use the time to collect ownership information, and check the Federal Register for any later change.
Dates as of 7 November 2026
| Date | What happened |
|---|---|
| 30 September 2025 | BIS publishes the Affiliates Rule as an interim final rule |
| 10 November 2025 | BIS suspension of the Affiliates Rule takes effect for one year |
| 23 September 2026 | Treasury Secretary announces a two-month extension of the US-China arrangement to 10 January 2027 |
| 5 November 2026 | BIS files a final rule extending the suspension until 10 January 2027 |
| 9 November 2026 | Scheduled Federal Register publication and effective date of the extension |
| 10 January 2027 | End of the extended suspension unless BIS extends it again |
Why name screening is not enough
A company caught by the rule is, by definition, not on the list itself; its owner is. Screening your customer's name against the Entity List will come back clear. You need to know who owns your customer, at least for parties in higher-risk jurisdictions.
Practical steps for a small exporter
- List your customers, distributors and end users in China, Russia and other higher-risk destinations.
- Ask each one in writing for its ownership, including indirect owners, and file the answer.
- Screen the owners you are told about, not only the customer.
- Add ownership representations and change-of-ownership notice to new contracts.
- Keep the questionnaire, the answer and your screening record together for each party.
Where Counterparty Watch helps
It screens your parties and any owners you add against the US, UK, EU and UN lists every day, sends and files the ownership questionnaire, and keeps the log. It does not trace ownership through corporate registries, and it is not legal advice.
Questions
Is the Affiliates Rule in force now?
No. It has been suspended since 10 November 2025, and a BIS final rule scheduled for publication on 9 November 2026 extends the suspension until 10 January 2027. Check the Federal Register before then for any further change. This is not legal advice.
Does the free CSL search show 50 percent owned companies?
No. The CSL lists named parties. Ownership has to be established through due diligence, such as asking the customer and checking what they tell you.
Sources
- Federal Register (public inspection): Extension of the Suspension of Expansion of End-User Controls for Affiliates of Certain Listed Entities (filed 5 November 2026, publication 9 November 2026) Source: federalregister.gov
- Federal Register: One Year Suspension of Expansion of End-User Controls for Affiliates of Certain Listed Entities (12 November 2025) Source: federalregister.gov
- Pillsbury: What if the BIS Affiliates Rule comes into force? (22 October 2026) Source: pillsburylaw.com
- Miller Canfield: BIS Affiliates Rule suspension extended but uncertainty remains (1 October 2026) Source: millercanfield.com
- International Trade Administration: Consolidated Screening List Source: trade.gov