BIS: Implements New Rule Automatically Extending Entity List and MEU Restrictions to Affiliates

BIS: Implements New Rule Automatically Extending Entity List and MEU Restrictions to Affiliates

On September 30, 2025, the Bureau of Industry and Security (BIS) issued an interim rule that significantly broadens the scope of U.S. export controls by redefining how “Affiliates” are treated under the Entity List and Military End-User (MEU) List frameworks. Under the new rule, any entity that is 50 percent or more owned, individually or collectively, by one or more listed entities will automatically become subject to Entity List or MEU restrictions, even if it is not separately named. This represents a departure from the prior approach, under which ownership or control alone did not trigger restrictions. The change increases compliance and due diligence obligations for companies engaged in international trade, investments, and global supply chains.

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