Please note that the content below was posted on October 2, 2025. We have since provided updated guidance on the topics discussed in this post here.
On September 29, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued a new interim final rule that significantly expands the scope of U.S. export controls. Entitled Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities and referred to by BIS as the “Affiliates Rule,” the rule is designed to close a longstanding loophole by extending restrictions to foreign affiliates of parties already subject to export restrictions, including those parties designated on the Entity List and the Military End-User (MEU) List.
Continue Reading BIS Closes Loophole: New Rule Expands Export Controls to Affiliates of Listed Entities