U.S. export controls: the 50% affiliates rule
BIS's Affiliates Rule, effective 29 September 2025, automatically applies Entity List and Military End-User restrictions to any foreign company owned 50% or more, directly or indirectly and individually or in aggregate, by listed parties or certain sanctioned (SDN) parties. Under the U.S.–China deal it was suspended from 10 November 2025 and is scheduled to return on 10 November 2026; as of 5 October 2026 a Federal Register search shows no extension, despite the truce extension announced in September. Once it returns, exporters have an affirmative duty to determine the ownership of parties to a transaction and, where they cannot, may need a BIS license.
How it unfolded.
- 2025-09-29
BIS's Affiliates Rule (interim final rule) takes effect; published in the Federal Register on 30 September. source ↗
- 2025-11-01
White House: under the U.S.–China deal, the Affiliates Rule will be suspended for one year from 10 November 2025. source ↗
- 2025-11-10
The suspension takes effect (published 12 November) and runs to 9 November 2026. source ↗
- 2026-09-23
Treasury Secretary Bessent says truce measures due to lapse on 10 November will run to 10 January 2027; whether this covers the Affiliates Rule pause is not confirmed in the Federal Register. source ↗
- 2026-11-10
The Affiliates Rule returns unless BIS extends the suspension. source ↗
What the markets are saying.
- 09.23 Truce extension announced (Affiliates Rule pause not confirmed)
Daily closes, last six months. Source: Yahoo Finance; refreshed with each Global Watch edition (last update Oct 9, 2026, 6:37 AM KST). Indicators only, not investment advice.
Questions for your purchasing and risk teams
- Identify the direct and indirect shareholders of every export and re-export counterparty, including end users and intermediate consignees.
- Add up the holdings of Entity List, MEU and SDN parties; at 50% or more the rule applies, and where several listed owners are involved the most restrictive license requirement among them applies.
- Keep a separate list of counterparties whose ownership you cannot establish; under Red Flag 29 that can mean a license is required.
- Identify now the orders and shipments that would be affected if the rule returns on 10 November 2026.
- Re-check counterparties' ownership regularly and require them by contract to notify you of ownership changes.
- Build license lead times into delivery and production schedules for transactions that may need one.
What HELIOS does about it
- Ownership matching: tracing direct and indirect shareholders through public registries and filings and checking them against the Entity List, MEU List and SDN List on the 50% aggregate test.
- Continuous monitoring of counterparties' ownership changes and list updates.
- Korean-language executive alerts on BIS reinstatement or extension notices and new listings.
- Vision AI forensic checks of shareholder registers and corporate documents supplied by counterparties.
- Federal Register — expansion-of-end-user-controls-to-cover- ↗
- Federal Register — one-year-suspension-of-expansion-of-end- ↗
- 법률신문 ↗
- The White House — ↗
- 국제금융센터 ↗
As of 2026-10-05. Figures are as published by each source. Not legal or investment advice.
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