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US BIS Issues New 50% Affiliates Rule for Export Controls

September 30, 2025

The US Department of Commerce’s Bureau of Industry and Security (BIS) issued a new rule to strengthen export control. Any entity that is at least 50 percent owned by one or more entities on the Entity List or the Military End-User (MEU) List will itself automatically be subject to Entity List/MEU List restrictions. Additionally, significant minority ownership by an Entity List/MEU List company is a red flag that triggers additional due diligence requirements for exporters. Compliance with this new rule may impact university activities such as research partnerships and technology transfer involving dual-use items or technologies controlled in the US. This announcement further builds the need for the practice of open source due diligence.