United States of America: Bureau of Industry and Security's rule expanding end-user controls to cover affiliates of certain listed entities entered into force

On 29 September 2025, US Bureau of Industry and Security's affiliates rule extending export controls for advanced technology items entered into force. The rule states that any foreign entity owned 50 per cent or more by Entity List parties now faces the same license requirements and restrictions as its listed parent entities. The rule extends to all items subject to the Export Administration Regulations when covered affiliates are parties to transactions. It also applies the 50 per cent ownership standard to the Military End-User List and certain Specially Designated Nationals programs. Exporters must determine ownership structures of their transaction partners before proceeding with exports, reexports, or transfers. It also provides that when ownership cannot be determined but Entity List ownership is known, exporters must resolve this issue, obtain a license, or identify an applicable license exception.