You had a year to get ready when BIS suspended the 50% Affiliates Rule. That runway is now closing. On November 10, the rule enters into force — extending Entity List, Military End-User List, and certain SDN List restrictions to any company majority-owned, directly, indirectly, or in aggregate, by a listed entity. Identifying those structures across dozens of jurisdictions, closing data gaps, updating workflows, and training teams takes months. Not weeks.
BIS50 Affiliates Rule Readiness Checklist
A practitioner’s checklist for building an ownership-based screening program before November 10. PDF · Free.
What Changed
When BIS first issued the 50% Affiliates Rule, the geopolitical and regulatory context was different. Since suspension, BIS has continued to add entities to the Entity List and MEU List at an elevated pace, enforcement actions against transshipment networks have increased, and the congressional landscape around codifying the rule into law has shifted. This session covers BIS’s current enforcement posture and what the environment means for when enforcement actually lands once the rule is in effect.
How the Rule Actually Works
- Aggregate ownership thresholds Direct ownership is the simple case — a listed party holds a controlling stake outright. Indirect ownership runs through one or more intermediate holding entities. Aggregate ownership is where two or more listed parties together hold a majority stake, even if no single one controls the company on its own. All three apply.
- MEU List extension The 50% rule extends MEU List restrictions through ownership the same way it extends Entity List restrictions — significantly expanding the universe of entities to which dual-use end-user controls apply, particularly across multi-tier Russian and Chinese state-affiliated networks.
- Red Flag 29 The new BIS red flag requires documented ownership investigation. Compliance programs must show they looked — not just that they checked names against a list. Programs that cannot produce evidence of ownership-based diligence will struggle to defend the standard of care BIS now expects.
Case Studies from Sayari’s BIS50 Analysis
The session covers three case study types drawn from Sayari’s research across its 11.7 billion global corporate and trade records:
- Nested Chinese subsidiary networks where aggregate ownership across multiple tiers reaches the 50% threshold — entities that pass name-based screening
- European companies majority-owned by Entity List parties through intermediate holding structures in non-obvious jurisdictions
- MEU-linked structures that no name-based or address-based screening approach would surface
Building a Defensible Screening Program
The session walks through concrete steps for trade compliance teams at companies of every size: initial gap assessment, choosing a data source that resolves aggregate ownership across multiple corporate layers, updating workflows, and building the documentation trail that satisfies Red Flag 29. BIS’s rule reflects a shift in what regulators expect — not just in Entity List screening, but in the entire posture of a trade compliance program toward beneficial ownership.
Ready to operationalize BIS 50 compliance?
See how Sayari precomputes aggregate ownership across more than six tiers of corporate structure — automatically surfacing entities that name-based screening can’t reach.