Masterclass

The Affiliates Rule is Back. Is Your Program Ready?

The BIS Affiliates Rule is set for Nov 10, 2026. This practitioners’ session will show what has changed since the rule’s suspension, and how to build a defensible ownership-based screening program now.

51 min Download the Readiness Checklist
Nov 10, 2026

Rule Implementation Date

The BIS Affiliates Rule snaps into force, unless Congress acts first to codify it into law before then.

3x or more

Expanded Restricted Universe

Preliminary Sayari research suggests a fully enacted BIS 50% rule could expand the number of entities subject to Entity List restrictions by three times or more.

6 hops deep

Aggregate Ownership Resolved

Sayari precomputes aggregate ownership risk across multiple corporate layers, automatically surfacing entities majority-owned by Entity List and MEU List companies that name-based screening would miss entirely.

Why this session, why now

A one-year runway is closing. Compliance programs need to be ready when the rule snaps into force.

You had one year to get ready when the Bureau of Industry and Security (BIS) suspended its 50% Affiliates Rule. But time is running out.

On Nov 10, the rule will enter into force, extending Entity List, Military End-User List, and certain Specially Designated Nationals (SDN) List restrictions to any company that is majority-owned, directly or indirectly or in aggregate, by a listed entity.

Identifying aggregate ownership structures across dozens of jurisdictions, closing data gaps, updating workflows, training teams — you know it can take months.

  • BIS 50% Affiliates Rule

    Extends Entity List, MEU List, and certain Specially Designated Nationals (SDN) List restrictions to any company majority-owned (directly, indirectly, or in aggregate) by a listed entity. Currently set to enter into force November 10, 2026.

  • Entity List, MEU, and SDN Extension Through Ownership Networks

    The Entity List, Military End-User List, and SDN designations already restrict named parties. Under the 50% rule, those restrictions extend through ownership networks — reaching entities that no name-based or address-based screening would surface.

  • Red Flag 29

    The new BIS red flag requires documented ownership investigation. Compliance programs must be able to show they looked — not just that they checked names against a list.

Session Agenda

What you will learn

A practitioner-focused session for trade compliance teams preparing for the November 10 snapback. Here’s what is covered in this on-demand masterclass:

  • What has changed since the rule was first issued and then suspended

    BIS’s current enforcement posture and what the geopolitical environment means for when enforcement actually lands.

  • How the 50% rule actually works in practice

    Aggregate ownership thresholds, direct vs. indirect control, MEU extension risk, and the new Red Flag 29 requiring documented ownership investigation.

  • Real case studies from Sayari’s BIS50 analysis

    Nested Chinese subsidiary networks, European companies majority-owned by Entity List parties, and MEU-linked structures that would not be identified by any name-based or address-based screening approach.

  • Best practices for building an ownership-based screening program

    From initial gap assessment through repeatable, documented workflows — with concrete steps for trade compliance teams at companies of every size. BIS’s rule reflects a dramatic shift in more than just Entity List screening.

  • How Sayari solves BIS50 and related due diligence requirements

    A product demonstration of automated ownership risk identification across multi-tier corporate structures, drawing on more than 11 billion corporate and trade records and precomputed aggregate ownership risk.

Who Should Watch

Built for trade compliance and export control teams

  • Trade Compliance Officers and Export Control Managers

  • Chief Compliance Officers and Legal Counsel with export controls responsibility

  • Supply Chain Risk and Procurement leaders at companies with China, Russia, or dual-use exposure

  • Technology and semiconductor companies subject to EAR end-user controls

  • Financial institutions and service providers supporting international trade transactions

  • Government contractors and defense industrial base participants with BIS MEU obligations

Frequently Asked Questions

Everything you need to know

Common questions about the BIS Affiliates Rule, the November 10 snapback, and what compliance programs need to do now.

What is the BIS 50% Affiliates Rule?
When does the BIS Affiliates Rule take effect?
What is Red Flag 29 and why does it matter?
What’s the difference between direct, indirect, and aggregate ownership?
How does the rule extend MEU List restrictions?
How does Sayari help compliance teams prepare for BIS50?
Is this masterclass free to watch?

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The clock to November 10 is running.

See how Sayari helps trade compliance teams build a defensible ownership-based screening program before the BIS Affiliates Rule snaps back into force.