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BIS 50 Rule Update

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.

Wednesday, May 20, 2026 · 11am EDT
Free
Hosted by: Sayari Lead Analysts & BIS50 Research Team
Masterclass Registration
Reserve your free seat for May 20th

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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 snap into force, extending Entity List and Military End-User 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.

On May 20th at 11am EDT, lead analysts at Sayari will cover what’s changed, and how compliance teams can build a defensible ownership-based screening program now — before BIS’s rule comes into effect.

BIS 50% Affiliates Rule

Extends Entity List and MEU List restrictions to any company majority-owned (directly, indirectly, or in aggregate) by a listed entity. Suspended for one year; snaps back into force November 10, 2026.

Entity List + MEU Extension

The Entity List and Military End-User List 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 we’ll cover on May 20th:

01 — What Changed

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.

02 — The Mechanics

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.

03 — Case Studies

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.

04 — Program Design

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.

05 — Live Demo

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 Attend

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.

The BIS 50% Affiliates Rule extends Entity List and Military End-User (MEU) List restrictions to any company that is majority-owned — directly, indirectly, or in aggregate — by one or more listed entities. In practice, this means a company can be subject to U.S. export controls even if it does not appear on any list itself, as long as listed parties together hold a controlling ownership stake. The rule was suspended for one year and is set to snap back into force on November 10, 2026.
November 10, 2026, unless Congress acts first to codify it into law before then. After that date, exporters, reexporters, and U.S. persons cannot rely on a name-only check against the Entity List or MEU List — they must also identify majority-owned subsidiaries and aggregate-owned affiliates of listed entities.
Red Flag 29 is the new BIS red flag indicating that a transaction may involve an entity majority-owned by a listed party. It establishes the expectation that compliance programs document a meaningful ownership investigation — not just confirm that a counterparty’s name does not appear on a published list. Programs that cannot show evidence of ownership-based diligence will struggle to defend the standard of care BIS now expects.
Direct ownership is when a listed party holds a controlling stake in a company outright. Indirect ownership is when a listed party controls a company through one or more intermediate holding entities — the chain of corporate layers between the listed party and the operating entity. Aggregate ownership is when two or more listed parties together hold a majority stake, even if no single listed party controls the company on its own. The BIS 50% rule applies to all three, which is why name-based and even single-tier ownership screening miss the bulk of the restricted universe.
The 50% rule extends MEU List restrictions through ownership the same way it extends Entity List restrictions. A company that is majority-owned — directly, indirectly, or in aggregate — by one or more MEU-listed parties inherits the EAR end-user controls applied to those parties. This significantly expands the universe of entities to which dual-use end-user controls apply, particularly across multi-tier corporate structures involving Russian and Chinese state-affiliated networks.
Sayari precomputes aggregate ownership risk across multiple corporate layers, automatically surfacing entities majority-owned by Entity List and MEU List companies. Drawing on more than 11 billion corporate and trade records, Sayari resolves ownership across more than six hops of corporate structure — identifying restricted entities that name-based or address-based screening cannot reach. The session includes a live demonstration of how this works in practice, plus the full BIS50 analytical methodology behind it.
Yes. Registration is free for the live session on Wednesday, May 20th at 11am EDT. All registrants receive on-demand access to the full recording within 24 hours of the event, also at no cost.

The clock to November 10 is running.

Join Sayari on May 20th for a practitioner session on what has changed since the BIS Affiliates Rule was suspended, and how to build a defensible ownership-based screening program before the rule comes back into force.

Register Free — May 20 Request a Sayari Demo →