Just one month after the Bureau of Industry and Security (BIS) announced its long-awaited 50% / Affiliates Rule, the U.S. suspended the regulation for one year as part of a trade agreement with the PRC. This allows the export of critical technology and semiconductors to subsidiaries of entities on the BIS Entity List and Military End-User (MEU) List to resume.
In this turbulent geopolitical climate, rapid regulatory shifts are becoming more commonplace, and industry has no choice but to respond. Unfortunately, for most organizations, this is not an agile process.
Best practice for updating a corporate compliance program can take months. First, organizations must understand the regulation and how it applies to them. Then, they must audit their compliance programs for vulnerabilities and data gaps. If filling those gaps necessitates a new data provider, the procurement process varies in length depending on the organization’s size and complexity. Only after finding and contracting a vendor can they finally screen third parties for new risks.
In today’s volatile political environment, organizations cannot afford to go through this process every time the regulatory winds change. It takes too long, leaving the organization exposed to enforcement risk and playing a perpetual game of catchup.
Organizations should strive to build compliance infrastructure that anticipates change. What industry needs now more than ever is a data provider that proactively prepares for regulatory shifts on their behalf. For Sayari, this means taking a comprehensive approach to data curation while investing in time-saving tools.
Helping customers navigate uncertainty by balancing data depth with speedy time-to-insight has been a priority since the beginning. From experience, the analysts who guided Sayari’s early product development knew more context was better — if it could be quickly and easily retrieved.
Sayari harvests as much data as possible to ensure users have as complete a picture as possible, while still saving time through automated screening and diligence workflows. Having followed this guiding principle for over a decade, Sayari is uniquely positioned to help corporate enterprises navigate today’s unpredictable regulatory landscape.
Sayari data includes:
- Not just corporate data: also trade data, watchlist data, financial data, risk intelligence, geospatial data…and the list keeps growing.
Corporate records form the backbone of Sayari’s data solution, and enriching these with a wide variety of other data types provides an unparalleled depth of perspective. Fusing these layers into a single pane of glass — a global knowledge graph — reduces the amount of time compliance professionals spend gathering, collating, and sharing different types of data from disparate sources, making the information faster to analyze and act upon.
- Not just identifying information: also contextual information, including related individuals, beneficial owners, trade partners, shipments, assets, and more.
Basic watchlist screening is no longer enough. Regulators are increasingly enacting typological controls — regulations that restrict entities based on their high-risk characteristics rather than name.
The BIS 50% Rule is a perfect example. Without a government-published list of risky affiliates, organizations need access to ownership information to screen for unlisted entities subject to Entity List restrictions.
By offering as much context as possible, Sayari helps industry prepare for future typological mandates.
- Not just entities of concern: all entities. Instead of focusing only on watchlisted entities and their associates, Sayari ingests entire corporate registries. This enables companies to confidently whitelist entities. It also, crucially, prepares organizations for rapid regulatory swings that shift entities into and out of enforcement focus.
- Not just current-state data: historical data. Sayari harvests and stores data going as far back as possible, providing more complete information than corporate registries themselves, some of which erase information as soon as it becomes obsolete.
This historical view helps identify entities that have updated their public profiles in an effort to evade regulatory restrictions.
For example, some Chinese companies have independently chosen to obscure or remove explicit references to MCF (military-civil fusion) in their public-facing information and some corporate records to minimize international scrutiny and potential sanctions. Enterprises concerned about military end users and foreign ownership, control, or influence (FOCI) greatly value the ability to identify such companies based on historical data.
Our flexible data foundation allowed Sayari to be first to market with its BIS50 Signal Screening Solution this past June. Since then, the solution has been used by scores of Forbes Global 2000 customers around the world to efficiently and effectively uncover the thousands of majority-owned subsidiaries that traditional screening lists do not capture.
While the rule is suspended through November 9, 2026, reinstatement or new changes could happen at any time. Corporations should continue to track affiliate risk to stay prepared.
To learn more about how Sayari can help your organization respond to the next regulatory shift, request a free, personalized demo.
