The Affiliates Rule is Back. Is Your Program Ready?
The BIS Affiliates Rule snapback is set for November 10, 2026. In this practitioners’ session, lead analysts at Sayari walk through what has changed since the rule’s suspension, and how to build a defensible ownership-based screening program now — before the rule snaps back into force.
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.
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.
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
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 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.