Overview
Jack Hayes authored an article for Export Compliance Manager titled "BIS Expands Export Controls to Cover Affiliates of Listed Entities." The October 2025 article explains the US Department of Commerce’s interim final rule imposing new restrictions on foreign entities owned 50% or more by parties on the Entity List, Military End-User List, or OFAC's SDN List. The rule automatically subjects these "Affiliates" to the most restrictive licensing requirements and introduces changes to foreign direct product rules, red flag guidance, and a temporary general license.
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