Regulation

BIS expands export controls to cover affiliates of listed entities

Issue 57
October 2025

Author
Jack R. HayesRyan Pereira
+ About author

Jack Hayes is a Partner at Steptoe LLP, focusing on US export controls and sanctions, including the ITAR. www.steptoe.com

Ryan Pereira is an Associate in the Washington, DC office of Steptoe. www.steptoe.com

STEPTOE: OUTSIDE COUNSEL
On September 30, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) promulgated an interim final rule (“IFR”), effective immediately, imposing new restrictions on foreign entities that are owned, directly or indirectly, individually or in the aggregate, 50% or greater by one or more entities on the Entity List or the Military End-User (“MEU”) List.1 BIS refers to such entities as “Affiliates” for the purpose of the IFR. Under the IFR, Affilia...

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