Regulation

Managing the BIS Affiliates Rule: challenges and solutions

Issue 57
October 2025

Author
Elizabeth ShinglerSteven BrothertonTom Hickey
+ About author

Elizabeth Shingler (Richmond) is a Senior Manager in the Global Export Controls and Sanctions practice of KPMG LLP. eshingler@kpmg.com

Steven Brotherton (San Francisco) is a Principal in the Global Export Controls & Sanctions practice of KPMG LLP and leader of the service line. sbrotherton@kpmg.com

Tom Hickey (thickey1@kpmg.com) is a Managing Director in the Trade & Customs Services practice of KPMG LLP and a member of the Global Export Controls & Sanctions service line; he is based in Chicago.

KPMG: SMART PRACTICE
The Bureau of Industry and Security’s (“BIS”) recently released Affiliates Rule has added another layer of complexity to a dynamic environment. The Affiliates Rule mirrors the Office of Foreign Assets Control (“OFAC”) 50% Rule wherein a company that is 50% owned, directly or indirectly, by a sanctioned party is itself sanctioned. The Affiliates Rule provides that an entity owned, directly or indirectly, 50% or more by one or more entities included on the Entity List, Militar...

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