The BIS 50% rule: where it stands and what to check

By VetLane HQ, export screening for component distributors · Last reviewed 19 October 2026 against the official sources cited

For years, a company owned by a party on the BIS Entity List was not itself restricted unless it was listed too. The BIS "Affiliates Rule", often called the 50% rule, changes that. It was published in September 2025, then suspended for a year. Here is what it says, where it stands, and what to check about your customers' owners.

What the rule says

The interim final rule published by BIS on 30 September 2025 extends Entity List restrictions to companies owned 50% or more by one or more listed entities, directly or indirectly, individually or in aggregate. It extends the restrictions of the Military End-User List in the same way, and covers certain parties sanctioned by OFAC. In practice, an unlisted subsidiary of a listed company would carry the same licence requirements as its parent.

Where it stands

When we reviewed this guide on 19 October 2026, no extension of the suspension had been published in the Federal Register. Check the Federal Register before relying on either outcome; we will update this page when the status changes.

What does not change during the suspension

• Entity List parties themselves remain restricted: screening names and addresses is as necessary as before. See what happens if a freight forwarder is on the Entity List.
• OFAC's own 50 percent rule keeps applying: a company owned 50% or more by blocked persons is itself blocked, listed or not. See the glossary entry.
• BIS guidance still treats unclear ownership and a link to a listed party as warning signs of diversion.

How to prepare: checking who owns your customers

1. Start with your customers for US-origin parts, and among them those in countries with many Entity List parties and those buying CHPL items.
2. Collect ownership information: public registers where they exist (the UK register of people with significant control, the GLEIF register of legal entity identifiers), and a declaration of shareholders from the customer when registers say nothing.
3. Add up the shares held by listed parties, directly and through other companies: the threshold is 50% in aggregate, not per owner.
4. Record what you found and what you could not find. "Ownership not available from public sources, declaration requested on this date" is a defensible note; silence is not.
5. Repeat when the lists change, because a new listing of a parent catches its subsidiaries at once.

VetLane's Pro plan reads the direct and ultimate parents of your customers in the GLEIF register and screens those parents against the official lists. GLEIF records accounting consolidation, not exact shares, so the result says what is known and which customers it could not cover; it never concludes that a customer is not owned by a listed party. See customer and destination screening.

Official sources

• Federal Register, 30 September 2025: Expansion of End-User Controls To Cover Affiliates of Certain Listed Entities
• Federal Register, 12 November 2025: One Year Suspension of Expansion of End-User Controls for Affiliates of Certain Listed Entities
• OFAC: frequently asked questions on entities owned by blocked persons

This guide explains public rules and guidance as of its review date. It is not legal advice; for a specific transaction, speak to an export control lawyer.