Export Controls Watch · Issue 1

November 2026: BIS 50% rule, EU and UK Russia listings, Mahan Airways order

BIS published no Entity List additions in October 2026. The month's actions focused on suppliers and diversion routes: the EU's largest set of Russia listings since 2022, a UK package aimed at suppliers of Common High Priority goods, and a renewed BIS denial order with parties in Dubai, Istanbul and Paris. In November, the BIS 50% rule is scheduled to apply again on 10 November unless BIS extends its suspension.

Published
2 Nov 2026
Covers
October 2026
By
Olivier Durnez, VetLane

Information, not legal advice. Each item summarises an official publication and links to it. The official text prevails over our summary.

October 2026

EU List update

EU Russia sanctions: 826 companies and 743 executives listed on 12 October

Status
In force
Effective
12 Oct 2026
Last checked
1 Nov 2026

What changed. On 12 October 2026, the EU added 826 entities and 743 persons to Annex I of Regulation (EU) No 269/2014, the Russia asset-freeze list. The Council says the companies appear on a list drawn up by the Russian government of firms belonging to its military-industrial complex, and that they supply key components, including electronics such as semiconductors, microcircuits and computers.

For a distributor. This means many Russian buyers of electronic components, including mid-sized suppliers that are not known as defense contractors, are now under an EU asset freeze. Making funds or goods available to them, directly or through an intermediary, is prohibited for EU persons.

Sources: Official Journal of the EU, Council Implementing Regulation (EU) 2026/2281, 12 Oct 2026 · Council of the EU, press release, 12 Oct 2026

In VetLane: covered

Screened in VetLane: EU Consolidated Financial Sanctions List (version of 2026-10-23).

UK List update

UK Russia sanctions: 38 additions on 8 October, including 17 CHP goods suppliers

Status
In force
Effective
8 Oct 2026
Last checked
1 Nov 2026

What changed. On 8 October 2026, the UK added 38 entries to the UK Sanctions List under the Russia regime: 26 persons and entities, and 12 ships. The UK government says 17 of them are involved in supplying Common High Priority (CHP) goods, including Russia-based importers of machine tools and electronics. New entries include companies with addresses in China, Turkey, Thailand and Kyrgyzstan.

For a distributor. This means a buyer or forwarder outside Russia, for example in China or Turkey, can be on the UK list for supplying CHP goods to Russia. A non-Russian address on an order does not show that the party is unlisted.

Sources: GOV.UK, Sanctions Notice, Russia, 8 October 2026 (FCDO) · GOV.UK, FCDO press release, 8 October 2026

In VetLane: covered

Screened in VetLane: UK Sanctions List (version of 2026-10-30).

US List update

BIS renews Mahan Airways denial order, with parties in Dubai, Istanbul and Paris

Status
In force
Effective
22 Oct 2026
Last checked
1 Nov 2026

What changed. On 22 October 2026, BIS renewed for one year its temporary denial order against Mahan Airways and 11 other parties, published in the Federal Register on 27 October. Named parties have addresses in Iran, the UAE, Turkey, Iraq, Jordan, Saudi Arabia, Syria, Lebanon, the UK and France. The order cites a May 2024 BIS check that found electronic components, including Tier 1 Common High Priority items, diverted to Russia via Iran aboard Mahan aircraft.

For a distributor. This means no person may export, reexport or transfer items subject to the EAR to or on behalf of these parties. Trading companies in Dubai and an office in Istanbul are among the named parties.

Source: Federal Register, 91 FR 67542, 27 Oct 2026 (FR Doc. 2026-21840)

In VetLane: covered

Screened in VetLane: Consolidated Screening List (version of 2026-11-02).

US Enforcement

BIS penalty: $2 million against Lambda Research for EAR99 software to Entity List parties

Status
Announced
Announced
2 Oct 2026
Last checked
1 Nov 2026

What changed. On 2 October 2026, BIS announced a settlement with Lambda Research Corporation (Massachusetts) covering 66 alleged violations from 2021 to 2025. They include licenses and automatic updates of EAR99 software for Huawei Technologies Japan, partly through a distributor in Japan, and for Shenzhen SiCarrier, both on the Entity List. The $2,000,000 civil penalty is suspended for one year, on conditions that include training and an audit.

For a distributor. This shows that EAR99 items still need a license when the buyer is on the Entity List, including updates sent after the buyer was listed. SiCarrier was listed on 2 December 2024, after the first sales.

Sources: BIS press release, 2 Oct 2026 · BIS, Lambda Research Corporation settlement agreement and proposed charging letter

In VetLane: covered

Screened in VetLane: Consolidated Screening List (version of 2026-11-02).

Coming up in November

US Rule

BIS 50% rule: scheduled to apply again from 10 November unless extended

Status
Scheduled
Effective
10 Nov 2026
Last checked
2 Nov 2026

What changed. The BIS Affiliates rule extends Entity List and Military End-User List restrictions to companies owned 50% or more by one or more listed parties. BIS suspended it from 10 November 2025; the suspension is set to end on 9 November 2026 "absent a future extension." As of 2 November 2026, no extension had been published, so the rule is scheduled to apply again from 10 November 2026.

For a distributor. Unless the suspension is extended, this means a buyer that is named on no list can still be restricted because of who owns it. Checking names alone does not show that.

Sources: Federal Register, 90 FR 47201, 30 Sep 2025 (Affiliates rule) · Federal Register, 90 FR 50857, 12 Nov 2025 (one-year suspension)

In VetLane: partly covered

Screened in VetLane: Consolidated Screening List (version of 2026-11-02). Ownership is shown only for companies with a public LEI, from GLEIF consolidation data, not exact percentages.

Corrections

No correction to this issue. If you spot an error, write to olivier@vetlanehq.com: we correct it here, with the date.

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