BIS “Affiliates Rule” Postponed for One Year
November 16, 2025 1 Comment
A month ago, we reported on the new BIS “Affiliates Rule” that extends a company’s sanctions to any subsidiary business that subject to 50% or more ownership by the sanctioned company. That rule became effective on September 29, 2025, but its implementation is already being postponed!
On November 12, BIS announced that it would be delaying the effective date of the Affiliates Rule for one year:
“This rule will be implemented in two phases. The first phase, effective on November 10, 2025, and ending November 9, 2026, is a one-year suspension of the Affiliates Rule. BIS is temporarily suspending all changes previously made to the EAR by the Affiliates Rule during this period. In the second phase of this final rule, effective November 10, 2026 and extending indefinitely, the changes included in the Affiliates Rule that are removed in the first stage will be added back into the EAR.”
Remember – OFAC policy still extend sanctions to 50%-owned subsidiaries of OFAC-sanctioned companies.
About Jason Dickstein
Pingback: New BIS Sanctions Rule Expands Obligations for Exporters