Overview

• Effective immediately, the interim “Affiliates Rule” applies Entity List and Military End‑User restrictions to any foreign entity 50% or more owned, directly or indirectly and in aggregate, by listed parties, with specified SDN programs also covered under EAR § 744.8.
• A Temporary General License permits limited transactions involving newly covered affiliates through November 28, 2025, including certain dealings in Country Groups A:5 and A:6 and defined joint ventures, with SDN‑captured affiliates excluded from this relief.
• BIS introduced Red Flag 29, requiring exporters to resolve ownership uncertainty when listed owners are known; if ownership percentages cannot be confirmed, a BIS license is required unless a license exception applies.
• The Consolidated Screening List will not capture all newly covered affiliates, so firms must add ownership‑based diligence, aggregation analysis, and continuous monitoring to mitigate strict‑liability risk.
• The rule excludes the Unverified List and Denial Orders, applies a most‑restrictive licensing posture when multiple listed owners exist, allows case‑by‑case exclusions via the ERC, and is open for public comment until October 29, 2025.