Overview

• The interim rule is already in effect and applies EAR license restrictions to foreign entities 50% or more owned, directly or indirectly and in the aggregate, by Entity List or MEU List parties and certain SDNs, with strict-liability exposure and a new Red Flag 29 requiring ownership checks.
• New FAQs clarify that control alone does not trigger coverage without 50% ownership, while foreign branches and offices of listed entities now share the listed entity’s license requirements.
• BIS stresses that screening the Consolidated Screening List is insufficient, so exporters must separately assess ownership links and may rely on private screening resources.
• A limited Temporary General License allows certain transactions during a short transition, with reports citing expiration on November 28 or December 1, 2025, and BIS is accepting public comments through October 29, 2025.
• BIS highlights General Prohibition 10 for cases involving fronts or shell companies even when the 50% threshold is not met, and it outlines what information to include when seeking a license if ownership cannot be fully determined.