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U.S. Extends Export Curbs to Subsidiaries of Blacklisted Firms With 50% Rule

BIS targets affiliate workarounds by imposing licensing on majority-owned units with most applications expected to be denied.

Overview

  • The rule automatically applies Entity List and Military End-User restrictions to any entity at least 50 percent owned by a listed company.
  • Exporters must treat significant minority ownership by listed entities as a red flag that triggers enhanced due diligence.
  • The restrictions take effect 60 days after publication in the Federal Register.
  • Analysts say the change could pull thousands of subsidiaries in nearly 100 countries into U.S. scrutiny, affecting sectors such as aircraft, semiconductors and medical equipment.
  • China’s Commerce Ministry condemned the action as extremely egregious, and trade lawyers warned companies may restructure to evade the controls.