BIS Suspends Affiliates Rule Until January 10, 2027

November 6, 2026

Today, the U.S. Department of Commerce's Bureau of Industry and Security ("BIS") announced that it would extend the suspension of its "Affiliates Rule" until January 10, 2027.  The suspension was set to expire on November 9, 2026.

The Affiliates Rule would extend restrictions on a foreign entity included on the BIS Entity List and related restriction lists (a "Listed Person") to the foreign entities in which the Listed Person owns at least a 50% interest.  The original suspension came amid industry feedback and retaliatory Chinese export control measures, factors that will continue to be relevant as the new suspension period progresses.

For now, the renewed suspension maintains the status quo: The Affiliates Rule remains suspended but could come into effect at a later date.  If reinstated, the Affiliates Rule would extend existing export controls restrictions to a new wave of entities affiliated with Listed Persons, posing heightened compliance and reputational-risk considerations for businesses engaged in the export of items subject to U.S. controls.

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