BIS Expands Entity List Controls to Cover Affiliates of Listed Parties
On September 30, 2025, the Bureau of Industry and Security (“BIS”) issued an interim final rule (“IFR”) that significantly revises the scope of the Export Administration Regulations (“EAR”) by extending Entity List restrictions to cover affiliates of listed parties. Effective on the date of filing for public inspection, the IFR abandons the longstanding “legally distinct” standard, under which only entities expressly enumerated on the Entity...
