On October 30, 2025, the White House suspended the implementation of the BIS 50% rule titled Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities for one year, starting on November 10, 2025. This delay is due to a reciprocal agreement with China. The rule would have extended export-licensing requirements to companies' majority-owned by parties on the Entity List, Military End-User List, or certain OFAC Specially Designated Nationals. The delay in implementation of this rule has generated a mixed reaction from the export industry.
On one hand, a substantial number of exporters and countries have already spent significant time ensuring they have processes in place to be compliant with the rules. Conversely, others are pleased that they now have ample time to ensure full compliance. This postponement, however, doesn't remove the core challenge: companies must conduct due diligence on foreign ownership of business partners.
With nuances to foreign ownership and a lack of reliable resources for recording such information, many in the industry are scrambling to build processes to comply with such a rule. Businesses previously relied on tools such as the International Trade Administration’s consolidated screening list, but since the rule took effect, standalone screening tools are no longer sufficient to maintain compliance.
Need support navigating the new rule?
As part of our long-standing service offerings, Tradewin delivers in-depth party vetting and denied party screening services that make compliance effortless. Our sister company Tradeflow, in partnership with Kharon, is preparing for this increased complexity by adding the BIS 50% as part of the Enhanced Denied Party Screening as an additional tier to their current offering. By storing trade partners with Tradeflow, users will be able to receive automated screening of their trade partners list and vet for 50%+ ownership by a denied party.
From entity screening to ownership research, our solutions are built to adapt as regulations change. Tradewin helps you manage complexity with confidence, so you can stay focused on your business. Contact us to learn more.
