How aggregated ownership screening protects high-security facilities from inadvertent violations, and how to implement it without slowing operations.
Update
November 10, 2025
BIS Affiliates Rule Postponed: The 50% rule enforcement is paused for one year after the Trump–Xi summit. The pause is active now, but the rule is expected to snap back on November 10, 2026.
By default, SecurePoint USA calculates OFAC 50% ownership in shadow mode: the result is recorded but does not change the screening decision. BIS 50% affiliate rule enforcement is paused until November 2026. Until then, ownership screening continues with escalation workflows.
BIS stayed the Affiliates Rule for one year starting November 10, 2025 after the U.S.–China trade summit.
Expect the Affiliates Rule to resume on November 10, 2026; use the pause to harden ownership workflows.
Even during the pause, teams must resolve Red Flag 29 scenarios and keep Entity/MEU ownership look-through.
Previous Alert
BIS aligned with OFAC’s long-standing 50% rule, applying Entity List and MEU List restrictions to majority-owned foreign affiliates. A temporary general license (TGL) through November 28, 2025 provides time to map ownership, shore up controls, and seek required licenses before the rule restarts.
Any entity 50%+ owned (directly or indirectly) by Entity List or MEU List parties inherits their restrictions.
A 60-day TGL (through Nov 28, 2025) lets exporters assess affiliates, gather attestations, and file licenses.
Exporters now have explicit duty to resolve ownership uncertainty; unresolved cases need a BIS license.
OFAC's 50 Percent Rule treats any entity owned 50% or more by one or more Specially Designated Nationals as blocked, even if the entity isn't listed. BIS extends the same logic to Entity List and MEU List ownership (currently postponed until November 2026).
"If Person A (blocked) owns 30% and Person B (blocked) owns 25%, the entity is 55% blocked and must be treated as sanctioned."
Three non-negotiable requirements for compliance
Spot when multiple listed parties collectively cross 50%, even if no single owner holds a majority.
Trace two-hop subsidiaries and shell structures that inherit Entity List or MEU status.
Document every ownership lookup, escalation, and license decision for a BIS review.
Built for high-security environments where speed and accuracy must coexist.
Where ownership records exist, calculate whether blocked persons own 50% or more of a vendor. Results run in shadow mode by default.
Decision-makers see applied thresholds, diagrams, and evidence without leaving the queue.
Screen against the BIS Entity List. Denied Persons List screening is available when enabled. There is no buyer-facing Entity List versus MEU toggle.
Workforce and vendor re-screens run on a daily schedule against the lists you run. Ownership-change monitoring is not a live scheduled control.
Four steps to put the 50% Rule into practice
Capture visitor and company legal names at check-in or vendor onboarding.
Request attestations or registry docs for high-risk affiliates; map at least two ownership layers.
Escalate unresolved Red Flag 29 cases for license evaluation or hold decisions.
Generate evidence packs from visit, screening, and decision records.
Regulatory violations carry severe penalties: civil penalties under IEEPA (50 U.S.C. 1705) are inflation-adjusted and can also be twice the transaction amount. Criminal exposure and loss of facility access can follow.
Reputational damage compounds: failed audits can trigger contract reviews, clearance investigations, and stakeholder scrutiny.
Operational efficiency matters: SecurePoint USA automates complex ownership analysis so throughput stays high even under BIS scrutiny.
Schedule a demo to see how SecurePoint USA handles complex ownership structures in real time, without adding friction to your check-in process.
A short checklist to keep visitor and vendor screening evidence in order while the Affiliates Rule stay remains in effect.
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