BIS 50 percent rule
Automated ownership aggregation for entity-based export controls. Stayed by BIS, with resumption scheduled for November 2026.
What the rule requires
Rule status: suspended, scheduled to take effect November 10, 2026
The BIS Affiliates Rule is suspended through November 9, 2026 and is scheduled to take effect November 10, 2026 absent further BIS action (BIS final rule, FR 2025-19846, staying the interim final rule at 90 FR 47201). While the stay holds it is not operative under the EAR. SecurePoint escalates BIS affiliate ownership signals to documented human review on every date, and does not start blocking them automatically when a scheduled date arrives. OFAC’s 50% Rule is in force today. Verify current status at bis.doc.gov.
Ownership aggregation across sanctioned or restricted entities
The BIS 50 percent rule requires aggregating direct and indirect ownership interests across multiple entities. If a sanctioned or restricted entity owns 50 percent or more (directly or indirectly) of another entity, that entity is also subject to the same restrictions.
Indirect ownership triggering restrictions
Ownership chains must be traced through multiple levels. A company may be restricted even if no direct ownership exists, if the aggregate indirect ownership meets the 50 percent threshold. This includes ownership through subsidiaries, affiliates, and intermediate holding companies.
Ongoing monitoring
Ownership structures change over time. Continuous monitoring is required to detect when ownership percentages cross the 50 percent threshold, triggering new restrictions or lifting existing ones.
How SecurePoint implements it
Ownership aggregation in screening
Automated ownership chain analysis during sanctions screening. SecurePoint aggregates direct and indirect ownership percentages to determine if the 50 percent threshold is met. Real-time calculations based on current BIS entity list data. BIS affiliate signals are escalated for documented compliance review. SecurePoint does not start blocking them automatically when the rule’s scheduled November 10, 2026 date arrives.
Affiliate detection
Automatic identification of affiliated entities and subsidiaries based on ownership relationships. Multi-level ownership chains are traced to identify all entities subject to restrictions under the 50 percent rule.
Escalation by default during postponement period
While the rule is postponed, when BIS affiliate hits are detected, cases automatically escalate to senior reviewers. Configurable escalation rules route high-risk ownership relationships before making access decisions. Full automated enforcement will resume in November 2026.
Full audit visibility
Every ownership aggregation calculation, affiliate detection, and escalation decision is logged in append-only audit trails. Complete transparency for export control reviews and BIS compliance audits.
Where it is used
Vendor checks
Screen suppliers, contractors, and business partners against BIS entity lists with ownership aggregation. Identify restricted entities even when direct ownership is not apparent.
Foreign visitors
Check foreign nationals and their associated companies against BIS restrictions. Aggregate ownership is resolved rather than assumed, so an entity that is not listed by name but is owned by listed persons still reaches a reviewer.
Pre-contract due diligence
Screen potential partners and contractors before entering agreements. Ownership aggregation helps identify restricted entities early in the procurement process.
Frequently asked questions
What is the BIS 50 percent rule?
It extends Entity List restrictions to entities that listed parties own in aggregate at or above fifty percent, even when the entity itself is not named on a list. Verify the current status, scope and effective date against bis.doc.gov before relying on any summary, including this one.
Why is name-only screening not enough?
Because an unlisted subsidiary of a listed parent will not match by name. Resolving ownership is what surfaces it. It is also why a consolidated screening list is a screening aid rather than a complete answer on restricted parties.
Does SecurePoint block a visit on a BIS affiliate match?
No. BIS affiliate matches escalate to documented human review rather than blocking. Ownership traversal runs in a monitoring capacity; sanctions and restricted-party screening are the controls that gate access.
How is aggregate ownership resolved?
Beneficial ownership chains are traced using GLEIF LEI relationship records and curated open-ownership data, and aggregate sanctioned ownership is calculated with the chain documented alongside the result. Coverage depends on what those sources hold for a given entity, so a clean result is not proof of clean ownership.
Does SecurePoint tell us whether we need a license?
No. License determinations depend on the item, the technology, the destination and the end use. Screening tells you that a party matches and routes it to a reviewer. The determination belongs with your export-control officer or trade counsel.
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BIS resumption is scheduled for November 2026. Prepare now.
Read the beta announcement to learn what is included.