New Rules Snag Affiliates of Sanctioned Entities in Export Web
Published Date: 9/30/2025
Rule
Summary
If a company is half or more owned by a business on the Entity List or by certain military or sanctioned groups, it now faces the same export rules as those listed companies. This change helps stop tricky business moves that try to dodge restrictions. The new rules kick in right away and aim to keep things fair without making businesses jump through extra hoops.
Analyzed Economic Effects
3 provisions identified: 0 benefits, 3 costs, 0 mixed.
Half‑Owned by Entity‑Listed Firms
If a company is at least 50 percent owned by one or more companies on the Commerce Department’s Entity List, that company will automatically be subject to the same Entity List export restrictions. That means the half‑owned firm faces the same export controls and licensing limits as the listed companies.
Half‑Owned by Listed Military End Users
If a company is at least 50 percent owned by one or more entities identified as listed "military end users," that company will automatically face the same Entity List restrictions. The 50 percent ownership threshold is the trigger for applying those export controls.
Half‑Owned by Sanctioned Parties
If a company is at least 50 percent owned by certain sanctioned parties, it will automatically be subject to Entity List restrictions under this rule. The rule uses a 50 percent ownership standard to determine when the sanctions‑related export controls apply.
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