
Beyond the Name: Operationalizing BIS’s “Affiliates Rule” with Kharon + e2open
As of September 29, 2025, the Bureau of Industry and Security’s (BIS) interim final rule treats any foreign entity that is 50% or more owned - directly, indirectly, or in aggregate - by parties on the Entity List or MEU List, or by select Specially Designated Nationals (SDNs), as though it were listed itself. This...