Regulatory  ·  2026-11-07

BIS extends suspension of the Affiliates Rule (50% rule) to 10 Jan 2027

RegulatoryMedium impactUnited States
The Bureau of Industry and Security filed plans (reported 5 Nov, notice due in the Federal Register) to extend the one-year suspension of the Affiliates Rule — the "50% rule" that would extend US export controls to entities majority-owned by parties on the BIS Entity List, Military End-User List, or certain sanctions lists — through 10 Jan 2027. The suspension had been scheduled to expire around 9-10 Nov 2026; the two-month extension follows a China trade deal and ongoing bilateral negotiations, and was signalled by Treasury Secretary Bessent in September.
The Affiliates Rule materially expands the footprint of US export controls over advanced AI chips and technology by reaching foreign subsidiaries of restricted parties; extending the suspension gives exporters temporary relief but keeps an active compliance risk for AI supply chains (chip and advanced-compute diversion).
Monitor the pending Federal Register notice; maintain ownership-structure and restricted-party screening for affiliates in case the rule takes effect in January 2027.
Kharon: BIS extends Affiliates Rule suspensionGibson Dunn: Export controls update (4 Nov 2026)
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