The New BIS 50% Rule: Hidden Exposure Across Global Supply Chains
Last month, the U.S. Department of Commerce issued a sweeping expansion to its export-control regime: the BIS 50% Rule. Any company owned 50 percent or more, individually or in aggregate, by one or more parties on the BIS Entity List is now automatically subject to the same export restrictions as its parent.
This creates a global compliance challenge: Exiger analysis of thousands of entities shows that many newly listed affiliates operate not just in China or Russia, but also in Europe and other major trading centers. The rule has quickly redrawn export compliance. Even legitimate transactions with seemingly low-risk partners may now trigger licensing requirements or violations — with civil penalties in the millions and potential criminal liability.
Join Exiger, CNAS, and KPMG export compliance experts to unpack the BIS 50% Rule and what it means for you, including:
- The expansion of the Entity List to address 50% ownership and where it will evolve next
- How the BIS 50% Rule differs from OFAC’s sanctions framework, and why that distinction matters
- Why thousands of subsidiaries across Europe and Asia are now automatically restricted, even if they don’t appear on any list
- When you need to watch for retroactive exposure if existing customers or suppliers are newly captured under the rule
- Where technology and affiliate-mapping data can identify hidden ownership structures before they cause costly violations for your company
Moderated by Exiger Senior Vice President of Risk & Compliance Kit Conklin, whose past experience includes advising Congress on supply chain risks, sanctions, and international trade as Senior Advisor to the U.S. House Select Committee on China.
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