On October 30, 2025, US Secretary of Treasury Scott Bessent announced that the United States will pause enforcement of the US Department of Commerce Bureau of Industry and Security’s (“BIS”) “Affiliates Rule” for one year. The rule was set to impose certain end user licensing requirements and restrictions under the Export Administration Regulations to unlisted foreign affiliates owned 50% or more by one or more entities on any of the Entity List, Military End-User List, or Specially Designated Nationals blocked under certain US sanctions programs. Our previous blog post on the introduction of the Affiliates Rule is here.
As of now, there has been no formal announcement or publication in the Federal Register suspending this rule, nor an official date on when enforcement of the Affiliates Rule will resume. Although enforcement is paused for the time being, companies should continue to assess their supply chains and foreign partners impacted by the Affiliates Rule in order to minimize exposure to enforcement actions once, or if, the Affiliates Rule is reinstated.
The authors acknowledge the assistance of Ryan Orange in the preparation of this blog post.
