Expert Q&A: The BIS 50% / Affiliates Rule with Kharon and Gibson Dunn
Recorded on Monday, October 27, 2025
There has been no shortage of webinars, articles, and legal alerts examining the new BIS 50% / Affiliates Rule, and for good reason. The rule reshapes how organizations assess ownership as it relates to export controls compliance.
Listen to Kharon and Gibson Dunn's "Ask Us Anything" session featuring leading experts on the Rule, including former BIS leaders, seasoned legal practitioners, and technical subject matter experts. We address the questions that you are still grappling with, from interpretation and implementation to practical compliance steps.
Speakers:
Matthew Axelrod, Partner, Gibson Dunn
Former Assistant Secretary for Export Enforcement, U.S. Department of Commerce's Bureau of Industry and Security (BIS)
Matt Axelrod is the only person to have served as both the Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) and Principal Associate Deputy Attorney General at the U.S. Department of Justice (DOJ) — a role described in the New York Times as "the most demanding job in all of DOJ.” His over 25 years of combined government enforcement and white-collar defense experience are why clients consistently rely on Matt to help them navigate their most sensitive and complex matters. Matt co-chairs Gibson Dunn’s Sanctions and Export Enforcement practice, where he works closely with clients to conduct internal investigations, evaluate compliance programs, advise on voluntary self-disclosures, and defend against government-facing investigations. He is based in the firm’s Washington, D.C. office.
Audi Syarief, Senior Associate, Gibson Dunn
Audi Syarief is a Senior Associate in the Washington, D.C. office of Gibson Dunn and a member of the firm’s International Trade Practice Group. He also serves as an Adjunct Professor of Law at Georgetown University Law Center, where he teaches U.S. economic sanctions and export controls. Audi advises clients on all aspects of U.S. economic sanctions and export controls, with significant experience in enforcement risk assessment, internal investigations, compliance program design, and restricted-party screening protocols.
Before joining Gibson Dunn, Audi clerked for the Honorable Timothy J. Kelly of the U.S. District Court for the District of Columbia. He earned his J.D. from the University of Virginia School of Law and his B.A. in Political Science from Rutgers University.
Olivia Valone, Strategic Growth Director, Kharon
Olivia is the Strategic Growth Director at Kharon, where she partners with leading organizations to navigate complex sanctions and compliance challenges. With over five years at Kharon, she has developed deep expertise in military end use (MEU), export controls, and financial crime compliance. Before joining Kharon, Olivia specialized in due diligence, supporting financial institutions in uncovering and addressing legal, reputational, and financial risks. Her work sits at the intersection of risk intelligence and strategic decision-making, helping clients stay ahead in an evolving regulatory landscape.