Could BIS Adopt a 50% Rule? Early Signals and Compliance Questions

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Wednesday, June 18, 2025 | 3:00 - 3:30 PM ET

According to reports, U.S. officials are preparing a rule that would extend export controls to subsidiaries majority-owned by entities already subject to U.S. restrictions. If adopted, the so-called “BIS 50% Rule” would significantly broaden the scope of the Entity List and related authorities.

Unlike OFAC, which automatically blocks subsidiaries that are 50 percent or more owned by sanctioned parties, BIS has not imposed the same downstream restrictions. That gap has created a permissive environment in which subsidiaries of listed firms, particularly in China and Russia, remain accessible for business under current U.S. export rules. Kharon’s data identifies thousands of such majority-owned entities worldwide that would likely come within reach of a BIS 50 Percent rule.

Join Kharon’s experts for a 20-minute briefing on the anticipated rule, what we know so far, and the broader implications for export compliance.

We’ll cover:
  • Overview of the anticipated BIS 50% rule
  • Potential impacts on screening, due diligence, and enforcement
  • Preliminary steps compliance teams can take in preparation
  • How Kharon’s comprehensive data can help assess exposure under a possible BIS 50 Percent rule

 

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