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Base rate computed from analyst-asserted responds_to: edges in the reverse direction (target-country → issuer-country) for prior issuer-actions on the same target. Modal type + lag percentiles only — not a model output. Treat as a historical anchor for sizing counter-response scenarios, not a forecast in itself.
The September 30, 2025 Affiliates Rule (90 FR 47201) had imposed an automatic Entity List extension: any unlisted entity that is at least 50% owned — directly or indirectly, individually or in the aggregate — by one or more Entity List parties (or by certain other restricted parties) is itself automatically subject to Entity List license requirements, even without a separate listing. This mirrored the long-standing OFAC "50% rule" but for the EAR's end-user controls.
This November 12, 2025 final rule freezes that extension. In a two-phase implementation:
amendments to 15 CFR parts 732, 734, 736, 744, and 748 are stayed. EAR text reverts to the pre-Affiliates-Rule baseline; only entities individually named on the Entity List trigger Entity List restrictions.
Affiliates Rule amendments are scheduled to re-enter the EAR indefinitely.
The suspension was framed by the White House as part of the post-Busan US-China understanding (October 30, 2025), where Beijing had cited the Affiliates Rule as a primary irritant requiring rollback. The original listings of named parties — Huawei, SMIC, YMTC, CXMT, and the hundreds of other Entity List names accumulated since 1997 — are unaffected; this is purely a rollback of the automatic-extension mechanism, not the underlying listings.
Entity List screening to named-party matching only for the suspension window, dropping the harder 50%-ownership tracing that the September rule had introduced. Diligence-cost relief is meaningful for semiconductor-tooling, EDA, and AI-compute distribution channels into Asia where ownership chains are opaque.
tangible US concessions in the post-Busan thaw, alongside the broader US-China Busan economic & trade arrangement. It signals BIS willingness to trade enforcement intensity for diplomatic outcomes — a meaningful change versus the 2022-2025 ratchet trajectory.
Affiliates Rule absent further action. Counsel and compliance teams should plan for a binary regulatory cliff at 2026-11-10 unless the suspension is extended or made permanent.
(e.g., guidance rather than rule), or revert wholesale on 2026-11-10?
proclamation (2026-01-14) and the FY26 export-control package — does it constrain BIS's ability to add new Entity List names during the suspension window?
relied on the 50%-ownership extension between Sept 30 and Nov 10, 2025? The rule text does not address retroactivity.