The US Trade Advisory group released a client alert on September 30, 2025.

On September 29, 2025, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an Interim Final Rule (“IFR”) that, effective immediately, significantly expands the scope of the Export Administration Regulations (“EAR”). Known as the “Affiliates Rule,” the IFR extends the restrictions under the EAR on parties on the Entity List, Military End-User (“MEU”) List, and subject to certain US sanctions, to foreign (non-US) affiliates that are owned 50% or more, directly or indirectly, individually or in the aggregate, by such parties.