In a Federal Register Notice (FRN) published on September 30, 2025, the Bureau of Industry and Security (BIS) announced an interim final rule establishing a 50% ownership threshold for the Entity List and Military End User List.

BIS is adopting this rule from the Office of Foreign Assets Control’s Specially Designated Nationals and Blocked Persons List and will impose export license requirements on any company that is at least 50% owned by a party on the Entity List or Military End User List.

This interim final rule went into effect on September 29, 2025. BIS is accepting public comments on this rule until October 30, 2025.

A temporary general license for “non-listed foreign affiliates of listed entities”, which permits certain export, reexport, and transfer (in-country) transactions involving non-listed foreign affiliates that are 50% or more owned by parties on the Entity List or Military End User List, will be valid for 60 days, until November 28, 2025.

FRN 2025-19001 can be found here:
https://www.federalregister.gov/documents/2025/09/30/2025-19001/expansion-of-end-user-controls-to-cover-affiliates-of-certain-listed-entities