Trade compliance rarely gets a deadline this clean. The BIS Affiliates Rule, which extends Entity List and related export restrictions to entities owned 50% or more by listed parties, took effect in September 2025, was suspended two months later, and returns to force on 10 November 2026. The date is fixed, the mechanics are published, and roughly ten weeks remain.
The rule's logic mirrors OFAC's long-standing 50 percent rule for sanctions: restriction follows ownership, directly or indirectly, whether or not the owned entity appears on any list. What changes in November is scale and consequence on the export side. A customer, distributor or intermediary that is majority-owned by a listed party inherits the restriction, and an exporter who ships to it without the required licence has violated export controls, cleanly named counterparty notwithstanding.
Why list screening cannot see this
The standard trade compliance stack matches counterparty names against restricted party lists. Against the Affiliates Rule this is structurally blind, for the same reason it always was against OFAC's rule: the entities the rule captures are, by definition, the ones on no list. Their connection to a listed party is an ownership fact, buried in corporate registries, holding structures and minority stakes that aggregate, sometimes across three or four layers and multiple jurisdictions.
The enforcement environment gives the gap teeth. BIS penalties now run to nine figures (the enforcement climate, and why screening misses it), and both BIS and OFAC guidance have converged on the same expectation: a compliance programme is responsible for knowing the ownership behind its counterparties, and "they were not on the list" is not a defence when the ownership was knowable.
The ten-week computation
The work between now and November is well-defined, and it is a computation, not a policy rewrite:
- Resolve the counterparty file to entities. Names, aliases and registration numbers collapsed into distinct real-world parties, because ownership attaches to entities, not spellings.
- Assemble the ownership graph above every active counterparty: parents, holding companies, aggregated stakes, from registry and ownership data, with the gaps honestly marked, because an unknown owner two layers up is itself a risk finding.
- Run the 50 percent arithmetic as a traversal, aggregating listed party ownership, direct and indirect, per counterparty. The output is an exposure register: entities that will be restricted on 10 November, entities near the threshold, and entities whose structures are too opaque to clear.
- Wire the register to decisions. Each exposed counterparty gets an owner and a disposition before the deadline: licence application, contract exit, restructured routing, or documented clearance. And because ownership changes weekly, the traversal has to keep running after November; a register computed once is stale by December.
The difference between October and December is the difference between a planning exercise and an incident response, on the same facts.
For those who move early, a strategic layer opens up. The same graph that answers "who is restricted in November?" answers the questions that follow: what happens to our exposure if this holding company is listed next; which alternative suppliers sit outside restricted structures; where does one listing cascade through our counterparty base? That is scenario capability, and firms that build the graph for the deadline keep it as an instrument.
Ownership traversal, threshold arithmetic and continuous re-screening are standing capabilities of the Prophesee Compliance Suite's Trade module. Compute your November exposure now. Start here.