U.S. Commerce Department’s Bureau of Industry and Security’s Entity List
Devon Elliott - 2802466455
On September 29, 2025, the U.S. Commerce Department’s Bureau of Industry and Security
adopted a “50% rule” so that any subsidiary at least 50% owned by a company on the Entity List
(or the Military End-User List) is automatically subject to the same export-licensing restrictions,
with a limited 60-day transition for certain transactions. T move targets workarounds in
semiconductor and other dual-use supply chains and aligns with Treasury’s ownership standard.
The Entity List is BIS’s (Bureau of Industry and Security, an agency within the U.S. Department
of Commerce) roster in identifying foreign persons and addresses that are subject to specific
licensing requirements because their activities are considered contrary to U.S. national-security
or foreign-policy interests. This includes exports, reexports, and in-country transfers to these
parties that generally require licenses and face curtailed license exceptions.
https://www.reuters.com/business/autos-transportation/us-expands-export-blacklist-includesubsidiaries-2025-09-29/?utm_source=chatgpt.com
https://www.ft.com/content/4354c8b7-1abf-4aa3-9314-ba723c8a1cfd?utm_source=chatgpt.com
https://www.reuters.com/world/china/under-trump-us-cedes-its-share-chinas-beef-marketaustralia-2025-09-29/?utm_source=chatgpt.com