In a significant move affecting global trade and compliance, the United States has formally suspended implementation of its new “affiliates rule” for one year – as part of a wider agreement with China.
The rule, introduced by the Bureau of Industry and Security (BIS) on 29 September 2025, would have extended export-control restrictions to any entity that is 50% or more owned (directly or indirectly) by firms already subject to U.S. sanctions or on the “Entity List.”
In the official notice filed on 10 November 2025, the U.S. government confirmed that the rule’s enforcement will be suspended from 10 November 2025 until 9 November 2026.
Why This Matters
- For exporters and compliance teams, this provides a temporary reprieve from what would have been a complex expansion of due-diligence obligations – particularly around ownership screening, indirect ties, and “shadow affiliate” risk.
- However, the delay does not equal repeal – the rule remains on the books and is expected to return in full once the suspension expires.
- Some trade experts warn that the one-year pause may give firms time to restructure entities and sidestep the rule when it’s reactivated, potentially weakening its intended national-security impact.
For UK-Based Firms and Global Supply Chains
While this is a U.S. regulation, its global reach means multinational firms and UK exporters must still pay close attention. Ownership structures, indirect downstream ties, and re-export risks remain significant considerations.
The suspension offers valuable time to review internal processes and strengthen compliance frameworks, but the underlying regulatory environment remains dynamic.
If you need guidance on how these changes may affect your supply chain, our team is here to help – please email us at crmteam@ugroup.co.uk to discuss further.