Manufacturers Must Prepare Now as BIS Affiliates Rule is Temporarily Paused

A Pause in the Action: BIS Affiliates Rule Under Review

On November 10, 2025, the Bureau of Industry and Security (BIS) formally suspended the Affiliates Rule, which had sought to expand export restrictions to certain foreign entities owned by listed parties. This decision marks a crucial moment for manufacturers and exporters navigating complex trade landscapes, particularly those with connections to China.

The One-Year Suspension: What's the Impact?

The suspension provides a temporary reprieve until November 9, 2026, when the Affiliates Rule may snap back into effect unless further action is taken by BIS. This rule aimed to enforce more cautious screening processes for foreign entities linked to U.S. sanctions and export controls, a crucial facet in today’s geopolitically sensitive trade environment. With the minor pause, businesses are encouraged to not let their guard down—quite the opposite. Many industry experts suggest utilizing this time to bolster compliance protocols and refine processes related to customer ownership clarity.

Preparing for Change: Key Actions for Manufacturers

As the dust settles on the suspension announcement, companies should prioritize their next steps to ensure they’re not caught off-guard when the rule potentially re-implements in the upcoming year. Here are some recommended actions:

• Conduct Thorough Risk Assessments: Understand not only your clients' ownership structures but also any indirect affiliations that could pose compliance risks under the rule.
• Ongoing Monitoring Is Essential: Since business structures can change, continue monitoring your customers’ statuses on an ongoing basis. Implement regular checks to validate the ownership information received.
• Modify Customer Agreements: It’s advisable to revise contracts to include clauses regarding ownership disclosures. This will help prevent any unforeseen exposure when the rule comes back into play.
• Request Certifications: Regularly obtain certifications from customers pertaining to ownership under the Affiliates Rule to maintain a clear audit trail.
• Document Everything: Maintain detailed records, including screenshots of ownership verifications and research notes, ensuring your due diligence is transparent and verifiable.

The Role of Technology in Compliance

For manufacturers seeking an effective solution to the complexities of compliance, innovative technologies like Shepherd provide robust screening capabilities. With a focus on reducing false positives and enhancing user experience, Shepherd utilizes AI to continuously monitor global watchlists—helping businesses stay ahead of potential compliance issues.

Features such as complete audit trails and straightforward record-keeping simplify the compliance documentation process, allowing businesses to focus more on their core operational tasks. Offering built-in support and transparent pricing, Shepherd empowers companies to manage their export import challenges more effectively.

Future Insights and Strategies

The suspension of the Affiliates Rule is a pivotal moment for businesses involved in international trade. However, manufacturers must recognize that this pause is not synonymous with permanence. The geopolitical chess game between the U.S. and China continues to influence trade policies. Companies should prepare themselves for swift changes in regulations, staying alert to BIS communications and legislative developments that could affect their strategic operations.

Overall, proactively enhancing compliance protocols and addressing ownership visibility concerns can significantly mitigate business risks in a fluctuating regulatory landscape.

Conclusion: Take Charge of Your Compliance

As companies assess their positions and plan for what lies ahead, now is the time to ensure you are ready for any regulatory shifts. Review your compliance strategies, enhance internal processes, and stay informed on global trade developments. For a more effective compliance strategy and to explore powerful screening solutions like Shepherd, visit our website today to sign up for a free demo.