The US Commerce Department’s issued a one-year suspension of the Affiliates rule in November 2025. It is important for exporters to know that the temporary pause on the Affiliates Rule does not eliminate compliance expectations. BIS continues to view affiliate‑based diversion as a core risk, and exporters should use this period to strengthen compliance foundations before the rule is reinstated.

What You Need to Know

• The pause is not a repeal. BIS has made clear that enforcement expectations remain unchanged.
• The rule’s underlying authority and policy intent are still in place.
• When reinstated, the rule is expected to return with limited lead time for implementation.

What the Affiliates Rule Does

The rule expands who counts as a party to the transaction under the EAR. Exporters must consider not only the direct buyer or end user, but also affiliated entities (including parents, subsidiaries, and sister companies) when assessing diversion or misuse risk.

This means:

• Broader due‑diligence obligations
• More complex ECCN classification implications
• Additional scrutiny for license exception eligibility
• Ongoing monitoring of ownership changes

Why This Matters During the Pause

Even without active implementation:

• Diversion risk through affiliate networks remains a documented enforcement priority.
• BIS expects exporters to understand who they are doing business with, including beneficial owners and related entities.
• Companies that wait will face compressed timelines and operational strain once the rule returns.

Recommended Actions for Customers

Use this pause to strengthen your compliance posture:

• Review and update ECCN classifications. Focus on items not reviewed recently or in high‑risk technology sectors.
• Map your ownership structures. Identify beneficial owners and screen affiliated entities for your highest‑value or highest‑risk customers.
• Assess system and workflow gaps. Determine whether your current tools can support affiliate‑level screening.
• Reevaluate license exception reliance. Ensure end‑user‑based exceptions remain valid when considering affiliate networks.
• Engage customers proactively. Normalize ownership disclosure as part of standard compliance practice.

Bottom Line

The pause is a preparation window, not a relaxation of obligations. Companies that invest now in classification accuracy, ownership mapping, and system readiness will be positioned to comply smoothly when the Affiliates Rule returns. Those that delay will face significant operational pressure.

RIM’s network of export professionals is available to help clients navigate the complex and evolving export regulatory requirements. Contact your local RIM representative to connect with RIM’s export team.