BIS 50% Rule: What you need to know

The BIS 50% Rule is coming—but it’s already reshaping screening activities. By making ownership the deciding factor for the US Entity List, this rule could expose hidden connections, highlight new risks, and impel companies to rethink how they manage global trade and global due diligence. 

In this episode, host Alex Pillow, is joined by Moody’s Industry Practice Lead, Hera Smith, to unpack what this rule will likely mean for businesses worldwide. Together, they explore the effects across industries and answer the questions that matter most: 

• What is the BIS 50% Rule and what loophole does it close? 
• How does it compare to OFAC’s 50% Rule? 
• What will the penalties be for violating this regulation? 
• Which industries will be most affected, and how should compliance teams adapt now? 
• What does effective collaboration between vendors and practitioners look like? 

Since the recording, implementation has changed and will now be enforced from November 2026.

Additional resources: 

• Bureau of Industry & Security website
• Moody’s blogs 
  • BIS 50% Rule – what is it and what has changed?
  • What are the differences between the BIS 50% Rule and the OFAC 50% Rule?

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