About this webinar
The Bureau of Industry and Security’s (BIS) Affiliates Rule was issued to close a “significant loophole” that undermines U.S. national security and foreign policy interests and to make export controls work as intended.
The rule is paused for one year, until November 2026, as part of U.S.-China trade negotiations. In formalizing the one-year suspension, however, BIS states that it will “continue to evaluate U.S. national security and foreign policy interests related to these non-listed foreign affiliates of listed entities.” Despite the pause, long-standing BIS guidance warns of evasion risk through subsidiaries, shell companies, and other intermediaries to obtain controlled goods.
Experts from Kharon and Descartes share insights on industry decision-making and best practices for navigating Affiliates Rule considerations during the suspension period. Together, we unpack how diversion schemes operate, the role of affiliates in evasion, common red flags, and the practical steps organizations are taking to address evasion and diversion.
