The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) is suspending the new Affiliates Rule (read our October 3, 2025 alert to learn more about the rule) until November 9, 2026. The BIS will formally publish the suspension on November 12, 2025, with an effective date of November 10, 2025.
This suspension provides additional time for companies to assess ownership, governance, and supply chain relationships that may trigger compliance obligations once the rule takes effect again on November 10, 2026.
If you would like additional information about the issues addressed in this alert, please contact Rich Matheny, Jake Osborn, Justin Pierce, or the Goodwin lawyer whom you typically consult.
Contacts
- /en/people/p/pierce-justin
Justin C. Pierce
Partner - /en/people/m/migala-stephenSM
Stephen Migala
Counsel
