Expeditors (EXPD) Status update summary

Overview of regulatory changes

• The BIS Affiliates Rule expands end-user controls to cover affiliates of listed entities, focusing on ownership structures and applying restrictions to entities owned 50% or more by listed parties, even if not directly named on lists.

• The rule was published as an interim final rule in September 2025, finalized in November 2025, with a one-year stay; its effective date is currently set for November 10, 2026, but may be extended to January 10, 2027, pending official confirmation.

• The rule affects the Entity List, Military End User List, and certain parties on the SDN List, significantly broadening the scope of compliance requirements.

Implications for compliance and screening

• Ownership analysis is now required in addition to name and address screening, as restrictions flow to entities owned 50% or more by listed parties, including through aggregated or indirect ownership.

• If ownership by a listed party is suspected but the percentage cannot be determined, the entity must be treated as if it is listed, requiring heightened due diligence.

• The rule eliminates the concept of legally distinct entities for screening purposes, requiring a network-based approach to compliance.

Best practices and strategies

• Effective screening programs should capture all business partners, screen against relevant lists, investigate results, archive decisions, and ensure ongoing re-screening as lists and ownership structures change.

• Automation, visibility, and consistent processes are critical for managing large volumes of entities and complex ownership networks.

• External screening solutions should provide ownership visibility, regular data updates, and robust audit trails.