Circle 10 November 2026. That is when the Affiliates Rule, issued by BIS, the US export-control enforcement agency, returns to force after a one-year suspension. From that date, any counterparty owned 50% or more, directly or indirectly, by parties on the Entity List, the US export blacklist, can inherit their restrictions, even if its own name appears on no screening list.
The rule took effect in September 2025, was suspended in November 2025, and returns on 10 November 2026. That leaves a short window to answer a deceptively simple question. Which of your counterparties will be affected?
The logic is familiar. OFAC, the US sanctions authority, has applied the same ownership-based approach for years. Restriction follows ownership, not branding, legal form or company name.
Screening cannot see this
The standard response is "we already screen our counterparties". Read the rule again. Screening compares names against lists, and the entities this rule captures are, by definition, often on no list. Their connection to a restricted party exists in their ownership structure, sometimes several corporate layers above them.
A counterparty can pass every list check and still fall within the scope of the rule, because the relevant fact is not what the company is called. It is who owns it.
The stakes are not theoretical. BIS fines now run to nine figures (the enforcement climate, and why screening misses it), and "they were not on the list" is not a defence when the ownership was knowable.
The ten-week computation
This is not primarily a policy exercise. It is a data exercise, and four steps matter.
- Resolve names to entities. Counterparties appear under multiple names, aliases and local registrations. Ownership attaches to real-world entities, not spellings, so the duplicates have to disappear before ownership can be analysed.
- Map the ownership structure above every counterparty, from registry and ownership data, with gaps marked. An unknown owner two or three layers up is not a missing data point. It is a compliance finding.
- Run the fifty percent arithmetic. Add up restricted-party ownership, direct and indirect, across the structure. The output identifies the counterparties already above the threshold, the ones approaching it, and the ones whose ownership is too opaque to clear confidently. The calculation is straightforward. The ownership data is the challenge.
- Assign ownership and resolution. Every exposure needs an owner before the deadline, whether the answer is more ownership information, a licence application, restructured transactions or an exit. And because ownership changes continuously, the arithmetic has to keep running.
October or December
The same facts produce two very different outcomes depending on when they are discovered. Finding an exposure in October is a planning exercise. Finding the same exposure in December is an incident response. The ownership structure has not changed. Only the timing has.
The organisations that start tracing ownership now will have options later. The ones that wait for the rule to return may discover their exposure after it matters.
The map outlives the deadline
The value of the ownership map does not end on 10 November. Once built, it answers the next question before it is asked. What happens to our exposure if this parent company becomes restricted tomorrow?
Trade controls increasingly follow ownership structures rather than entity names. Building the map for November solves a deadline. Keeping it current creates a capability.
The Prophesee Compliance Suite provides ownership tracing, threshold calculations and continuous re-screening across corporate structures. Compute your November exposure now, while it is still a planning exercise. Start here.