[{"data":1,"prerenderedAt":4},["ShallowReactive",2],{"article-body-the-fifty-percent-rule-countdown":3},"\nCircle 10 November 2026. That is when the Affiliates Rule, issued\nby BIS, the US export-control enforcement agency, returns to force\nafter a one-year suspension. From that date, any counterparty\nowned 50% or more, directly or indirectly, by parties on the\nEntity List, the US export blacklist, can inherit their\nrestrictions, even if its own name appears on no screening list.\n\nThe rule took effect in September 2025, was suspended in November\n2025, and returns on 10 November 2026. That leaves a short window\nto answer a deceptively simple question. Which of your\ncounterparties will be affected?\n\nThe logic is familiar. OFAC, the US sanctions authority, has\napplied the same ownership-based approach for years. Restriction\nfollows ownership, not branding, legal form or company name.\n\n## Screening cannot see this\n\nThe standard response is \"we already screen our counterparties\".\nRead the rule again. Screening compares names against lists, and\nthe entities this rule captures are, by definition, often on no\nlist. Their connection to a restricted party exists in their\nownership structure, sometimes several corporate layers above\nthem.\n\nA counterparty can pass every list check and still fall within the\nscope of the rule, because the relevant fact is not what the\ncompany is called. It is who owns it.\n\nThe stakes are not theoretical. BIS fines now run to nine figures\n([the enforcement climate, and why screening misses\nit](/insights/95-percent-false-positives-is-a-design-choice)), and\n\"they were not on the list\" is not a defence when the ownership\nwas knowable.\n\n## The ten-week computation\n\nThis is not primarily a policy exercise. It is a data exercise,\nand four steps matter.\n\n1. **Resolve names to entities.** Counterparties appear under\n   multiple names, aliases and local registrations. Ownership\n   attaches to real-world entities, not spellings, so the\n   duplicates have to disappear before ownership can be analysed.\n2. **Map the ownership structure** above every counterparty, from\n   registry and ownership data, with gaps marked. An unknown owner\n   two or three layers up is not a missing data point. It is a\n   compliance finding.\n3. **Run the fifty percent arithmetic.** Add up restricted-party\n   ownership, direct and indirect, across the structure. The\n   output identifies the counterparties already above the\n   threshold, the ones approaching it, and the ones whose\n   ownership is too opaque to clear confidently. The calculation\n   is straightforward. The ownership data is the challenge.\n4. **Assign ownership and resolution.** Every exposure needs an\n   owner before the deadline, whether the answer is more ownership\n   information, a licence application, restructured transactions\n   or an exit. And because ownership changes continuously, the\n   arithmetic has to keep running.\n\n## October or December\n\nThe same facts produce two very different outcomes depending on\nwhen they are discovered. Finding an exposure in October is a\nplanning exercise. Finding the same exposure in December is an\nincident response. The ownership structure has not changed. Only\nthe timing has.\n\nThe organisations that start tracing ownership now will have\noptions later. The ones that wait for the rule to return may\ndiscover their exposure after it matters.\n\n## The map outlives the deadline\n\nThe value of the ownership map does not end on 10 November. Once\nbuilt, it answers the next question before it is asked. What\nhappens to our exposure if this parent company becomes restricted\ntomorrow?\n\nTrade controls increasingly follow ownership structures rather\nthan entity names. Building the map for November solves a\ndeadline. Keeping it current creates a capability.\n\n[The Prophesee Compliance Suite](/solutions/compliance/trade)\nprovides ownership tracing, threshold calculations and continuous\nre-screening across corporate structures. Compute your November\nexposure now, while it is still a planning exercise.\n[Start here](/contact).\n",1786984937462]