Effective September 29, 2025, many thousands of additional non-U.S. entities around the world are now prohibited from receiving U.S. goods, software, and technology under an “affiliates” interim final rule (the IFR) published by the Bureau of Industry and Security (BIS) at the U.S. Department of Commerce. The IFR contains two measures that dramatically increase the reach of the Export Administration Regulations’ party-based controls—namely, a 50 Percent Ownership Rule and an Entity List “legally distinct” standard. While the emergence of a BIS 50 Percent Ownership Rule is not entirely unexpected, the IFR expands the universe of relationships that automatically impose sanctions on unlisted entities in ways that were potentially unanticipated by many in industry, including ownership by persons on the Military End User List and by certain persons on the Specially Designated Persons and Blocked Persons List.