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BIS 50% Rule Means Significant Compliance Lift for Businesses, Lawyers Say, Global Investigations Review

October 01, 2025

Partner Michael Huneke spoke with Global Investigations Review for an article about the US Bureau of Industry and Security’s (BIS’s) new 50% export control rule.

Mike told the publication that, per the new rule, companies have an “affirmative obligation” to decipher a party’s ownership structure. If a company can’t figure it out, it will need to apply for a license from BIS, and the bureau will expect applicants to describe what due diligence was taken to ascertain ownership structure.

“That’s a place where, frankly, compliance will add value, because what due diligence they’re able to do will be an important part of that license application process and the review of those license applications,” Mike said.

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