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BIS Affiliates Rule Suspension Offers Two More Months of Relief for Exporters, Export Compliance Daily

November 06, 2026

Partner Michael Huneke was quoted by Export Compliance Daily in an article about the US Bureau of Industry and Security’s decision to extend the suspension of its Affiliates Rule until January 10, 2027, providing exporters additional time to prepare for potentially expanded export restrictions and due diligence requirements.

Mike noted that the rule has created significant compliance challenges for companies, particularly in identifying corporate ownership structures and reconciling inconsistent information from screening vendors. While many businesses have used the suspension to develop compliance strategies and familiarize themselves with new screening tools, he cautioned that implementation could still prove difficult if the rule takes effect. 

“[I]f and when it snaps back, there'll be a steep upward learning curve for people who aren't using it right now,” Mike said.

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