The U.S. Department of Commerce’s Bureau of Industry & Security (BIS) on September 29, 2025 took a significant yet anticipated step by adopting an Interim Final Rule, referred to as the Affiliates Rule, extending the restrictions imposed on entities listed on the Entity List (“EL”) to unlisted entities that are 50% or more owned by one or more of the listed entities.  Presently, naming to the Entity List, the BIS’s strictest listing of non-U.S. parties, was limited to the named entity and none of its legally distinct affiliates or subsidiaries.  This rule drastically changes that by capturing a wider range of related entities whose names would not necessarily be on the list.  This action will have a momentous impact on many companies in China and elsewhere, significantly increasing compliance burdens, particularly on companies doing business in or with sensitive regions.

Farhad Alavi (Washington Partner), Sam Amir Toossi (New York Partner), and Valentin Povarchuk (Washington Counsel) will be attending the 2025 International Bar Association (IBA) Annual Conference in Toronto this year, which will be held between November 2-7.

We are pleased to announce Akrivis Law Group that our client Engro Polymer & Chemicals Ltd. (EPCL) has been officially removed from the U.S. Department of Commerce Bureau of Industry & Security’s (BIS) Unverified List.  The change took effect on December 16, 2022 and was published in the Federal Register. A copy of the final rule can be found here.

Akrivis Law Group Partner Sam Amir Toossi was interviewed by Law360 regarding the DOJ’s case against Bijan Rafiekian, a former business partner of Michael Flynn, for alleged FARA violations. After trial in 2019, the court set aside the jury’s guilty verdict, a decision that subsequently overturned by the Fourth Circuit.  The district court then ordered a new trial, a decision that the DOJ is currently appealing.  In the article, Mr. Toossi discussed the possible implications for future FARA prosecutions if the Fourth Circuit affirms the district court’s prefer for a new trial.