BIS Affiliates Rule · OFAC 50% Rule
The 50% rule doesn’t stop at the first owner.
Most screening tools do.
Affiliate-aware ownership screening for US mid-market exporters — backed by ADEXMA trade-compliance advisory. It walks the ownership tree, aggregates across owners and lists, and produces a hashed diligence memo you can put in the file.
Live demo — why aggregation matters
Listed Parent Group
on BIS Entity List
↓owns 50%
Pan-Asia Holdings Ltd
not listed
↓owns 50%
Shenzhen Optics Mfg Co Ltd
your counterparty
AFFILIATE_50 ✓ correct
Pan-Asia is itself captured (50% ≥ threshold), so its 50% of Shenzhen counts at this tier = 50% → license required.
Real ownership aggregation
Multi-owner, cross-list, and reset-at-tier — the capture a multiplicative tool misses. The piece enterprise tools charge 5–6 figures for.
“Unknown” is a first-class answer
Open data can’t resolve private foreign ownership %s — so we escalate instead of guessing. Red Flag 29 never auto-clears.
An audit memo, not just a graph
Every screen ships a dated, provenance-logged, SHA-256-hashed memo — the Part 762 record that actually mitigates enforcement.