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BIS 50% rule ownership aggregation beta by SecurePoint USA
Beta Now Open

BIS 50% Rule:
Ownership Aggregation for Export Compliance

Stop calculating ownership percentages in spreadsheets. Get aggregation results where ownership records exist, full chain visibility on those records, and timestamped evidence for your compliance files.

January 17, 2026
•
7 min read

The Problem You Know Too Well

Compliance teams are drowning in ownership math. Here is what we hear every week.

Ownership Spreadsheets

Tracing indirect ownership through shell companies in Excel is error prone and impossible to audit.

Time Sink

Compliance teams spend hours per entity manually calculating aggregate percentages across ownership chains.

Audit Evidence Gaps

When BIS asks how you calculated ownership, you need timestamped evidence, not a stale spreadsheet.

What is Ownership Aggregation?

The BIS 50% rule says: if sanctioned parties collectively own 50% or more of an entity, that entity inherits their restrictions. The challenge is calculating "collectively" when ownership flows through multiple layers.

Example: Indirect Ownership

Target Company: Acme Widget Corp

Owner A (Entity List): Owns 60% of Holding Co X

Holding Co X: Owns 50% of Acme Widget Corp

Indirect ownership calculation: Owner A’s 60% makes Holding Co X itself restricted. Holding’s full 50% of Acme is attributed, so Acme is covered. Multiplying 60% × 50% into 30% is the wrong rule.

A second listed party that owns Acme directly is added at full face value, not blended through Holding. OFAC FAQ 401 uses this threshold-gated method; do not treat a multiplied remainder as the answer.

Beta Features

What the Beta Includes

Everything you need to operationalize ownership screening.

Ownership Aggregation

Aggregate ownership percentages across the layers stored in the ownership graph, where records exist.

Full Chain Visibility

See every ownership path from target entity up to sanctioned owners, with percentages at each level.

Sanctions List Coverage

Sources we sync from: OFAC SDN, BIS Entity List, BIS MEU, UN Sanctions, EU Consolidated List, UK Sanctions.

Evidence Pack

Timestamped record of your query: entity searched, ownership chain found, lists checked, result timestamp.

The Evidence Pack

Every ownership lookup generates a timestamped record for your compliance files. This is not "audit defense"; it is documentation showing what you checked, when you checked it, and what the system found.

Evidence Pack Contains:

  • Entity name and identifiers searched
  • Full ownership chain with percentages at each level
  • Sanctions lists checked and their last sync timestamps
  • Aggregate ownership percentage calculated
  • Query timestamp (UTC)

Common Questions

The objections we hear, and straight answers.

Where does ownership data come from?

Customer-imported CSV or manually added relationships, plus any ownership edges already in the graph. You control those inputs; the engine does the math on what is stored. Automated GLEIF ingest is paused.

What if my entity is not in the graph?

You can import ownership edges via CSV or add relationships manually. Once added, the calculation runs against your data.

How fresh is the sanctions data?

The BIS Entity List refreshes weekly. Each query can show the sync timestamp for the lists that ran, and we link to source list pages where available.

Who This Is For

Teams that need ownership screening without the spreadsheet pain.

Defense Contractors

Managing visitor access at facilities that handle export-controlled technology.

Aerospace Suppliers

Screening vendors and partners in complex global supply chains.

Export Compliance Teams

Operationalizing BIS and OFAC 50% rule requirements at scale.

Compliance Consultants

Advising clients on ownership screening without manual graph building.

What We Are NOT

Clear boundaries on what this tool does and does not do.

Not Legal Advice

This tool does not provide legal counsel. Consult qualified export control attorneys for compliance decisions.

Not a Corporate Registry

We calculate ownership from data you provide or import. We are not a primary source of corporate records.

Not a Guarantee

Results depend on data quality and completeness. We do not guarantee regulatory compliance outcomes.

Join the Beta

Request access to ownership aggregation screening and help shape the product before general release.

Frequently Asked Questions

What is the BIS 50% rule?

The BIS 50% rule applies Entity List and MEU List restrictions to any entity that is 50% or more owned, directly or indirectly, by listed parties. This mirrors OFAC's longstanding 50% rule for SDN ownership.

How does ownership aggregation work?

The system traverses all ownership paths from a target entity upward. If multiple listed owners each hold partial stakes, their percentages are summed. For example, if Owner A (listed) holds 30% and Owner B (listed) holds 25%, the aggregate is 55%.

What sanctions lists are checked?

Screening runs against OFAC SDN and SSI, the BIS Entity List (which carries the MEU sub-list) and Denied Persons List, FBI Most Wanted, Federal Reserve enforcement actions, the UFLPA Entity List and Section 1260H, and non-US sources alongside them: UK OFSI, the EU Financial Sanctions Facility, the UN Security Council consolidated list, France’s DGT asset freezing list, Singapore MAS enforcement actions, INTERPOL Red Notices, the OpenSanctions aggregated dataset, World Bank debarment and Inter-American Development Bank sanctions. Several further sources are maintained but stay off unless an organization turns them on, including the BIS Unverified List, the ITAR/DDTC debarred list, SAM exclusions, LEIE and politically exposed persons. Confirm which sources your own tenant has enabled rather than assuming everything is active.

Can I import my own ownership data?

Yes. You can upload ownership relationships via CSV or add them manually through the admin interface. The calculation engine uses whatever data you provide.

What is included in the Evidence Pack?

The Evidence Pack is a timestamped record containing: entity name searched, ownership chain discovered, sanctions lists checked, aggregate percentage calculated, and query timestamp. This is documentation for your compliance files.

Is this tool legal advice?

No. This tool performs calculations based on data you provide. It does not constitute legal advice, guarantee regulatory compliance, or replace consultation with qualified export control counsel.

How long does a typical lookup take?

It depends on the ownership graph. An entity with one direct owner has a single path to evaluate, while an entity held through several layers of holding companies has many more, so it takes longer. We do not publish a typical lookup time.

What happens after the beta?

Beta participants will have early access to the production release and input on feature priorities. Pricing will be announced separately.

Disclaimer

This tool and the information provided in this article are for informational purposes only and do not constitute legal advice. The BIS 50% rule and related regulations are complex and subject to change.

Ownership calculations depend on the accuracy and completeness of data you provide or import. SecurePoint USA does not guarantee the accuracy of calculations, regulatory compliance outcomes, or fitness for any particular purpose.

Always consult with qualified export control counsel before making compliance decisions. Regulatory enforcement timelines mentioned are planning assumptions based on publicly available information and may change.

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Visitor Compliance Checklist

  • ITAR/EAR and CMMC L2 requirements
  • Audit-ready evidence collection
  • Possible matches go to a reviewer
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BIS 50% Rule Ownership Aggregation | SecurePoint USA