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Free Compliance Tool

BIS 50 Rule Calculator

Calculate aggregate ownership by BIS Entity List or MEU List parties against the 50% threshold.

150% Threshold

Entities owned 50% or more by restricted parties are typically subject to the same restrictions.

2Aggregate Logic

You must sum the ownership from ALL restricted parties, not just single owners.

3Indirect Paths

If a restricted party owns 50% or more of an intermediary, treat that intermediary as restricted and enter its full direct stake in the target. Do not multiply percentages through the chain. For automated chain analysis, use our ownership lookup.

Ownership Structure

Owner Label
Ownership %
Restricted?
%
%
⚠️

Unknown ownership: 45.00%. Ensure unknown owners are not restricted.

Status: Red Flag

Minority Ownership Warning

Restricted ownership is below 50% but exceeds the 25% red flag threshold. Enhanced due diligence required.

Aggregate Restricted
30.00%
Max Single Owner
30.00%

How this calculator works

This tool sums each owner’s direct stake and marks which owners are restricted. That is the right aggregation for a flat cap table. For a chain, do not pre-multiply. If Restricted Parent owns 60% of Holding and Holding owns 50% of the target, Holding is itself restricted: enter Holding at 50% restricted. The target is covered. Entering 30% is the wrong rule (OFAC FAQ 401).

Example Calculation:
Restricted Owner A:30%
Restricted Owner B:25%
Total Restricted:55% (BLOCKED)

Minority ownership red flags

Many compliance failures happen in the 30-49% range. While not automatically blocked by statute, BIS guidance explicitly identifies "significant minority ownership" by a restricted party as a Red Flag.

Our Recommendation: Treat any aggregate restricted ownership of 25% or more as a trigger for enhanced due diligence (EDD) to verify control and end-use.

Worked example: a supplier that screens clean by name

A composite illustration, not a customer case. Name screening on the supplier returns no list hits, but its ownership data shows:

  • Owner A, a restricted party, holds 30%.
  • Owner B, a separate restricted party, holds 25%.
  • The rest is split across owners who are not listed.

Neither owner holds a majority on its own, but together they hold 55%, so the supplier is inside the 50% scope even though its own name is clean. Enter both owners in the calculator above at their direct stakes and mark them restricted to see the result. Under OFAC’s 50% Rule that aggregation applies to blocked owners today; for Entity List and MEU List owners, the BIS Affiliates Rule would apply it if and when the rule takes effect, as the status note above explains.

Disclaimer: Educational content only, not legal advice. Compliance decisions should be made based on official regulations (15 CFR Part 744) and consultation with trade counsel. This tool helps visualize the math but does not replace comprehensive screening of your specific counterparties.

BIS 50 Rule Calculator | SecurePoint USA