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SBA Proposes To Relax Employee-Based Size Standard

Client Alert | less than 1 min read | 08.03.07

On July 27, 2007, the U.S. Small Business Administration issued a proposed rule to simplify and relax the way in which it determines whether an entity complies with an employee-based size standard. Instead of the current method, which uses a rolling average of the number of employees over the previous 12 months, the proposed method is based on the average number of employees over the last three completed calendar years and will not only require less frequent updates to an entity's size status but also allow a greater number of contractors that have experienced growth in the past several years to still qualify as small.

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Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....