The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has issued a new Affiliates rule that expands compliance obligations related to international shipments, transfers, collaborations, and certain services. This change affects faculty, staff, students, and investigators across all campuses who engage in activities that involve IU items, software, technology, or data leaving the United States—or being provided to foreign persons.
This rule expands export restrictions to include foreign entities that are 50% or more owned directly or indirectly by one or more parties listed on the BIS Entity List, Military End User (MEU) List, or certain OFAC sanctions lists. These entities are now treated as if they are listed themselves, even if not explicitly named.
This change significantly increases the risk of inadvertent violations when shipping internationally.
To support our community, the Research Security Office (RSO) is available to review international shipping requests before you proceed. RSO review is highly encouraged to ensure compliance, reduce risk, and avoid unexpected delays.
This is particularly critical for:
- Physical shipments (e.g., equipment, samples, reagents, prototypes, devices, lab spare parts);
- Hand-carried items on international travel;
- International returns, replacements, and loaners; and
- Courier pickups, exports for repair, or transfers to collaborators outside the U.S.
Shipments to Foreign Countries of Concern
We especially encourage you to consult with RSO when shipments involve state and federally designated foreign countries of concern, which currently include China (including Hong Kong and Macau), Cuba, Iran, North Korea, Russia, and Venezuela. These destinations can carry additional restrictions and risks.
How RSO can help
- A quick review of your destination, recipient, and item for compliance considerations; and
- Guidance on any additional steps, federal approvals, or other documentation that may be required.
By reaching out to rsohelp@iu.edu, you gain:
In your request, include:
- Description of item(s), part numbers, model information, and manufacturer (if applicable);
- Destination country and recipient details;
- Intended use and whether the item will return; and
- Timeline or required dates.
Our goal is to make compliance straightforward and to support IU's teaching, research, and international collaborations. For questions-or to schedule a short briefing on the Affiliates Rule-please contact rsohelp@iu.edu.
Thank you for helping IU remain compliant with federal export control regulations.