Question 1

What is the BIS 50% Rule (Affiliates Rule)?

Accepted Answer

The BIS 50% Rule is a new U.S. export control requirement that extends Entity List and MEU List restrictions to any company that is 50% or more owned (directly or indirectly) by one or more listed entities. This includes subsidiaries, holding companies, offshore structures, and multi-layer corporate ownership.

Question 2

When will the BIS 50% Rule be fully enforced?

Accepted Answer

The rule becomes fully enforceable in November 2026, but early preparation is essential due to the difficulty of uncovering hidden ownership relationships.

Question 3

What are the risks of BIS 50% Rule non-compliance?

Accepted Answer

Organizations face export privilege loss, regulatory penalties, and significant shipment delays. Many companies now search for BIS 50% Rule penalties and export control enforcement as enforcement tightens.

Question 4

How does Assent support BIS 50% Rule compliance?

Accepted Answer

Assent’s Enhanced Entity Screening integrates AI-powered analysis, ownership tracing, and expert review to:Identify complex indirect ownership chainsUncover offshore or layered affiliatesConsolidate beneficial ownership data across jurisdictionsApply OFAC and BIS style 50% ownership logicProduce defensible evidence for audits and licensing decisions

Question 5

Which minerals are included in responsible sourcing and SCIP reporting requirements?

Accepted Answer

Responsible minerals programs traditionally focused on the “conflict minerals” (3TGs):TantalumTinTungstenGoldToday, regulators and customers also expect due diligence on extended minerals linked to human rights and sustainability risks:CobaltCopperGraphiteLithiumMicaNickelCompanies should expand their responsible minerals sourcing program to cover both conflict and extended minerals.

Question 6

How can I identify which suppliers are in scope for a responsible minerals sourcing program?

Accepted Answer

Not every supplier must be contacted. To determine scope:Focus on suppliers providing products that contain conflict or extended minerals.Exclude service providers (e.g., legal, accounting) and non-relevant goods (e.g., janitorial supplies, wood, plastics).Collaborate with procurement and engineering teams to confirm which suppliers are material to consumer-facing goods.A scoped supplier list makes responsible minerals due diligence more efficient and avoids unnecessary outreach.

Question 7

Which compliance standards and reporting templates apply to responsible minerals sourcing?

Accepted Answer

Global frameworks and tools that guide compliance include:OECD Due Diligence Guidance (the international standard for responsible sourcing programs)Conflict Minerals Reporting Template (CMRT) for 3TG reportingExtended Minerals Reporting Template (EMRT) for cobalt, lithium, and other extended mineralsAligning your program with these standards ensures consistency with regulatory expectations.

Question 8

What are the biggest challenges when engaging suppliers on mineral sourcing?

Accepted Answer

The most common challenges include:Finding the right contact: Procurement lists often contain sales emails, not compliance contacts.Educating suppliers: Some may be unfamiliar with conflict or extended minerals requirements.Managing volume: Large supplier networks make manual follow-up inefficient.Clear outreach — with instructions, deadlines, and links to templates — increases response rates and supplier accuracy.

Question 9

How can technology support responsible minerals sourcing compliance?

Accepted Answer

Technology simplifies supplier engagement, tracking, and reporting by:Automating supplier outreach and data collectionCentralizing supplier responses in one platformFlagging risks tied to smelters or specific mineralsReducing manual follow-up and repetitive requestsEnsuring compliance programs adapt to evolving regulationsSolutions such as Assent’s sustainability platform help compliance teams reduce administrative workload while keeping programs aligned with SCIP and conflict minerals reporting requirements.

Question 10

Is the DDRT mandatory?

Accepted Answer

The template itself isn’t a legal mandate. It’s an industry standard many OEMs support to streamline disclosures. Still, suppliers can expect customers to request it and demand action on identified risks.

Question 11

If I use the DDRT, do I still need a supply chain sustainability platform?

Accepted Answer

Yes. The DDRT standardizes how information is requested and disclosed, but regulators and OEMs still expect verifiable due diligence and corrective actions. A platform like Assent helps you operationalize those requirements and prove results.

Question 12

Does Assent help with the DDRT?

Accepted Answer

Assent’s Forced Labor solution complements the DDRT by enabling supplier engagement, monitoring, evidence review, remediation tracking, and standardized reporting across regulations.

Question 13

What is Bill S-211?

Accepted Answer

Bill S-211 requires companies that produce, distribute, or import goods in Canada to report publicly on how they’ve identified, assessed, and mitigated forced and child labour risks in their supply chains. Manufacturers remain a primary focus area, representing over one-third of all reporting entities in 2024. Compliance now means demonstrating measurable progress in your due diligence program, not simply publishing a report.

Question 14

What are regulators looking for now under Bill S-211 reporting?

Accepted Answer

Following the 2025 deadline, Canadian authorities are emphasizing enforcement and accountability. Reports are being reviewed for completeness, accuracy, and evidence of real action. Key areas of focus include:Proof of supplier engagement on forced and child labour risks.Evidence of internal training and clear escalation processes.Year-over-year progress in identifying and mitigating high-risk suppliers.Consistency across global reports, particularly for companies also subject to the UK Modern Slavery Act or upcoming EU Forced Labour Regulation.

Question 15

How does Assent improve Bill S-211 compliance?

Accepted Answer

Assent helps manufacturers go beyond one-time reporting to build continuous compliance and resilience under Bill S-211 and other global human rights regulations. Our Forced Labour Solution combines AI-powered supplier screening, automated data collection, and audit-ready reporting tools to help companies prove due diligence throughout the year.With Assent, you can:Automate supplier outreach and forced labour declarations.Identify high-risk suppliers through indirect screening and ownership data.Centralize all compliance documentation for annual reporting.Benchmark progress across multiple human rights frameworks.

The BIS 50% Rule (Affiliates Rule): Get Prepared Now

How to Create an Effective Responsible Minerals Sourcing Program

AIAG’s DDRT Is Here. Is Your Compliance Program Ready?

2025 Forced Labor Reporting: Canada Deadline Imminent

Forced Labor Law Compliance Ramping Up in 2025

Why the UFLPA Expansion Should Raise Red Flags for Automotive Manufacturers

What Is Canada’s Fighting Against Forced Labour & Child Labour in Supply Chains Act?

Tag: Forced Labor