"Counterparty Screening" Articles (6)

The BIS and OFAC 50% Rules: Exactly 50%, Aggregation, and Chains of Subsidiaries

Does exactly 50% ownership trigger the BIS and OFAC 50% rules? Are several owners' stakes added together? How are grandchild and great-grandchild companies counted? This guide works through the text of the rule and OFAC's numbered FAQ examples, and covers where the BIS rule's stay stands (it ends 9 November 2026) and how to check a counterparty's ownership.

2026-10-20Ryuta Hamamoto

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China's Revised Defense Mobilization Law Takes Effect: What Applies to Companies in Peacetime

China's revised National Defense Mobilization Law (14 chapters, 82 articles) took effect on October 1, 2026. Most coverage has focused on the requisition of civilian resources, but several articles bind companies before any mobilization is declared, including a duty to supply data for mobilization-potential surveys. I walk through the text by article number and list what export control and subsidiary management teams should check.

2026-10-03Ryuta Hamamoto

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Taiwan's Screening List vs Japan's | 11,664 Entries Against 835

I pulled Taiwan's daily-updated export entity control list and Japan's End User List in full and compared them. 11,664 entries against 835, roughly 14x apart. But this is not a question of which is stricter. The two countries build lists on fundamentally different premises.

2026-08-27Ryuta Hamamoto

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China's countermeasures and tighter drone export controls: where should a company trading with both the US and China stand?

On August 5, 2026, China's Ministry of Commerce announced countermeasures against seven US entities and tightened export controls on drone-related dual-use items headed to the United States, on the same day. The countermeasures bind "organizations and individuals within China," which means Chinese subsidiaries of Japanese companies are directly covered. Here are the four different Chinese lists, where Japan already stands, and how to position a business that trades with both sides.

2026-08-21Ryuta Hamamoto

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Japan Moves Toward Mandatory Beneficial Owner Filing: A New Law, Anti-Money-Laundering, and Economic Security

Every company has a representative listed in its registry and shareholders lined up in its share ledger.

2026-06-29Ryuta Hamamoto

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How the Economic Security Center Plan Will Reshape Corporate Export Control Governance in H2 2026

How the Economic Security Center Plan Will Reshape Corporate Export Control Governance in H2 2026. This TIMEWELL article explains the context and practical takeaways for professionals.

2026-06-08Ryuta Hamamoto