Complex ownership structures can conceal connections that automated screening alone may miss. The Commerce Department’s BIS Affiliates Rule, scheduled to resume November 10, 2026, extends applicable license requirements and restrictions to unlisted foreign entities owned 50% or more—directly or indirectly, in the aggregate—by Entity List or Military End-User (MEU) List entities.
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Ownership risk extends beyond the entity’s name. Screening against the Consolidated Screening List (CSL) alone may miss restricted-party interests buried in shell companies, and/or multiple layers of corporate ownership. With the BIS Affiliates Rule scheduled to resume November 10, 2026, understanding direct, indirect, and aggregate ownership is critical. Kreller investigates ownership chains, traces ultimate beneficial owners (UBOs), provides ownership mapping and assesses combined stakes held by relevant listed parties to support informed compliance decisions before shipment.
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Certain EAR violations can result in liability even without knowledge that a license was required. Red Flag 29, scheduled to resume with the BIS Affiliates Rule on November 10, 2026, identifies known ownership by an Entity List or MEU List party as a key diversion red flag requiring affirmative due diligence to determine ownership percentages. Kreller investigates ownership chains and documents findings and information gaps to help resolve red flags and support compliance decisions before transactions proceed.
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When ownership is opaque, local investigative reach matters. Kreller supports export-control due diligence in challenging markets such as China and Russia, and across the Middle East and Africa, where access to reliable ownership information can be limited. Our in-country investigators examine local corporate registry records and draw on human intelligence (HUMINT) sources to trace layered ownership structures and identify restricted-party connections that standard screening databases may not capture.
Third Party Due Diligence (Customers Distributors, & Suppliers): Identify direct owners, intermediate holding companies, UBOs and connectivity to sanctioned/restricted entities
Complex Corporate Structures: Trace ownership through subsidiaries, joint ventures, and layered holding companies
High-Risk Jurisdictions: Investigate ownership where records are limited or difficult to access
Mergers, Acquisitions, Joint Ventures & Investments: Map a target’s ownership before a transaction
Ownership Changes: Reassess ownership following restructuring or shareholder changes
Unclear screening results: Investigate whether a potential name or address match reflects an actual restricted-party connection
Aggregate and Indirect ownership analysis: Assess combined stakes held by relevant restricted parties across multiple ownership chains
Diversion and Transshipment Risk: Map ownership links among customers, distributors, and intermediaries to identify connections to restricted parties or potential diversion networks
Compliance documentation: Document ownership findings, supporting sources, and unresolved gaps for internal review or legal counsel
Kreller delivers due diligence investigations which can be tailored to each organization’s risk profile and business objectives. We help our clients determine the appropriate level of diligence based on the industry, jurisdiction, and nature of the third-party relationship, and can customize the investigative scope to address their specific needs and concerns.
-Global watchlist and sanctions screening
-Adverse media search
-Basic company verification
-Open-source intelligence (OSINT) Report
-UBO/beneficial ownership/mapping
-Red Flag resolution
-Site visit verification
-In-Country/Field Investigation
-HUMINT source commentary
Licensed private investigative agency (not a database aggregator)
Human-led, investigator-reviewed reports
In-country sources across 230+ countries and territories
Highly customizable scope and deliverables
Over three decades of proven results
Have questions about your risk exposure? Contact us today to request a quote, view a sample report, or schedule a consultation with a Kreller enhanced due diligence expert.
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