In this episode of Sanctions+, hosts Milana Karayanidi and Shahrzad Noorbaloochi discuss with Dina Hoffman the new “Affiliates Rule” by BIS and what it means for export controls compliance. Drawing on her experience with BIS in Germany and her current work in Kazakhstan with ECS Advisors, Dina explains aggregation across the Entity List and MEU owners, the rule of most restrictiveness, and the practical implications of new Red Flag 29 and BIS’s closer alignment with OFAC’s 50% rule. The discussion touches upon tracing the ownership to the ultimate beneficial owner, recalibrating screening beyond the Consolidated Screening List, document diligence, and preparing for increased licensing and voluntary disclosure decisions. This episode also explores the culture of Kazakhstan – from its nomadic heritage to modern life in Astana and Almaty.