Responsible buyer
Operations, finance, compliance, and program owners accountable for Bis Affiliates Ownership Diligence.
Review desk · readiness grid
AffiliateClear
See exactly what is ready, missing, and blocked in Bis Affiliates Ownership Diligence.
Pain exists because CSL name screening is no longer enough under the Affiliates Rule; BIS created an affirmative duty to determine ownership; opaque registries (China/Russia/etc.) defeat DIY spreadsheet work; big-law rates make portfolio re-screens expensive; and enterprise screening platforms sell data/tools, not DFY pack delivery for mid-market export compliance managers.
affiliateclearbisaffiliatesownershipdiligence
Who this is for
A precise operating owner, not a generic audience.
Cost of the gap
AffiliateClear sells a finished Affiliates Rule Ownership Diligence Pack : for a capped set of foreign counterparties, the company delivers ownership trees (direct/indirect/aggregated), Entity List / MEU / §744.8 SDN ownership hits, a clear 50%-threshold determination (or unresolved Red Flag 29 memo), questionnaire artifacts, and an audit-ready diligence binder so the exporter can hold, escalate, or license before the November 10, 2026 snapback — without operating a screening SaaS themselves.
Outcome
Exclusions: Not legal advice; not a BIS license filing unless separately scoped with counsel; not OFAC blocking determinations; not ECCN classification (separate product).
Decision rule
Proceed only when the source record, service boundary, responsible reviewer, and release criteria can be named before work begins.
Method
The work moves through visible states.
- Scope12 AI-vs-human operations pipeline AI Entity resolve + list screen → AI Registry scrape / extract → Rules 50% aggregate calc → AI Draft memo → Specialist Chokepoint QA → QA Audit trail check → Customer Receive binder Licensed counsel engaged only on escalation (license strategy, voluntary disclosure, contested ownership)—not on every Clear determination.
- CollectCollect only the source records required for the agreed work.
- NormalizeNormalize records and preserve file-level provenance.
- ValidateRun deterministic completeness and consistency checks.
- ResolveRoute missing, conflicting, or unsupported items to an exception queue.
- ReviewHave a qualified human review the release candidate.
- ReleaseRelease the final pack with an audit trail and correction path.
Engagement
Buy the reviewed outcome, with boundaries written down.
15 Pricing, pricing legality & unit economics SKU Unit Price (fixed) Portfolio Diligence Pack (≤50 counterparties) Pack $8,000–$14,000 Portfolio Diligence Pack (51–200) Pack $14,000–$28,000 Deep-dive opaque counterparty Party $750–$2,500 Monitoring & refresh retainer Month $2,000–$6,000 Why not hourly: Buyers buy a determination binder outcome, not hours. Hourly recreates law-firm economics. Pricing legality: Fixed fees for diligence facilitation are standard. Avoid contingency on “penalty avoided.” Do not share in recovered funds.
Release package
- 10 The outcome we sell Deliverable
- Portfolio Ownership Diligence Pack (MVP) Counterparty master list with risk tiers Ownership graph PDFs for each in-scope party (up to agreed cap) Listed-owner hit table (Entity List / MEU / §744.8 SDN) with aggregate % Determination: Clear / Covered Affiliate / Unresolved Red Flag 29 Questionnaire pack + evidence appendix (registry extracts, filings, news) Specialist-signed cover memo + audit trail Acceptance: Every in-scope counterparty has a determination label + evidence folder; unresolved items include documented best-efforts log suitable for license-application narrative.
- Exclusions: Not legal advice; not a BIS license filing unless separately scoped with counsel; not OFAC blocking determinations; not ECCN classification (separate product).
- Rework: Free correction if factual ownership source was available at delivery and omitted; no refund for later ownership changes (monitoring SKU).
Proof standard
Operating evidence: No verified cycle-time result is published yet. The first result will be calculated from accepted intake through qualified-human release.
Client evidence: No client identity or case narrative is published. A reference may appear only after written permission and factual review.
Volume evidence: No completed-client count is claimed. Counts will be published only after the delivery ledger and provider records reconcile.
Evidence room
Authority comes from traceable sources, not decorative claims.
- Federal Register — One Year Suspension / Snapback of Affiliates Rule (90 FR 50857)Source identified in the canonical blueprint; verify currency before client reliance.
- WilmerHale — Affiliates Rule diligence obligationsSource identified in the canonical blueprint; verify currency before client reliance.
- Debevoise — Commerce expands export-controls to affiliatesSource identified in the canonical blueprint; verify currency before client reliance.
- MoFo — Affiliates Rule implicationsSource identified in the canonical blueprint; verify currency before client reliance.
- ArentFox Schiff — CSL insufficient; Red Flag 29Source identified in the canonical blueprint; verify currency before client reliance.
- Morgan Lewis — Affirmative ownership responsibilitySource identified in the canonical blueprint; verify currency before client reliance.
- Gibson Dunn — Watershed Affiliates Rule analysisSource identified in the canonical blueprint; verify currency before client reliance.
- Wilson Sonsini — Formal one-year suspensionSource identified in the canonical blueprint; verify currency before client reliance.
Service boundary
Automation prepares. A qualified human releases.
AffiliateClear is an operational documentation and processing service operated by Your Deputy, Obuke LLC. It is not a law firm and does not provide legal, tax, medical, financial, or other licensed professional advice. Consumer and personal debt matters are not accepted. The client retains its licensed professionals and decision authority. Automation may organize and check records, but a qualified human must review and release every client deliverable. Minimum-necessary data handling and professional review apply.
- Unsupported facts remain unresolved, never inferred into a client deliverable.
- Jurisdiction-specific or licensed questions are routed to the client's professional.
- Every correction retains the source, reviewer, version, and reason for change.
Questions
Know the limits before intake.
Is this legal or professional advice?
No. This is bounded operational documentation and processing support. Licensed judgment remains with the client and its professionals.
Does automation make the final decision?
No. It can organize records, run declared checks, and prepare an exception queue. A qualified human reviews and releases every deliverable.
Is a client portal or CRM already active?
This public site does not claim an active portal integration. Portal access is provisioned only after the relevant backend is configured and independently verified.
What happens when evidence conflicts?
The item is placed in an exception state with its sources and owner. It is not silently resolved or presented as verified.
Fit diagnostic
Send enough context to scope the next conversation—no sensitive files.
Do not submit protected health information, personal financial data, credentials, or confidential client records through this public page.