Enterprise Forced Labor Screening

UFLPA enforcement is moving up the supply chain.

CBP detentions are no longer limited to direct importers. UFLPA enforcement now reaches Tier 2 and Tier 3 suppliers – companies your direct vendor never disclosed. Sayari maps the ownership chains connecting your imports to Xinjiang-linked entities.

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THE REGULATORY REALITY

47%

of UFLPA detentions in H1 2025 involved Tier 2 or Tier 3 suppliers – entities that most importers’ direct-vendor screening programs don’t reach. Enforcement exposure now requires multi-tier supply chain visibility.

CBP UFLPA Enforcement Data · Sayari Research · H1 2025

THE PROBLEM

Why direct-supplier screening doesn’t stop UFLPA risk

The structural gaps that point solutions can’t close.

Multi-tier supply chain opacity

Direct suppliers may source components or raw materials from Xinjiang-linked entities at Tier 2 or Tier 3 – relationships your vendor never disclosed and direct-supplier screening never reaches.

Ownership linkage to UFLPA entities

A supplier may not be on the UFLPA entity list but may be majority-owned by or commercially dependent on a listed entity. Standard list-matching misses these indirect relationships.

Trade flow complexity

Raw materials and components pass through multiple processing steps and jurisdictions before reaching your direct supplier. Tracing the full chain requires trade manifest data linked to corporate ownership.

THE SAYARI APPROACH

Multi-tier supply chain visibility powered by trade data.

Sayari Map links HS code-level trade manifest data to corporate ownership networks – enabling you to trace your supply chain from direct supplier back to raw material origin, and identify UFLPA entity list connections at any tier.

Multi-Tier Supply Chain Mapping

Sayari Map traces shipment data across Tier 1, Tier 2, and Tier 3 – connecting each supplier to its trade partners and corporate ownership structure.

UFLPA Entity List Integration

Every entity in your supply chain is screened against the UFLPA entity list and the broader Sayari sanctions and enforcement database – including connected entities not directly listed.

Ownership Chain Analysis

Any supplier with connections to UFLPA-listed entities through ownership, co-directorship, or commercial relationships is flagged – not just those that appear directly on the list.

CBP-Ready Documentation

Sayari produces source-cited supply chain maps and entity reports formatted for CBP rebuttable presumption documentation – reducing detention response time.

uflpa_screening.log

> UFLPA Entity List Screen

supplier: “Guangzhou Sunrise Textile Co.”
✓ Resolved to canonical entity (CN-GZ-0887)
✓ UFLPA entity list: no direct match
⚠ Sub-tier supplier: Xinjiang source detected

> Supply Chain Trace

Tier 1: Guangzhou Sunrise Textile – CLEAR
Tier 2: Lop Nur Cotton Growers Co-op (CN)
✗ UFLPA designated entity – CBP hold required

shipment.hold(entry=”2024-SC-88712″, reason=”UFLPA”) → CBP notified

Sayari Graph – UFLPA & supply chain forced labor screen

On this page

The Problem
Sayari's approach
How it works
Results
Platform

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Se this live on your data

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HOW IT WORKS

From data to decision

01 – MAP

Upload your supplier list

Submit your direct vendor list or individual supplier names. Sayari resolves each entity and begins supply chain traversal.

02 – TRACE

Multi-tier trade and ownership analysis

Sayari Map traces trade flows backward from each supplier, linking shipment data to corporate ownership networks to identify Tier 2/3 exposure.

03 – DOCUMENT

CBP-ready report output

Receive a source-cited supply chain map, UFLPA entity flag report, and documentation package formatted for CBP detention response.

3.8+B+

Trade records in Sayari Map for supply chain tracing

Sayari Map integrates billions of global trade manifest records with corporate ownership data – giving compliance teams the multi-tier supply chain visibility that UFLPA enforcement now requires, without years of supplier audit programs.

Sayari Research · 2025</small?

WHY SAYARI

Legacy tools vs Sayari

SAYARI

Multi-tier supply chain mapping – Sayari Map traces trade flows through Tier 2 and Tier 3
Ownership-linked UFLPA screening – flags suppliers connected to listed entities through corporate structure
Trade manifest analysis – HS code-level shipment data linked to corporate ownership networks
CBP-ready documentation – source-cited reports formatted for detention response

LEGACY TOOLS

Direct-supplier screening only – no Tier 2/3 visibility into sub-supplier relationships
UFLPA entity list matching only – misses suppliers connected to listed entities through ownership
No trade flow data – can’t trace raw material origin through processing tiers
Manual documentation process for CBP detention response

CLIENT RESULTS

Measured outcomes from production deployments

COVERAGE

Tier 3

Supply chain depth reachable through Sayari Map trade flow analysis

SPEED

60%↓

Reduction in CBP detention response time with Sayari documentation package

ACCURACY

3.8B+

Trade records integrated in Sayari Map for supply chain tracing

PRODUCTS FOR THIS USE CASE

Sayari products that power this workflow

Sayari Graph

Entity resolution and ownership graph for 500M+ companies across 250+ jurisdictions.

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Sayari MAP

Trade-flow intelligence mapping shipment data to corporate ownership networks.

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Sayari Signal

Continuous monitoring that alerts on meaningful changes across your counterparty base.

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FREQUENTLY ASKED QUESTIONS

Common questions about this use case

What forced labor regulations does Sayari help companies comply with?

Can Sayari identify suppliers connected to the Xinjiang region?

How far down the supply chain can Sayari trace forced labor exposure?

What evidence can Sayari provide to support a UFLPA rebuttal?

GET STARTED

Map your supply chain for UFLPA exposure.

Request a demo to see Sayari Map trace your supply chain for Xinjiang-linked connections.

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