SAYARI

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

HOW IT WORKS

From data to decision

MAP

Upload your supplier list

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

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.

DOCUMENT

CBP-ready report output

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

3.8B+

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

WHY SAYARI

Legacy tools vs Sayari

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

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

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

Sayari helps compliance teams navigate UFLPA (Uyghur Forced Labor Prevention Act), CBP enforcement, EU Due Diligence Directive requirements, UK Modern Slavery Act disclosures, German Supply Chain Due Diligence Act (LkSG), and emerging state-level forced labor legislation. The platform provides the sub-tier visibility needed to substantiate compliance claims to regulators.

Yes. Sayari links trade shipment data to corporate registry records, enabling procurement and compliance teams to identify suppliers with operational or ownership ties to Xinjiang – including through multi-tier supply chains where the direct tier-1 supplier is not based in Xinjiang but sources from entities that are.

Sayari combines 4B+ trade transactions with 500M+ corporate entity profiles to trace supply chains to tier-3, tier-4, and beyond. Teams can identify sub-tier exposure that would never surface through questionnaire-based due diligence, and generate documentation sufficient to rebut CBP’s statutory presumption under UFLPA.

Sayari generates traceable evidence packages linking each supplier relationship to primary-source corporate registry records, shipment histories, and geographic ownership data. This documentation supports the rebuttal standard required by CBP: clear and convincing evidence that goods were not produced with forced labor.

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