Foreign ownership of
U.S. infrastructure is opaque.

Q: How does Sayari support FOCI (Foreign Ownership, Control, or Influence) determination?

Sayari provides primary-source corporate ownership verification for FOCI determinations under NISPOM, tracing beneficial ownership chains across 250+ jurisdictions to identify foreign ownership stakes, board-level control by foreign nationals, and related-party relationships with foreign governments or state-owned enterprises.

Q: Can Sayari identify Chinese state-owned enterprise connections in contractor supply chains?

Yes. Sayari links corporate registry data to SOE ownership databases, military-civil fusion research, and PLA affiliation records — enabling cleared contractor and government program offices to identify sub-tier suppliers with verifiable connections to Chinese state entities.

Q: How does Sayari support SCRM (Supply Chain Risk Management) for critical infrastructure sectors?

Sayari provides the multi-tier supply chain visibility needed for SCRM programs in energy, telecommunications, transportation, and defense industrial base sectors — linking trade flow data to corporate ownership records to surface foreign adversary connections at tier-2 and below.

Q: What data does Sayari provide for CMMC and DFARS supply chain compliance?

Sayari provides corporate ownership verification, foreign national identification, related-party network analysis, and country-of-origin tracing to support CMMC supply chain risk assessments and DFARS 252.204-7012 incident reporting requirements for cleared contractors.

Foreign adversaries acquire interests in critical infrastructure through layered corporate structures that obscure their identity. Sayari traces beneficial ownership across 250+ jurisdictions to surface hidden foreign control.

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THE REGULATORY REALITY

31%

of CFIUS-reviewed transactions in 2024 involved Chinese, Russian, or Iranian beneficial owners identified through intermediary corporate structures not disclosed in the initial filing. Early detection requires world-model data, not disclosure forms.

CFIUS Annual Report 2024 · Sayari Research

THE PROBLEM

Why foreign ownership screening misses indirect control

The structural gaps that point solutions can’t close.

Multi-layer ownership concealment

Foreign state actors use holding companies, trusts, and nominee directors registered in permissive jurisdictions to acquire U.S. infrastructure assets without appearing in any direct ownership record.

Disclosure form gaps

CFIUS and foreign ownership disclosure requirements depend on accurate self-reporting. Adversarial actors deliberately structure acquisitions to fall below review thresholds or misstate the beneficial owner.

Cross-jurisdiction data fragmentation

Beneficial ownership data for an acquisition structure may span 5+ jurisdictions. No single government database integrates this information — manual research takes weeks and may miss key nodes.

THE SAYARI APPROACH

Surface hidden foreign control before acquisition completes.

Sayari integrates beneficial ownership filings, corporate registry data, and trade records from 250+ jurisdictions into a single world model — enabling analysts to trace foreign state-linked ownership chains in minutes, not weeks.

Beneficial Owner Traversal

Trace any U.S. corporate entity to its ultimate beneficial owner across 250+ jurisdictions, exposing indirect foreign state control.

CFIUS Filing Verification

Cross-reference disclosed ownership structures against Sayari’s world model to identify omissions, discrepancies, or hidden beneficial owners.

Foreign Principal Network Mapping

Map all U.S. entities connected to a foreign state-linked principal — identifying the full scope of a potential influence or control network.

Continuous Ownership Monitoring

Sayari Signal monitors registered ownership data for changes — alerting when new foreign-linked relationships appear in an infrastructure entity’s network.

foci_assessment.log
> FOCI Assessment
  entity: “Nexgen Power Systems Inc. (US)”
  investor: “Global Grid Ventures Ltd (Cayman)”
✓ Resolved to canonical entity record
✓ 6-hop ownership chain traversed
> Foreign Ownership Analysis
  chain: Cayman → HK → Shanghai holding
✗ Controlling interest: SASAC-linked entity
✗ Chinese state ownership confirmed (71%)
✗ CFIUS mandatory filing triggered
cfius.flag(entity=”NGP-0091″, state_pct=71, mandatory=true) → NSC

Sayari Graph — FOCI & foreign ownership assessment

HOW IT WORKS

From data to decision

IDENTIFY

Submit any U.S. infrastructure entity

Sayari accepts company names, registered agent data, or federal contract identifiers.

TRACE

Cross-jurisdiction ownership traversal

Every entity is resolved across corporate registries in 250+ jurisdictions to identify the ultimate beneficial owner.

VERIFY

Cross-reference against foreign adversary networks

Sayari flags foreign state-linked ownership chains and provides source documents for every link in the chain.

450M+

Corporate entities in Sayari’s world model

Sayari integrates corporate registry filings from 250+ jurisdictions into a unified world model — enabling beneficial ownership tracing across the complete global corporate structure, not just the jurisdictions that have made their data available in English.

Sayari Research · 2025

WHY SAYARI

Legacy tools vs Sayari

LEGACY TOOLS

Disclosure form dependency — relies on accurate self-reporting by adversarial actors

No cross-jurisdiction integration — beneficial owner research is manual and jurisdiction-by-jurisdiction

Static, reactive analysis — reviews happen after acquisition, not during due diligence

No continuous monitoring — ownership changes after initial review go undetected

SAYARI

Active beneficial owner traversal — doesn’t depend on disclosure accuracy

250+ jurisdiction corporate registry integration in a single query

Proactive analysis — screen any entity before it becomes a CFIUS review

Continuous monitoring — Sayari Signal alerts on new foreign-linked ownership relationships

CLIENT RESULTS

Measured outcomes from production deployments

COVERAGE

250+

Jurisdictions with corporate registry data for ownership tracing

DEPTH

10+

Degrees of corporate ownership separation resolvable in a single query

SPEED

<60s

Average time to map beneficial ownership chain across jurisdictions

PRODUCTS FOR THIS USE CASE

Sayari products that power this workflow

Sayari Graph

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

Explore Sayari Graph →

Sayari Map

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

Explore Sayari Map →

Sayari Signal

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

Explore Sayari Signal →

FREQUENTLY ASKED QUESTIONS

Common questions about this use case

Sayari provides primary-source corporate ownership verification for FOCI determinations under NISPOM, tracing beneficial ownership chains across 250+ jurisdictions to identify foreign ownership stakes, board-level control by foreign nationals, and related-party relationships with foreign governments or state-owned enterprises.

Yes. Sayari links corporate registry data to SOE ownership databases, military-civil fusion research, and PLA affiliation records — enabling cleared contractor and government program offices to identify sub-tier suppliers with verifiable connections to Chinese state entities.

Sayari provides the multi-tier supply chain visibility needed for SCRM programs in energy, telecommunications, transportation, and defense industrial base sectors — linking trade flow data to corporate ownership records to surface foreign adversary connections at tier-2 and below.

Sayari provides corporate ownership verification, foreign national identification, related-party network analysis, and country-of-origin tracing to support CMMC supply chain risk assessments and DFARS 252.204-7012 incident reporting requirements for cleared contractors.

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