#3 U.S. Telecom
Eight hundred critical infrastructure vendors screened for foreign ownership in 90 days, under a regulatory deadline.
~800 Critical infrastructure vendors
500M+ Companies in ownership graph
Continuous Monitoring
Challenge
Two regulations converged with no automated screening capability
Solution
Ownership-chain analysis across 500M+ companies
Result
Eight hundred vendors screened, continuous FOCI monitoring deployed
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In This Case Study
Two regulations converged with no automated screening capability
FCC rip-and-replace mandates and PADFA created an immediate, high-volume screening requirement. The carrier had only manual research and self-attestation — methods that could not deliver the volume, speed, or depth required.
Ownership-chain analysis across 500M+ companies
The carrier deployed an investigative platform giving analysts direct access to ownership chain analysis, beneficial ownership resolution, and foreign government connection identification.
Eight hundred vendors screened, continuous FOCI monitoring deployed
The TPRM team completed the FCC compliance screen and generated documentation; the legal team established a repeatable PADFA evaluation process for every new data-sharing relationship.
The challenge
Your vendors passed sanctions screening. Their owners were not checked.
One of the top three U.S. telecommunications carriers faced a dual compliance challenge. The TPRM team needed to screen approximately 800 critical infrastructure vendors for FOCI exposure as part of the FCC rip-and-replace mandate. Simultaneously, the legal and compliance team needed to evaluate data-sharing partners under PADFA to identify any foreign adversary connections in their vendor ecosystem.
There was no automated screening capability in place. The carrier’s existing vendor management processes relied on manual research and self-attestation — methods that could not deliver the volume, speed, or depth required by the new regulations. Screening 800 vendors for ownership chains, beneficial ownership connections, and foreign government ties required a fundamentally different approach.
- FCC rip-and-replace mandate + PADFA created an immediate dual compliance requirement
- No automated screening capability — only manual research and self-attestation
- ~800 critical infrastructure vendors needed FOCI exposure assessment
- Self-attestation cannot reveal foreign government ties hidden in ownership chains
The solution
PADFA-specific FOCI screening with primary-source registry evidence
The carrier deployed an investigative platform for FOCI screening, giving analysts direct access to ownership chain analysis, beneficial ownership resolution, and foreign government connection identification across 500M+ companies. The platform’s graph architecture allowed the team to trace vendor ownership structures through multiple jurisdictions and identify connections to foreign adversary entities that self-attestation questionnaires would never reveal.
For the PADFA use case, the legal team used the same platform to evaluate data-sharing partners, screening for foreign adversary ownership and control indicators that would trigger restrictions under the new law.
- Primary-source corporate data layer feeds the company’s proprietary risk scoring
- 500M+ companies in 250+ jurisdictions — entity identity, ownership, relationships
- Graph architecture surfaces non-obvious shared ownership, SOE, and MCF connections
Sayari capabilities used
The results
FOCI screening embedded in vendor qualification – continuously
The carrier now operates with continuous FOCI monitoring across its critical infrastructure vendor base. The compliance team that scrambled to screen 800 vendors under regulatory deadline pressure now runs ongoing surveillance that catches ownership changes, new sanctions designations, and emerging FOCI indicators as they occur. The PADFA compliance framework built during the initial evaluation serves as a repeatable process for every new data-sharing relationship.
~800
Critical infrastructure vendors screened for FOCI
250+
Jurisdictions for ownership chain tracing
Continuous
Surveillance flags ownership changes and emerging FOCI indicators
“We can now independently verify vendor ownership claims against authoritative source data, rather than relying on vendor self-reporting.”
Head of TPRM
#3 U.S. Telecom
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