Tracing Foreign Ownership in FOCI Risk Assessments
The Australian Government has made FOCI assessments mandatory in technology procurement. Central to every assessment is a deceptively difficult question: who ultimately owns or controls the vendor? In this session, practitioners from Solvyr and Sayari share real-world lessons on where these assessments go wrong — and how to get them right.
Assessment
Control
FOCI assessments are now mandatory. But the question at the centre of every one — who really owns this vendor? — is harder than it looks.
The Australian Government has made FOCI assessments a core component of technology procurement, with the Department of Home Affairs releasing official guidance to help agencies identify and manage foreign ownership, control, or influence risks across their supplier base.
The problem isn’t understanding that ownership matters. It’s actually tracing it. Corporate structures can be deliberately layered across multiple jurisdictions. Nominee directors, shell vehicles, and intermediate holding companies can obscure the real controlling interest across four, five, or six ownership tiers. Critical registry records are often held in foreign languages — Mandarin, Russian, Arabic — beyond the reach of most procurement teams working with standard research tools.
In this session, Bianca Puglisi from Solvyr shares hands-on experience conducting complex beneficial ownership assessments for Australian Government clients — including the patterns that repeat, the structures that conceal, and the moments where standard research hits a wall. David Huggett from Sayari demonstrates how Sayari Graph surfaces hidden ownership relationships buried in foreign corporate registries.
Department of Home Affairs Guidance
The Department of Home Affairs has issued official guidance requiring agencies to assess foreign ownership, control, or influence as part of technology procurement decisions. Understanding the ultimate beneficial owner is central to every assessment.
Security of Critical Infrastructure Act
The SOCI Act imposes positive security obligations on owners and operators of critical infrastructure assets, including requirements to identify and manage foreign ownership risks across the supply chain.
Protective Security Policy Framework
The PSPF requires Australian Government entities to manage risks from foreign interference, including vetting suppliers for FOCI exposure as part of procurement and contract management.
What you will learn
Practitioner-focused content from teams who conduct these assessments for real. Here’s what is covered in this on-demand masterclass:
Why Tracing Ultimate Beneficial Ownership Is Harder Than It Looks
The gap between what ownership disclosures say and what corporate registries reveal — and the structural reasons that beneficial ownership is routinely underreported or obscured.
How Complex, Multi-Jurisdictional Structures Are Used to Obscure Foreign Control
Patterns from real FOCI assessments: the jurisdictions most commonly used to layer ownership, the nominee and holding company structures that conceal control, and how to recognise them.
Real-World Lessons from Beneficial Ownership Assessments
Bianca Puglisi from Solvyr shares hands-on stories from FOCI assessments in the Australian context — including where they go wrong and what a defensible assessment actually looks like.
How Sayari Graph Surfaces Hidden Ownership in Foreign Registries
A live demonstration of how Sayari Graph connects ownership records across 250+ jurisdictions — surfacing relationships that manual research and name-based screening routinely miss.
Built for procurement, security, and risk professionals
Australian Government procurement officers, ICT security advisors, whole-of-government risk managers, and compliance professionals who are responsible for identifying and managing FOCI risk in their agencies.
Practitioners who do this work.
A practitioner conversation from the people conducting FOCI assessments in the Australian context — and building the tools that power them.
Bianca is Solvyr’s lead Analyst and Operations Manager, providing advice on complex acquisitions, risk and reputational advisory and delivering Cyber Security projects across Solvyr’s corporate, Government and not-for-profit clients. Prior to joining Solvyr, Bianca served in the Australian Army as an Intelligence Analyst and then as a Cyber Security professional. During her Defence career, Bianca served throughout Australia and overseas, including in counter-terrorism operations. Bianca has been awarded an ADF Commendation for outstanding service and a US Military Commendation during operational service. She has a Bachelor of Psychology from James Cook University.
David is a Senior Solutions Consultant at Sayari, where he leverages over two decades of experience working for, and supporting, the Australian Government. He specialises in helping government and corporate clients understand and utilise intelligence solutions to address complex challenges across a variety of use cases such as enhanced due diligence. David is an experienced intelligence analyst and investigator from the Australian Intelligence Community, and has also spent the past three years supporting the Australian Government while working for Open Source Intelligence software companies.
Everything you need to know
Common questions about the session, FOCI assessments in Australia, and how Sayari supports them.
Trace ownership. Defend every FOCI assessment.
See how Sayari helps government and enterprise teams trace beneficial ownership across 250+ jurisdictions and build defensible FOCI assessments.