Risk factors are included on entity profiles in Sayari Graph to provide enhanced insight into risk type and severity. This page documents the different levels and types of risk in Sayari Graph.
Adverse Media Risk Factors
Bribery and Corruption (from Adverse Media)
Key: reputational_risk_bribery_and_corruption
Level: elevated
Category: adverse_media
The entity has been mentioned by official government websites or mass media outlets as wanted, charged, indicted, prosecuted, convicted, or sentenced for criminal activity related to bribery and corruption.
Cybercrime (from Adverse Media)
Key: reputational_risk_cybercrime
Level: elevated
Category: adverse_media
The entity has been mentioned by official government websites or mass media outlets as wanted, charged, indicted, prosecuted, convicted, or sentenced for criminal activity related to cybercrime.
Financial Crime (from Adverse Media)
Key: reputational_risk_financial_crime
Level: elevated
Category: adverse_media
The entity has been mentioned by official government websites or mass media outlets as wanted, charged, indicted, prosecuted, convicted, or sentenced for criminal activity related to financial crime.
Forced Labor and Modern Slavery (from Adverse Media)
Key: reputational_risk_forced_labor
Level: elevated
Category: adverse_media
The entity has been mentioned by official government websites or mass media outlets as wanted, charged, indicted, prosecuted, convicted, or sentenced for criminal activity related to forced labor and modern slavery.
Law Enforcement Action (from Adverse Media)
Key: law_enforcement_action
Level: elevated
Category: adverse_media
The entity has been mentioned by official government websites or mass media outlets as wanted, charged, indicted, prosecuted, convicted, or sentenced in relation to a law enforcement action.
Organized Crime (from Adverse Media)
Key: reputational_risk_organized_crime
Level: elevated
Category: adverse_media
The entity has been mentioned by official government websites or mass media outlets as wanted, charged, indicted, prosecuted, convicted, or sentenced for criminal activity related to organized crime.
Other Reputational Risk (from Adverse Media)
Key: reputational_risk_other
Level: elevated
Category: adverse_media
The entity has been mentioned by official government websites or mass media outlets as wanted, charged, indicted, prosecuted, convicted, or sentenced for criminal activity related to other reputational risk.
Terrorism (from Adverse Media)
Key: reputational_risk_terrorism
Level: elevated
Category: adverse_media
The entity has been mentioned by official government websites or mass media outlets as wanted, charged, indicted, prosecuted, convicted, or sentenced for criminal activity related to terrorism.
Export Controls Risk Factors
Entity Displays Active License from Federal Security Service of the Russian Federation (FSB RF)
Key: entity_licensed_with_fsb_rf
Level: high
Category: export_controls
The entity displays an active license from the Federal Security Service of the Russian Federation (FSB RF), which allows companies to work on projects classified as a state secret.
Entity Exports to Entity that Displays Active License from FSB RF
Key: exports_to_entity_licensed_with_fsb_rf
Level: high
Category: export_controls
The entity has possibly directly exported to an entity that displays an active license from the Federal Security Service of the Russian Federation (FSB RF), which allows companies to work on projects classified as a state secret (1 hop away). Per FinCEN and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), transactions with these companies is a potential red flag indicator of export control evasion in effort to procure EAR99 items. Consideration of this indicator, in conjunction with conducting appropriate risk-based customer and transactional due diligence, will assist in determining whether an identified activity may be connected to export control evasion.
Export Control Lists
Key: export_controls
Level: critical
Category: export_controls
The entity is subject to trade restrictions per the U.S. Consolidated Screening List, a list of parties for which the United States government maintains restrictions on certain exports, reexports, or transfers of items.
Exports Components in USA Bureau of Industry and Security (BIS) Common High Priority Items List
Key: exports_bis_high_priority_items
Level: elevated
Category: export_controls
The entity has possibly directly or indirectly exported to Russia, Belarus, or Iran one or more shipments with Harmonized System (HS) codes corresponding to critical U.S. components that Russia relies on for its weapons systems (1-3 hops away). These HS codes are listed in Tiers 3.A, 3.B, 4.A, and 4.B of the U.S. Bureau of Industry and Security’s Common High Priority List (CHPL). The BIS has developed the CHPL in collaboration with the European Union, Japan, and the United Kingdom.
Exports Critical Components in USA Bureau of Industry and Security (BIS) Common High Priority Items List
Key: exports_bis_high_priority_items_critical_components
Level: high
Category: export_controls
The entity has possibly directly or indirectly exported to Russia, Belarus, or Iran one or more shipments with Harmonized System (HS) codes corresponding to critical U.S. components that Russia relies on for its weapons systems (1-3 hops away). These HS codes listed in Tier 1 and Tier 2 of the U.S. Bureau of Industry and Security’s Common High Priority List (CHPL) are subject to the most comprehensive controls under the Export Administration Regulations (15 CFR Parts 730 – 774) (EAR), meaning a license is required for items associated with these HS codes destined for these jurisdictions, including certain foreign-produced items. The BIS has developed the CHPL in collaboration with the European Union, Japan, and the United Kingdom.
Government Contractors in USA Bureau of Industry and Security (BIS) Military End User (MEU) Country
Key: meu_list_contractors
Level: high
Category: export_controls
The entity appears on a Chinese, Russian, and/or Venezuelan government list of entities authorized to procure and contract with that government. Because of their statuses as approved contractors for those governments, these entities may satisfy the criteria to be considered “military end users.” This designation represents an unacceptable risk of use in or diversion to a “military end use” or “military end user” in the countries listed above.
Imports Components in USA Bureau of Industry and Security (BIS) Common High Priority Items List
Key: imports_bis_high_priority_items
Level: elevated
Category: export_controls
The entity has imported one or more shipments with HS codes corresponding to critical U.S. components that Russia relies on for its weapons systems. These HS codes are listed in Tiers 3.A, 3.B, 4.A, and 4.B of the U.S. Bureau of Industry and Security’s Common High Priority List (CHPL). The BIS has developed the CHPL in collaboration with the European Union, Japan, and the United Kingdom.
Imports Critical Components in USA Bureau of Industry and Security (BIS) Common High Priority Items List
Key: imports_bis_high_priority_items_critical_components
Level: high
Category: export_controls
The entity has imported one or more shipments with HS codes corresponding to critical U.S. components that Russia relies on for its weapons systems. These HS codes listed in Tier 1 and Tier 2 of the U.S. Bureau of Industry and Security’s Common High Priority List (CHPL) are subject to the most comprehensive controls under the Export Administration Regulations (15 CFR Parts 730 – 774) (EAR), meaning a license is required for items associated with these HS codes destined for these jurisdictions, including certain foreign-produced items. The BIS has developed the CHPL in collaboration with the European Union, Japan, and the United Kingdom.
Owned by Entity in Export Controls List
Key: owned_by_entity_in_export_controls
Level: high
Category: export_controls
The entity is possibly owned (minority, majority, or wholly) by an entity in an export controls list up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch. Applicable to entities globally.
Owned by Entity in USA Commerce BIS MEU List
Key: owned_by_bis_meu_entity
Level: high
Category: export_controls
The entity is possibly owned (minority, majority, or wholly) by an entity listed in the USA Department of Commerce Bureau of Industry and Security (BIS) Military End User (MEU) List up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch. Applicable to entities globally.
Owned by Entity in USA NDAA Section 1260H List
Key: owned_by_section_1260h_entity
Level: high
Category: export_controls
The entity is possibly owned (minority, majority, or wholly) by an entity listed in the USA Department of Defense 1260H List up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch. Applicable to entities globally.
Owner of Entity in Export Controls List
Key: owner_of_export_controls_entity
Level: high
Category: export_controls
The entity possibly owns (minority, majority, or wholly) an export-controlled entity up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch. Applicable to entities globally.
Possibly the Same As (PSA) Entity Displays Active License from Federal Security Service of the Russian Federation (FSB RF)
Key: psa_entity_licensed_with_fsb_rf
Level: high
Category: export_controls
The entity is possibly the same as an entity that displays an active license from the Federal Security Service of the Russian Federation (FSB RF), which allows companies to work on projects classified as a state secret. The entities did not meet the threshold required to merge them into a single entity, but they may be the same.
Possibly the Same As (PSA) Entity in Export Controls List
Key: psa_export_controls
Level: critical
Category: export_controls
The entity is Possibly the Same As (PSA) an entity subject to export controls. The entities did not meet the threshold required to merge them into a single entity, but they are likely the same.
Related to Export Controls
Key: export_controls_adjacent
Level: elevated
Category: export_controls
The entity is 1 hop away from an entity subject to export controls. Applies to all relationship types that do not signify ownership.
Forced Labor Risk Factors
Entity from ASPI Forced Labor Report
Key: aspi_uyghur_forced_labor_report_entity
Level: high
Category: forced_labor
The entity is named in the Australian Strategic Policy Institute’s report, “Uyghurs for sale: ‘Re-education’, forced labour and surveillance beyond Xinjiang.” The ASPI has identified entities that are using Uyghur labour transferred from Xinjiang since 2017.
Entity from Sheffield Hallam University Forced Labor Reports
Key: sheffield_hallam_university_forced_labor_entity
Level: critical
Category: forced_labor
The entity is named in Sheffield Hallam University Forced Labor Reports for having reasonable evidence of the use of forced labor in the XUAR (Xinjiang Uygur Autonomous Region) through the manufacturing or production of goods.
Entity from Sheffield Hallam University Useful Resources
Key: sheffield_hallam_university_useful_resources
Level: elevated
Category: forced_labor
This entity appears in the “Companies Operating in the Uyghur Region” dataset published by Sheffield Hallam University. The dataset was collected from a human resources website in December 2021.
Forced Labor Risk (Direct Trade History with ASPI Entity)
Key: forced_labor_aspi_origin_direct
Level: elevated
Category: forced_labor
Historical shipment records indicate that the entity has possibly traded directly with an entity named in the Australian Strategic Policy Institute’s report, “Uyghurs for sale: ‘Re-education’, forced labour and surveillance beyond Xinjiang,” less than two years ago (1 hop away). Applicable to entities globally.
Forced Labor Risk (Direct Trade History with Entity from Sheffield Hallam University Forced Labor Reports)
Key: forced_labor_sheffield_hallam_university_reports_origin_direct
Level: high
Category: forced_labor
Historical shipment records indicate that the entity has possibly traded directly with an entity named in Sheffield Hallam University Forced Labor Reports less than two years ago. Applicable to entities globally.
Forced Labor Risk (Direct Trade History with WRO Entity)
Key: forced_labor_wro_origin_direct
Level: high
Category: forced_labor
Historical shipment records indicate that the entity has possibly traded directly with a Withhold Release Orders (WRO) entity less than two years ago (1 hop away). Applicable to entities globally.
Forced Labor Risk (Direct Trade History with Xinjiang Entities)
Key: forced_labor_xinjiang_origin_direct
Level: high
Category: forced_labor
Historical shipment records indicate that the entity has possibly traded directly with a Xinjiang-based entity less than two years ago (1 hop away). Applicable to entities globally.
Forced Labor Risk (Direct Trade History with Xinjiang Import Controls Designated Entity)
Key: forced_labor_uflpa_origin_direct
Level: high
Category: forced_labor
Historical shipment records indicate that the entity has possibly traded directly with an entity listed in the U.S. Department of Homeland Security’s “Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China,” also known as the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, less than two years ago (1 hop away). Applicable to entities globally.
Forced Labor Risk (Entity Located in Xinjiang)
Key: forced_labor_xinjiang_geospatial
Level: high
Category: forced_labor
Geographic coordinates indicate that the entity is based in Xinjiang, China, a region designated as high risk for forced labor practices. Excludes entities exclusively derived from trade data sources.
Forced Labor Risk (Entity Registered in Xinjiang)
Key: forced_labor_xinjiang_registration
Level: high
Category: forced_labor
The entity has a Uniform Social Credit Code (USCC) and/or registration number that indicates the entity is registered in Xinjiang, China, a region designated as high risk for forced labor practices. Applicable to entities globally.
Forced Labor Risk (Keywords Found in Company Attributes)
Key: forced_labor_china_keywords
Level: high
Category: forced_labor
The company name, address, or business purpose contains keywords that reference potential prison labor: “prison” or “laogai”. Applicable to China-based entities only.
Forced Labor Risk (Owned by Xinjiang-Based Entity)
Key: owned_by_xinjiang_entity
Level: high
Category: forced_labor
The entity is possibly owned (minority, majority, or wholly) by a Xinjiang-based entity up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch. Applicable to entities globally.
Forced Labor Risk (Owner of Xinjiang-Based Entity)
Key: owner_of_forced_labor_xinjiang_entity
Level: high
Category: forced_labor
The entity possibly owns (minority, majority, or wholly) a Xinjiang-based entity up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch. Applicable to entities globally.
Forced Labor Risk (Subtier Trade History with ASPI Entity)
Key: forced_labor_aspi_origin_subtier
Level: elevated
Category: forced_labor
Historical shipment records indicate that the entity has possibly traded indirectly with an entity named in the Australian Strategic Policy Institute’s report, “Uyghurs for sale: ‘Re-education’, forced labour and surveillance beyond Xinjiang,” that is 2 or 3 hops away. Applicable to entities globally.
Forced Labor Risk (Subtier Trade History with Entity from Sheffield Hallam University Forced Labor Reports)
Key: forced_labor_sheffield_hallam_university_reports_origin_subtier
Level: high
Category: forced_labor
Historical shipment records indicate that the entity has possibly traded indirectly with an entity named in Sheffield Hallam University Forced Labor Reports that is 2 or 3 hops away. Applicable to entities globally.
Forced Labor Risk (Subtier Trade History with WRO Entity)
Key: forced_labor_wro_origin_subtier
Level: high
Category: forced_labor
Historical shipment records indicate that the entity has possibly traded indirectly with a Withhold Release Orders (WRO) entity that is 2 or 3 hops away. Applicable to entities globally.
Forced Labor Risk (Subtier Trade History with Xinjiang Entities)
Key: forced_labor_xinjiang_origin_subtier
Level: high
Category: forced_labor
Historical shipment records indicate that the entity has possibly traded indirectly with a Xinjiang-based entity (2-3 hops away). Applicable to entities globally.
Forced Labor Risk (Subtier Trade History with Xinjiang Import Controls Designated Entity)
Key: forced_labor_uflpa_origin_subtier
Level: high
Category: forced_labor
Historical shipment records indicate that the entity has possibly traded indirectly with an entity listed in the U.S. Department of Homeland Security’s “Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China,” also known as the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, (2-3 hops away). Applicable to entities globally.
Forced Labor Risk (XPCC Contractors)
Key: forced_labor_xinjiang_contractors
Level: high
Category: forced_labor
The entity appears on a government list of entities authorized to procure and contract with the Xinjiang Production and Construction Corps (XPCC). The U.S. Department of the Treasury has designated the XPCC a paramilitary organization subordinate to the Chinese Communist Party (CCP) engaged in human rights abuses in Xinjiang, including forced labor.
Forced Labor Risk (Xinjiang Import Controls Designation)
Key: forced_labor_xinjiang_uflpa
Level: critical
Category: forced_labor
The entity is listed in the U.S. Department of Homeland Security’s “Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China,” also known as the Uyghur Forced Labor Prevention Act (UFLPA) Entity List. Entities in the United States are prohibited from importing goods made wholly or in part with forced labor into the United States in an effort to end the systematic use of forced labor in the Xinjiang Uyghur Autonomous Region.
Forced Labor Risk (Xinjiang Keywords)
Key: forced_labor_xinjiang_name
Level: high
Category: forced_labor
The name suggests the entity may conduct business in Xinjiang, a region designated as high risk for forced labor practices. Applied to entities derived from Chinese and trade data sources.
Forced Labor Risk (Xinjiang Operations)
Key: forced_labor_xinjiang_operations
Level: high
Category: forced_labor
The entity has authorization to conduct operations and/or is involved in contracting activities in Xinjiang, a region designated as high risk for forced labor practices.
Forced Labor and Modern Slavery (from Adverse Media)
Key: reputational_risk_forced_labor
Level: elevated
Category: forced_labor
The entity has been mentioned by official government websites or mass media outlets as wanted, charged, indicted, prosecuted, convicted, or sentenced for criminal activity related to forced labor and modern slavery.
Former WRO Entity
Key: former_wro_entity
Level: high
Category: forced_labor
The entity was formerly subject to trade restrictions per the U.S. Customs and Border Protection (CBP) Withhold Release Orders (WRO) and Findings List, a list of parties for which the United States Government has reasonable evidence of the use of forced labor in the manufacturing or production of a good or goods entering the U.S. supply chain.
Intermediary Entity from Sheffield Hallam University Forced Labor Reports
Key: sheffield_hallam_university_forced_labor_reports_intermediary_entity
Level: high
Category: forced_labor
The entity is named in Sheffield Hallam University Forced Labor Reports for having reasonable evidence of serving as an intermediary manufacturer and/or downstream customer with one or more trading relationships with Chinese companies sourcing materials from the XUAR (Xinjiang Uygur Autonomous Region).
Owned by ASPI Forced Labor Report Entity
Key: owned_by_aspi_forced_labor_entity
Level: elevated
Category: forced_labor
The entity is possibly owned (minority, majority, or wholly) by an entity named in the Australian Strategic Policy Institute’s report, “Uyghurs for sale: ‘Re-education’, forced labour and surveillance beyond Xinjiang,” up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch. Applicable to entities globally.
Owned by Entity from Sheffield Hallam University Forced Labor Reports
Key: owned_by_sheffield_hallam_university_reports_forced_labor_entity
Level: high
Category: forced_labor
The entity is possibly owned (minority, majority, or wholly) by an entity named in Sheffield Hallam University Forced Labor Reports up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch. Applicable to entities globally.
Owned by Forced Labor Risk Entity (Xinjiang Import Controls Designation)
Key: owned_by_forced_labor_xinjiang_uflpa
Level: high
Category: forced_labor
The entity is possibly owned (minority, majority, or wholly) by an entity listed in the U.S. Department of Homeland Security’s “Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China,” also known as the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch.
Owned by WRO Entity
Key: owned_by_wro_entity
Level: high
Category: forced_labor
The entity is possibly owned (minority, majority, or wholly) by a Withhold Release Orders (WRO) entity up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch. Applicable to entities globally.
Owner of ASPI Forced Labor Report Entity
Key: owner_of_aspi_forced_labor_entity
Level: elevated
Category: forced_labor
The entity possibly own (minority, majority, or wholly) an entity named in the Australian Strategic Policy Institute’s report, “Uyghurs for sale: ‘Re-education’, forced labour and surveillance beyond Xinjiang,” up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch. Applicable to entities globally.
Owner of Entity from Sheffield Hallam University Forced Labor Reports
Key: owner_of_sheffield_hallam_university_reports_forced_labor_entity
Level: high
Category: forced_labor
The entity possibly owns (minority, majority, or wholly) an entity named in Sheffield Hallam University Forced Labor Reports up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch. Applicable to entities globally.
Owner of Forced Labor Risk Entity (Xinjiang Import Controls Designation)
Key: owner_of_forced_labor_xinjiang_uflpa
Level: high
Category: forced_labor
The entity possibly owns (minority, majority, or wholly) an entity listed in the U.S. Department of Homeland Security’s “Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China”, also known as the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch.
Owner of WRO Entity
Key: owner_of_wro_entity
Level: high
Category: forced_labor
The entity possibly owns (minority, majority, or wholly) a Withhold Release Orders (WRO) entity up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch. Applicable to entities globally.
Possibly the Same (PSA) as Entity with Forced Labor Risk (Xinjiang Import Controls Designation)
Key: psa_forced_labor_xinjiang_uflpa
Level: critical
Category: forced_labor
The entity is Possibly the Same As (PSA) an entity listed in the USA Department of Homeland Security’s “Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China,” also known as the Uyghur Forced Labor Prevention Act (UFLPA) Entity List. The entities did not meet the threshold required to merge them into a single entity, but they are likely the same.
Possibly the Same As (PSA) Entity from Sheffield Hallam University Useful Resources
Key: psa_sheffield_hallam_university_useful_resources
Level: elevated
Category: forced_labor
This entity is possibly the same as an entity in the “Companies Operating in the Uyghur Region” dataset published by Sheffield Hallam University. The dataset was collected from a human resources website in December 2021. The entities did not meet the threshold required to merge them into a single entity, but they may be the same.
Possibly the Same As (PSA) Entity with Forced Labor Risk (Entity Located in Xinjiang)
Key: psa_forced_labor_xinjiang_geospatial
Level: high
Category: forced_labor
The entity is Possibly the Same As (PSA) an entity with geographic coordinates which indicate that the entity is based in Xinjiang, China, a region designated as high risk for forced labor practices. The entities did not meet the threshold required to merge them into a single entity, but they are likely the same.
Possibly the Same As (PSA) Entity with Forced Labor Risk (Entity Registered in Xinjiang)
Key: psa_forced_labor_xinjiang_registration
Level: high
Category: forced_labor
The entity is Possibly the Same As (PSA) an entity with a Uniform Social Credit Code (USCC) and/or registration number that indicates the entity is registered in Xinjiang, a region designated as high risk for forced labor practices. The entities did not meet the threshold required to merge them into a single entity, but they are likely the same.
Possibly the Same As (PSA) Entity with Forced Labor Risk (Xinjiang Keywords)
Key: psa_forced_labor_xinjiang_name
Level: high
Category: forced_labor
The entity is Possibly the Same As (PSA) an entity with an entity name and/or a source where the entity appears that suggests the entity may conduct business in Xinjiang, a region designated as high risk for forced labor practices. The entities did not meet the threshold required to merge them into a single entity, but they are likely the same.
Possibly the Same As (PSA) Intermediary Entity from Sheffield Hallam University Forced Labor Reports
Key: psa_sheffield_hallam_university_intermediary_entity
Level: high
Category: forced_labor
This entity is possibly the same as an entity named in Sheffield Hallam University Forced Labor Reports for having reasonable evidence of serving as an intermediary manufacturer and/or a downstream customer with trading relationships with one or more Chinese companies sourcing materials from the XUAR (Xinjiang Uygur Autonomous Region). The entities did not meet the threshold required to merge them into a single entity, but they may be the same.
Possibly the Same As (PSA) Sheffield Hallam University Forced Labor Reports Entity
Key: psa_sheffield_hallam_university_forced_labor_entity
Level: critical
Category: forced_labor
The entity is Possibly the Same As (PSA) an entity named in Sheffield Hallam University Forced Labor Reports for having reasonable evidence of the use of forced labor in the XUAR (Xinjiang Uygur Autonomous Region) through the manufacturing or production of goods. The entities did not meet the threshold required to merge them into a single entity, but they may be the same.
Possibly the Same As (PSA) a ASPI Forced Labor Report Entity
Key: psa_forced_labor_aspi_uyghur
Level: high
Category: forced_labor
The entity is Possibly the Same As (PSA) an entity named in the Australian Strategic Policy Institute’s report, “Uyghurs for sale: ‘Re-education’, forced labour and surveillance beyond Xinjiang.” The ASPI has identified entities that are using Uyghur labour transferred from Xinjiang since 2017.
Possibly the Same As (PSA) a WRO Entity
Key: psa_wro_entity
Level: critical
Category: forced_labor
The entity is Possibly the Same As (PSA) an entity subject to trade restrictions per the U.S. Customs and Border Protection (CBP) Withhold Release Orders and Findings List, a list of parties for which the United States Government has reasonable evidence of the use of forced labor in the manufacturing or production of a good or goods entering the U.S. supply chain.
Possibly the Same as Entity with Forced Labor Risk (Xinjiang Operations)
Key: psa_forced_labor_xinjiang_operations
Level: high
Category: forced_labor
The entity has authorization to conduct operations and/or is involved in contracting activities in Xinjiang, a region designated as high risk for forced labor practices. The entities did not meet the threshold required to merge them into a single entity, but they are likely the same.
Related to Entity from ASPI Forced Labor Report
Key: aspi_uyghur_forced_labor_report_entity_adjacent
Level: elevated
Category: forced_labor
The entity is 1 hop away from an entity named in the Australian Strategic Policy Institute’s report, “Uyghurs for sale: ‘Re-education’, forced labour and surveillance beyond Xinjiang.” Applies to all relationship types.
Related to Entity from Sheffield Hallam University Forced Labor Reports
Key: sheffield_hallam_university_forced_labor_reports_entity_adjacent
Level: elevated
Category: forced_labor
The entity is 1 hop away from an entity named in Sheffield Hallam University Forced Labor Reports. Applies to all relationship types.
Related to Forced Labor Risk Entity (Xinjiang Import Controls Designation)
Key: forced_labor_xinjiang_uflpa_adjacent
Level: elevated
Category: forced_labor
The entity is 1 hop away from an entity listed in the U.S. Department of Homeland Security’s “Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China,” also known as the Uyghur Forced Labor Prevention Act (UFLPA) Entity List. Applies to all relationship types that do not signify ownership.
Related to WRO Entity
Key: wro_entity_adjacent
Level: elevated
Category: forced_labor
The entity is 1 hop away from an entity subject to trade restrictions per the U.S. Customs and Border Protection (CBP) Withhold Release Orders (WRO) and Findings List. Applies to all relationship types.
WRO Entity
Key: wro_entity
Level: critical
Category: forced_labor
The entity is subject to trade restrictions per the U.S. Customs and Border Protection (CBP) Withhold Release Orders (WRO) and Findings List, a list of parties for which the United States government has reasonable evidence of the use of forced labor in the manufacturing or production of a good or goods entering the U.S. supply chain.
Political Exposure Risk Factors
Export to State-Owned Enterprise (SOE)
Key: export_to_soe
Level: high
Category: political_exposure
The entity exports to an entity that is a State-Owned Enterprise (SOE).
Former State-Owned Enterprise (SOE)
Key: former_soe
Level: elevated
Category: political_exposure
The entity was formerly a state-owned enterprise (SOE). According to the Organisation for Economic Co-operation and Development (OECD), a state-owned enterprise is defined as any corporate entity recognized by national law as an enterprise, and in which the state exercises ownership or control through full, majority, or significant minority ownership. Applicable to entities derived from risk intelligence data.
Owned by State-Owned Enterprise (SOE)
Key: owned_by_soe
Level: high
Category: political_exposure
The entity is possibly owned (minority, majority, or wholly) by a state-owned enterprise (SOE) up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch. Applicable to entities globally.
Owner of State-Owned Enterprise (SOE)
Key: owner_of_soe
Level: high
Category: political_exposure
The entity possibly owns (minority, majority, or wholly) a state-owned enterprise (SOE) up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch. Applicable to entities globally.
Politically Exposed Person (PEP)
Key: pep
Level: high
Category: political_exposure
According to the Financial Action Task Force (FATF), politically exposed persons (PEPs) are individuals who are or have been entrusted with prominent public functions. Examples include heads of state or of government, senior politicians, senior government officials, judicial or military officials, senior executives of state-owned corporations, and important political party officials. Applicable to entities derived from Acuris Risk Intelligence and PEP, politician, and public servant data.
Possibly the Same as (PSA) State-Owned Enterprise (SOE)
Key: psa_state_owned
Level: high
Category: political_exposure
The entity is Possibly the Same As (PSA) a state-owned enterprise (SOE). According to the Organization for Economic Cooperation and Development (OECD), a state-owned enterprise is defined as any corporate entity recognized by national law as an enterprise, and in which the state exercises ownership or control through full, majority, or significant minority ownership. The entities did not meet the threshold required to merge them into a single entity, but they are likely the same.
Possibly the Same as a Politically Exposed Person (PEP)
Key: psa_pep
Level: high
Category: political_exposure
The entity is Possibly the Same As (PSA) one or multiple other entities that are Politically Exposed Persons (PEPs). The entities did not meet the threshold required to merge them into a single entity, but they may be the same.
Related to Politically Exposed Person (PEP)
Key: pep_adjacent
Level: elevated
Category: political_exposure
The entity is 1 hop away from a politically exposed person (PEP). Applies to all relationship types.
Related to State-Owned Enterprise (SOE)
Key: soe_adjacent
Level: elevated
Category: political_exposure
The entity is 1 hop away from a state-owned enterprise (SOE). Applies to all relationship types.
State-Owned Enterprise (SOE)
Key: state_owned
Level: high
Category: political_exposure
According to the Organisation for Economic Co-operation and Development (OECD), a state-owned enterprise is defined as any corporate entity recognized by national law as an enterprise, and in which the state exercises ownership or control through full, majority, or significant minority ownership. Applicable to entities derived from Acuris Risk Intelligence.
Regulatory Action Risk Factors
Law Enforcement Action (from Adverse Media)
Key: law_enforcement_action
Level: elevated
Category: regulatory_action
The entity has been mentioned by official government websites or mass media outlets as wanted, charged, indicted, prosecuted, convicted, or sentenced in relation to a law enforcement action.
Owner of Entity Subject to Regulatory Action
Key: owner_of_regulatory_action_entity
Level: high
Category: regulatory_action
The entity possibly owns (minority, majority, or wholly) an entity that has been listed as subject to enforcement action by regulatory authorities, law enforcement/anti-corruption agencies, or other disciplinary bodies and is up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch. Applicable to entities globally.
Possibly the Same As (PSA) an Entity Subject to Regulatory Action
Key: psa_regulatory_action
Level: high
Category: regulatory_action
The entity is Possibly the Same As (PSA) one or multiple other entities that have been listed as subject to enforcement action by regulatory authorities, law enforcement/anti-corruption agencies, and other disciplinary bodies. The entities did not meet the threshold required to merge them into a single entity, but they are likely the same.
Regulatory Action
Key: regulatory_action
Level: high
Category: regulatory_action
The entity has been listed as subject to enforcement action by regulatory authorities, law enforcement/anti-corruption agencies, or other disciplinary bodies.
Relevant Risk Factors
Basel AML Index
Key: basel_aml
Level: relevant
Category: relevant
The Basel Anti-Money Laundering (AML) Index is an annual ranking that assesses the risk of money laundering and terrorist financing around the world and is maintained by the Basel Institute on Governance. The ranking displayed here ranks jurisdictions on a scale of 0 (lowest risk) to 10 (highest risk).
Corruption Perceptions Index
Key: cpi_score
Level: relevant
Category: relevant
The Corruption Perceptions Index (CPI) is published yearly by Transparency International and ranks 180 countries and territories around the world by their perceived levels of public sector corruption. The results are given on a scale of 0 (highly corrupt) to 100 (very clean). If the entity is referenced with multiple countries, the country with the highest score will be used.
EU High-Risk Third Countries
Key: eu_high_risk_third
Level: relevant
Category: relevant
This entity operates in a country identified by the European Commission as high risk due to strategic deficiencies in their regime related to anti-money laundering and countering the financing of terrorism.
Sanctions Risk Factors
EU Sanctioned Entity
Key: eu_sanctioned
Level: critical
Category: sanctions
Entities (persons, companies, or vessels) currently subject to trade, transport, immigration, or financial sanctions in the EU Financial Sanctions List and/or the EU Sanctions Map. The EU Financial Sanctions List and the EU Sanctions Map are published by the European Union (EU).
Entity in USA Treasury Non-SDN Chinese Military-Industrial Complex (CMIC) List
Key: cmic_entity
Level: high
Category: sanctions
The entity is listed in the USA Department of the Treasury Non-SDN Chinese Military-Industrial Complex Companies List.
Export to Sanctioned Entity
Key: export_to_sanctioned
Level: high
Category: sanctions
The entity exports to an entity that is currently subject to trade, transport, immigration, and/or financial sanctions in one or several international sanctions lists.
Former Sanctions
Key: formerly_sanctioned
Level: high
Category: sanctions
The entity was formerly subject to trade, transport, immigration, or financial sanctions in international sanctions lists.
Majority Owned by EU Sanctioned Entity
Key: eu_50_percent_rule
Level: high
Category: sanctions
The entity is possibly majority owned by one or more entities currently subject to trade, transport, immigration, or financial sanctions in the EU Financial Sanctions List and/or the EU Sanctions Map up to 4 hops away with an aggregate of more than 50% controlling interest (per EU’s 50% rule) via direct shareholding relationships. These relationships include shareholder or subsidiary. Applicable to entities globally.
Majority Owned by OFAC SDN
Key: ofac_50_percent_rule
Level: high
Category: sanctions
The entity is possibly majority owned by one or more entities currently subject to trade, transport, immigration, or financial sanctions in the USA OFAC SDN Sanctions List up to 4 hops away with an aggregate of 50% or more controlling interest (per OFAC’s 50% rule) via direct shareholding relationships. These relationships include shareholder or subsidiary. Applicable to entities globally.
OFAC SDN Entities
Key: ofac_sdn
Level: critical
Category: sanctions
Entities (persons, companies, aircraft, or vessels) currently subject to trade, transport, immigration, or financial sanctions in the USA OFAC SDN Sanctions List. The SDN, or Specially Designated Nationals and Blocked Persons, List is published by the U.S. Office of Foreign Assets Control (OFAC).
Owned by Entity in USA Treasury Non-SDN Chinese Military-Industrial Complex (CMIC) List
Key: owned_by_cmic_entity
Level: high
Category: sanctions
The entity is possibly owned (minority, majority, or wholly) by an entity listed in the USA Department of the Treasury Non-SDN Chinese Military-Industrial Complex Companies List up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch. Applicable to entities globally.
Owned by Sanctioned Entity
Key: owned_by_sanctioned_entity
Level: high
Category: sanctions
The entity is possibly owned (minority, majority, or wholly) by a sanctioned entity up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch. Applicable to entities globally.
Owner of Sanctioned Entity
Key: owner_of_sanctioned_entity
Level: high
Category: sanctions
The entity possibly owns (minority, majority, or wholly) a sanctioned entity up to 3 hops away via direct shareholding relationships with 10% or more controlling interest, including beneficial owner, owner, shareholder, partner, subsidiary, or branch. Applicable to entities globally.
Possibly the Same As (PSA) a Sanctioned Entity
Key: psa_sanctioned
Level: critical
Category: sanctions
The entity is Possibly the Same As (PSA) one or multiple other entities that are Sanctioned. The entities did not meet the threshold required to merge them into a single entity, but they may be the same.
Related to Sanctioned
Key: sanctioned_adjacent
Level: elevated
Category: sanctions
The entity is one hop away from a sanctioned entity. Applies to all relationship types.
Sanctioned
Key: sanctioned
Level: critical
Category: sanctions
Entities (persons, companies, aircraft, or vessels) currently subject to trade, transport, immigration, or financial sanctions in international sanctions lists.