Risk Details

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
Visibility: seed

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
Visibility: seed

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
Visibility: seed

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
Visibility: seed

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
Visibility: seed

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
Visibility: seed

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
Visibility: seed

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
Visibility: seed

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
Visibility: seed

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
Visibility: network

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
Visibility: seed

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
Visibility: seed

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
Visibility: seed

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
Visibility: seed

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
Visibility: network

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
Visibility: network

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.

Military-Civil Fusion (MCF) Entity

Key: military_civil_fusion
Level: high
Category: export_controls
Visibility: seed

The entity is a Chinese company possibly associated with China’s Military-Civil Fusion (MCF) program based on keywords found in the company’s name, address, or business purpose. MCF is the Chinese Communist Party (CCP) national strategy to develop the People’s Liberation Army (PLA) into a “world class military” by 2049 through the elimination of barriers between China’s civilian and defense sectors.

National Defense Authorization Act Section 889 Covered Entities

Key: ndaa_889_covered_entities
Level: high
Category: export_controls
Visibility: seed

The entity is subject to US public procurement restrictions per section 889 of the John S. McCain National Defense Authorization Act, which prohibits the government from obtaining certain telecommunications equipment produced by covered entities and from contracting with any entity that uses such equipment.

Owned by Entity in Export Controls List

Key: owned_by_entity_in_export_controls
Level: high
Category: export_controls
Visibility: network

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
Visibility: network

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
Visibility: network

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.

Owned by Listed on Non-SDN Chinese Military-Industrial Complex Companies (NS-CMIC) List

Key: owned_by_cmic_entity
Level: high
Category: export_controls
Visibility: network

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 Military-Civil Fusion (MCF) Entity

Key: owned_by_military_civil_fusion
Level: elevated
Category: export_controls
Visibility: network

The entity is possibly owned (minority, majority, or wholly) by a Chinese company possibly associated with China’s Military-Civil Fusion (MCF) program, based on keywords found in the company’s name, address, or business purpose, 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
Visibility: network

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
Visibility: psa

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
Visibility: psa

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.

Possibly the Same As (PSA) Military-Civil Fusion Entity

Key: psa_military_civil_fusion
Level: high
Category: export_controls
Visibility: psa

The entity is possibly the same as an entity that is a Chinese company possibly associated with China’s Military-Civil Fusion (MCF) program based on keywords found in the company’s name, address, or business purpose. 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) USA BIS Boycott Requester List Entity

Key: psa_bis_boycott_requester_list
Level: elevated
Category: export_controls
Visibility: psa

The entity is possibly the same as an entity listed on the USA BIS Boycott Requester List as having made a boycott-related request in connection with a transaction in the interstate or foreign commerce of the United States and has been reported to BIS as required by Section 760.5 of the EAR. The entities did not meet the threshold required to merge them into a single entity, but they may be the same.

Key: export_controls_adjacent
Level: elevated
Category: export_controls
Visibility: network

The entity is 1 hop away from an entity subject to export controls. Applies to all relationship types that do not signify ownership.

USA BIS Boycott Requester List Entity

Key: bis_boycott_requester_list
Level: elevated
Category: export_controls
Visibility: seed

The entity is listed on the USA BIS Boycott Requester List as having made a boycott-related request in connection with a transaction in the interstate or foreign commerce of the United States and has been reported to BIS as required by Section 760.5 of the EAR.

Forced Labor Risk Factors

Direct Trade History with ASPI Entity

Key: forced_labor_aspi_origin_direct
Level: elevated
Category: forced_labor
Visibility: network

Historical shipment records suggest that the entity possibly traded directly with an entity mentioned in the following forced labor report: “Uyghurs for sale: ‘Re-education’, forced labour and surveillance beyond Xinjiang” by Australian Strategic Policy Institute, that was identified in tier 1 of their supplier network using global import & export data.

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
Visibility: network

Historical shipment records suggest that the entity possibly traded directly with an entity mentioned in Sheffield Hallam University Forced Labor Reports that was identified in tier 1 of their supplier network using global import & export data.

Direct Trade History with UFLPA Entity

Key: forced_labor_uflpa_origin_direct
Level: high
Category: forced_labor
Visibility: network

Historical shipment records suggest that the entity possibly traded directly with an entity mentioned 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, that was identified in tier 1 of their supplier network using global import & export data.

Direct Trade History with WRO Entity

Key: forced_labor_wro_origin_direct
Level: high
Category: forced_labor
Visibility: network

Historical shipment records suggest that the entity possibly traded directly with an entity mentioned in the U.S. Customs and Border Protection (CBP) Withhold Release Orders (WRO) and Findings List that was identified in tier 1 of their supplier network using global import & export data.

Direct Trade History with Xinjiang-Based Entity

Key: forced_labor_xinjiang_origin_direct
Level: high
Category: forced_labor
Visibility: network

Historical shipment records suggest that the entity possibly traded directly with a Xinjiang-based entity that was identified in tier 1 of their supplier network using global import & export data. The Xinjiang-based entity was assessed with geospatial and/or keyword methodology as possibly located, registered, or conducting business in Xinjiang.

Entity from ASPI Forced Labor Report

Key: aspi_uyghur_forced_labor_report_entity
Level: elevated
Category: forced_labor
Visibility: seed

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
Visibility: seed

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 with Chinese Prison Labor Keyword

Key: forced_labor_china_keywords
Level: high
Category: forced_labor
Visibility: seed

The company name, address, or business purpose contains keywords that reference potential prison labor: “prison” or “laogai”. Applicable to China-based entities only.

Entity with Xinjiang Keyword

Key: forced_labor_xinjiang_name
Level: high
Category: forced_labor
Visibility: seed

The company 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.

Entity with Xinjiang Operations

Key: forced_labor_xinjiang_operations
Level: high
Category: forced_labor
Visibility: seed

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
Visibility: seed

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
Visibility: seed

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
Visibility: seed

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
Visibility: network

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
Visibility: network

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 UFLPA Entity

Key: owned_by_forced_labor_xinjiang_uflpa
Level: high
Category: forced_labor
Visibility: network

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
Visibility: network

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.

Owned by Xinjiang-Based Entity

Key: owned_by_xinjiang_entity
Level: high
Category: forced_labor
Visibility: network

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.

Owner of ASPI Forced Labor Report Entity

Key: owner_of_aspi_forced_labor_entity
Level: elevated
Category: forced_labor
Visibility: network

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
Visibility: network

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 UFLPA Entity

Key: owner_of_forced_labor_xinjiang_uflpa
Level: high
Category: forced_labor
Visibility: network

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
Visibility: network

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.

Owner of Xinjiang-Based Entity

Key: owner_of_forced_labor_xinjiang_entity
Level: high
Category: forced_labor
Visibility: network

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.

Possibly the Same As (PSA) ASPI Forced Labor Report Entity

Key: psa_forced_labor_aspi_uyghur
Level: elevated
Category: forced_labor
Visibility: psa

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) Entity with Xinjiang Keyword

Key: psa_forced_labor_xinjiang_name
Level: high
Category: forced_labor
Visibility: psa

The entity is Possibly the Same As (PSA) an entity with a company name 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 into a single entity, but they are likely the same.

Possibly the Same As (PSA) Entity with Xinjiang Operations

Key: psa_forced_labor_xinjiang_operations
Level: high
Category: forced_labor
Visibility: psa

The entity is Possibly the Same As (PSA) an entity that 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.

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
Visibility: psa

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
Visibility: psa

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) UFLPA Entity

Key: psa_forced_labor_xinjiang_uflpa
Level: critical
Category: forced_labor
Visibility: psa

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) WRO Entity

Key: psa_wro_entity
Level: critical
Category: forced_labor
Visibility: psa

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 (PSA) Xinjiang Cotton Industry Entity

Key: psa_forced_labor_xinjiang_cotton_entity
Level: elevated
Category: forced_labor
Visibility: psa

The entity is possibly the same as an entity identified in e-commerce listings to be involved in the manufacture, trade, or storage of Xinjiang-produced cotton, a high priority sector for enforcement under the Strategy to Prevent Importation of Goods Mined, Produced or Manufactured with Forced Labor in the People’s Republic of China. 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) Xinjiang-Geolocated Entity

Key: psa_forced_labor_xinjiang_geospatial
Level: high
Category: forced_labor
Visibility: psa

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) Xinjiang-Registered Entity

Key: psa_forced_labor_xinjiang_registration
Level: high
Category: forced_labor
Visibility: psa

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.

Key: aspi_uyghur_forced_labor_report_entity_adjacent
Level: elevated
Category: forced_labor
Visibility: network

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.

Key: sheffield_hallam_university_forced_labor_reports_entity_adjacent
Level: elevated
Category: forced_labor
Visibility: network

The entity is 1 hop away from an entity named in Sheffield Hallam University Forced Labor Reports. Applies to all relationship types.

Key: forced_labor_xinjiang_uflpa_adjacent
Level: elevated
Category: forced_labor
Visibility: network

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.

Key: wro_entity_adjacent
Level: elevated
Category: forced_labor
Visibility: network

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.

Supplier Network with ASPI Entity

Key: forced_labor_aspi_origin_subtier
Level: elevated
Category: forced_labor
Visibility: network

Historical shipment records suggest that the entity has a third-party entity mentioned in the following forced labor report: “Uyghurs for Sale: ‘Re-education’, Forced Labor, and Surveillance beyond Xinjiang” by Australian Strategic Policy Institute, that was identified in tier 2 or 3 of their supplier network using global import & export data.

Supplier Network with Entity from Sheffield Hallam University Forced Labor Reports

Key: forced_labor_sheffield_hallam_university_reports_origin_subtier
Level: elevated
Category: forced_labor
Visibility: network

Historical shipment records suggest that the entity has a third-party entity mentioned in Sheffield Hallam University Forced Labor Reports that was identified in tier 2 or 3 of their supplier network using global import & export data.

Supplier Network with UFLPA Entity

Key: forced_labor_uflpa_origin_subtier
Level: elevated
Category: forced_labor
Visibility: network

Historical shipment records suggest that the entity has a third-party entity mentioned 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, that was identified in tier 2 or 3 of their supplier network using global import & export data.

Supplier Network with WRO Entity

Key: forced_labor_wro_origin_subtier
Level: elevated
Category: forced_labor
Visibility: network

Historical shipment records suggest that the entity has a third-party entity actively subject to trade restrictions per the U.S. Customs and Border Protection (CBP) Withhold Release Orders (WRO) and Findings List that was identified in tier 2 or 3 of their supplier network using global import & export data.

Supplier Network with Xinjiang-Based Entity

Key: forced_labor_xinjiang_origin_subtier
Level: elevated
Category: forced_labor
Visibility: network

Historical shipment records suggest that the entity has a third-party Xinjiang-based entity that was identified in tier 2 or 3 of their supplier network using global import & export data. The Xinjiang-based entity was assessed with geospatial and/or keyword methodology as possibly located, registered, or conducting business in Xinjiang.

UFLPA Entity

Key: forced_labor_xinjiang_uflpa
Level: critical
Category: forced_labor
Visibility: seed

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.

WRO Entity

Key: wro_entity
Level: critical
Category: forced_labor
Visibility: seed

The entity is actively 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.

Xinjiang Cotton Industry Entity

Key: forced_labor_xinjiang_cotton_entity
Level: elevated
Category: forced_labor
Visibility: seed

E-commerce listings indicate that the entity is involved in the manufacture, trade, or storage of Xinjiang-produced cotton, a high priority sector for enforcement under the Strategy to Prevent Importation of Goods Mined, Produced or Manufactured with Forced Labor in the People’s Republic of China.

Xinjiang Production and Construction Corps (XPCC) Contractor

Key: forced_labor_xinjiang_contractors
Level: high
Category: forced_labor
Visibility: seed

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.

Xinjiang-Geolocated Entity

Key: forced_labor_xinjiang_geospatial
Level: high
Category: forced_labor
Visibility: seed

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.

Xinjiang-Registered Entity

Key: forced_labor_xinjiang_registration
Level: high
Category: forced_labor
Visibility: seed

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.

Political Exposure Risk Factors

Export to State-Owned Enterprise (SOE)

Key: export_to_soe
Level: high
Category: political_exposure
Visibility: network

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
Visibility: seed

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
Visibility: network

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
Visibility: network

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
Visibility: seed

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
Visibility: psa

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
Visibility: psa

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.

Key: pep_adjacent
Level: elevated
Category: political_exposure
Visibility: network

The entity is 1 hop away from a politically exposed person (PEP). Applies to all relationship types.

Key: soe_adjacent
Level: elevated
Category: political_exposure
Visibility: network

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
Visibility: seed

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
Visibility: seed

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
Visibility: network

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
Visibility: psa

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
Visibility: seed

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
Visibility: seed

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
Visibility: seed

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
Visibility: seed

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

Export to Sanctioned Entity

Key: export_to_sanctioned
Level: high
Category: sanctions
Visibility: network

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
Visibility: seed

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
Visibility: network

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 50% or more 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
Visibility: network

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.

Majority Owned by UK Sanctioned Entity

Key: uk_50_percent_rule
Level: high
Category: sanctions
Visibility: network

The entity is possibly majority owned by one or more entities currently subject to sanctions in the UK Sanctions List up to 4 hops away with an aggregate of more than 50% controlling interest via direct shareholding relationships. These relationships include shareholder or subsidiary. Applicable to entities globally.

Owned by Sanctioned Entity

Key: owned_by_sanctioned_entity
Level: high
Category: sanctions
Visibility: network

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
Visibility: network

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
Visibility: psa

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.

Key: sanctioned_adjacent
Level: elevated
Category: sanctions
Visibility: network

The entity is 1 hop away from an entity subject to trade, transport, immigration and/or financial sanctions in one or several international sanctions lists. Applies to all relationship types.

Sanctioned

Key: sanctioned
Level: critical
Category: sanctions
Visibility: seed

Entities (persons, companies, aircraft, or vessels) currently subject to trade, transport, immigration, or financial sanctions in international sanctions lists.