What Risk Factors are Covered in High-Risk Ownership?

Basel AML

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).

CMIC Entity

The entity listed in the USA Department of the Treasury Non-SDN Chinese Military-Industrial Complex Companies (NS-CMIC). 

CPI Score

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

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.

Export Control: Export Controls Adjacent

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

Export Control: Exports BIS High Priority Items

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.

Export Control: Listed

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.

Export Control: MEU List Contractors

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.

Export Control: Owned by BIS MEU Entity

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.

Export Control: Owned by CMIC Entity

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.

Export Control: Owned by Export Controlled Entity

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.

Export Control: Owned by Section 1260H Entity

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.

Export Control: Owner of Export Controlled Entity

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.

Export Control: Possibly Same as Export Controlled Entity

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.

Export to State Owned Entity

The entity exports to an entity that is a State-Owned Enterprise (SOE).

Forced Labor: China

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: Owned by Sheffield Hallam University

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.

Forced Labor: Owned by WRO Entity

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.

Forced Labor: Owner of Sheffield Hallam University

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.

Forced Labor: Owner of WRO Entity

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.

Forced Labor: Owner of Xinjiang Entity

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: Owner of Xinjiang UFLPA

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.

Forced Labor: PSA Sheffield Hallam University

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.

Forced Labor: PSA WRO Entity

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.

Forced Labor: PSA Xinjiang Geospatial

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.

Forced Labor: PSA Xinjiang Name

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.

Forced Labor: PSA Xinjiang Registration

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.

Forced Labor: PSA Xinjiang UFLPA

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.

Forced Labor: Sheffield Hallam University

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.

Forced Labor: Sheffield Hallam University adjacent

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

Forced Labor: Sheffield Hallam University Origin

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.

Forced Labor: Sheffield Hallam University Origin Subtier

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.

Forced Labor: UFLPA Origin

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.

Forced Labor: UFLPA Origin Subtier

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.

Forced Labor: WRO Adjacent

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.

Forced Labor: WRO Entity

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.

Forced Labor: WRO Origin

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.

Forced Labor: WRO Origin Subtier

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.

Forced Labor: Xinjiang Contractors

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: Xinjiang Entity

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: Xinjiang Geospatial

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: Xinjiang Name

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.

Forced Labor: Xinjiang Origin

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.

Forced Labor: Xinjiang Origin Subtier

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.

Forced Labor: Xinjiang Registration

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: Xinjiang UFLPA

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: Xinjiang UFLPA Adjacent

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.

Former State Owned Entity

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.

Imports BIS High Priority Items

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.

Law Enforcement 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.

Owned by State Owned Entity

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 Entity That is Target of 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.

Owner of State Owned Entity

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)

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. 

PEP Adjacent

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

PSA PEP

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.

PSA Regulatory Action Target

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.

PSA State Owned

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.

Regulatory Action

The entity has been listed as subject to enforcement action by regulatory authorities, law enforcement/anti-corruption agencies, or other disciplinary bodies.

Reputational Risk: Bribery and Corruption

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.

Reputational Risk: Cybercrime

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.

Reputational Risk: Financial Crime

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.

Reputational Risk: 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.

Reputational Risk: Organized Crime

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.

Reputational Risk: Other

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.

Reputational Risk: Related Party

The entity is related to other parties flagged for existing risk factors.

Reputational Risk: Terrorism

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.

Sanctions: Export to Sanctioned

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.

Sanctions: Formerly Sanctioned

The entity was formerly subject to trade, transport, immigration, or financial sanctions in international sanctions lists.

Sanctions: Listed

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

Sanctions: Owned by Sanctioned Entity

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.

Sanctions: Owner of Sanctioned Entity

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.

Sanctions: Possibly Same as Sanctioned

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.

Sanctions: Sanctioned Adjacent

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.

State Owned

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.

State Owned Enterprise Adjacent

The entity is 1 hop away from a state-owned enterprise (SOE). Applies to all relationship types.