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LABOR DEPARTMENT HUNTING FORCED-LABOR RISKS WITH SAYARI

By Kate Nishimura

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KATE NISHIMURA

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The U.S. Department of Labor (DOL) Bureau of International Labor Affairs (ILAB)
tapped a supply chain intelligence platform to find forced labor risks in supply
chains.

Washington, D.C.’s Sayari is now providing commercial risk intelligence and
enhancing the agency’s import regulation work. The software provider’s signature
product, Sayari Graph, maps global supply chains and screens suppliers in real
time using global trade and corporate data. The labor affairs bureau will use
the platform to help enforce the Uyghur Forced Labor Prevention Act (UFLPA) and
monitor candidates for the growing blacklist of risky companies.

Already in use by U.S. Customs and Border Protection (CBP), ILAB is the second
agency of the U.S. Department of Labor’s Forced Labor Enforcement Task Force
(FLETF) to adopt the analytics platform. The seven-agency FLETF is tasked with
keeping forced-labor goods out of the U.S.

“We are proud to partner with DOL to investigate suspected ties to forced
labor,” Sayari CEO and co-founder Farley Mesko said in a statement. “The level
of visibility Sayari enables into complex supply chains at a time of increasing
regulatory concern is unparalleled and will empower DOL to deny entities that
engage in forced labor access to the U.S. economy.”




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Sayari, one of Inc.’s 5,000 fastest-growing private U.S. companies, was awarded
CBP’s $7.8 million enterprise contract in September 2022, giving trade
enforcement and investigation teams access to commercial and risk data,
including trade metrics from over 65 reporting countries. This helps
investigators to better identify “deep sub-tier counterparty risk” and compel
companies to comply with import regulations like the UFLPA. According to Sayari,
investigators using the analytics platform discover an average of 544 percent
net new entities. The data-rich platform surfaces results on 90 percent of the
subjects searched.

A Sayari executive explained how the system supports the bureau work.

The DOL division is using the company’s analytics platform to understand
ownership structures and look at actual trade flows, Sayari global head of
analytical solutions Dave Lynch told Sourcing Journal. Sayari pulls data from
corporations and their owners, as well as bill of lading (BoL) documents on the
goods being transported. “We’re identifying actual shipment contents, along with
the consignor and consignee,” Lynch said.

“ILAB is first using our ownership data to better understand parent company and
subsidiary relationships in China,” he said. This is essential because there’s
no public information on trade in China. “If you’ve got a company in Xinjiang
and a company in Shanghai, there unfortunately is no public trade data that
would tell you that there’s a shipment going between those two companies,” Lynch
added.

Ownership data offers “a proxy measure of trade” happening in China, however.
Data in Sayari Graph, when paired with available international trade data, “is
helping to figure out if there are any Xinjiang or Xinjiang-linked companies
that are shipping products internationally that might find their way into U.S.
markets, either directly or through commingled shipments,” Lynch said.

Today, Sayari’s clients are split 50-50 between companies tracing their supply
chains and mitigating risk and government agencies tasked with combatting forced
labor. Lynch said UFLPA has forced companies to look “beyond their immediate
suppliers to proactively screen risk.” And as agencies like DOL and CBP amass
supplier insights using the Sayari platform, they’ll get better at identifying
risks and producing audits that could help companies understand where things
went wrong if their shipment gets detained or they’re issued a Withhold Release
Order (WRO).





Understanding China’s supply chains is also a matter of national security,
according to Sayari.

“To successfully implement de-risking strategies and, and ultimately execute the
National Security Strategy, it is imperative for government officials and
departments to better understand complicated business ownership in order to
avoid inadvertently reinvesting in businesses ultimately controlled by Beijing,”
Sayari director of defense and intelligence James Dempsey said in a statement
last fall. Sayari contributed to the Atlantic Council’s research into
China-based companies and their role in supporting the Chinese government’s
coercive regime. Dempsey said the Chinese Communist Party, or CCP, “uses all
levers of national power to achieve foreign policy objectives.”

In a statement, Dr. William Piekos, nonresident fellow with the Atlantic
Council’s Global China Hub, said global public data is “critical” to
investigations into China’s influence, “allowing insight into direct ownership
links between entities, and when deployed alongside trade, shipping, and
geospatial data, offering further insight into connections between and across
jurisdictions.”

In September, Sayari appointed Kevin Higgins, senior executive of the Central
Intelligence Agency’s Directorate of Operations, to its board. “His specialized
knowledge will inform innovative tactics for Sayari’s government customers
working to keep essential technologies away from illicit actors and corporate
customers grappling with the influx of regulations resulting from today’s
complex geopolitical landscape,” the company said.

The U.S. Department of Labor (DOL) Bureau of International Labor Affairs (ILAB)
tapped a supply chain intelligence platform to find forced labor risks in supply
chains. Washington, D.C.’s Sayari is no



READ MORE ABOUT

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 * U.S. Department of Labor
 * UFLPA


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   Information about your activity on this service, such as your interaction
   with ads or content, can be very helpful to improve products and services and
   to build new products and services based on user interactions, the type of
   audience, etc. This specific purpose does not include the development or
   improvement of user profiles and identifiers.
   
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FUNCTIONAL COOKIES

Functional Cookies

These cookies enable the website to provide enhanced functionality and
personalisation. They may be set by us or by third party providers whose
services we have added to our pages. If you do not allow these cookies then some
or all of these services may not function properly.

 * UNDERSTAND AUDIENCES THROUGH STATISTICS OR COMBINATIONS OF DATA FROM
   DIFFERENT SOURCES 424 PARTNERS CAN USE THIS PURPOSE
   
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   Reports can be generated based on the combination of data sets (like user
   profiles, statistics, market research, analytics data) regarding your
   interactions and those of other users with advertising or (non-advertising)
   content to identify common characteristics (for instance, to determine which
   target audiences are more receptive to an ad campaign or to certain
   contents).
   
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 * CREATE PROFILES TO PERSONALISE CONTENT 215 PARTNERS CAN USE THIS PURPOSE
   
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   Information about your activity on this service (for instance, forms you
   submit, non-advertising content you look at) can be stored and combined with
   other information about you (such as your previous activity on this service
   or other websites or apps) or similar users. This is then used to build or
   improve a profile about you (which might for example include possible
   interests and personal aspects). Your profile can be used (also later) to
   present content that appears more relevant based on your possible interests,
   such as by adapting the order in which content is shown to you, so that it is
   even easier for you to find content that matches your interests.
   
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TARGETING COOKIES

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may
be used by those companies to build a profile of your interests and show you
relevant adverts on other sites. They do not store directly personal
information, but are based on uniquely identifying your browser and internet
device. If you do not allow these cookies, you will experience less targeted
advertising.

 * ACTIVELY SCAN DEVICE CHARACTERISTICS FOR IDENTIFICATION 119 PARTNERS CAN USE
   THIS PURPOSE
   
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   With your acceptance, certain characteristics specific to your device might
   be requested and used to distinguish it from other devices (such as the
   installed fonts or plugins, the resolution of your screen) in support of the
   purposes explained in this notice.

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PERSONALISED ADVERTISING AND CONTENT, ADVERTISING AND CONTENT MEASUREMENT,
AUDIENCE RESEARCH AND SERVICES DEVELOPMENT 738 PARTNERS CAN USE THIS PURPOSE

Personalised advertising and content, advertising and content measurement,
audience research and services development

 * USE LIMITED DATA TO SELECT ADVERTISING 584 PARTNERS CAN USE THIS PURPOSE
   
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   Advertising presented to you on this service can be based on limited data,
   such as the website or app you are using, your non-precise location, your
   device type or which content you are (or have been) interacting with (for
   example, to limit the number of times an ad is presented to you).
   
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 * CREATE PROFILES FOR PERSONALISED ADVERTISING 482 PARTNERS CAN USE THIS
   PURPOSE
   
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   Information about your activity on this service (such as forms you submit,
   content you look at) can be stored and combined with other information about
   you (for example, information from your previous activity on this service and
   other websites or apps) or similar users. This is then used to build or
   improve a profile about you (that might include possible interests and
   personal aspects). Your profile can be used (also later) to present
   advertising that appears more relevant based on your possible interests by
   this and other entities.
   
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 * USE PROFILES TO SELECT PERSONALISED ADVERTISING 476 PARTNERS CAN USE THIS
   PURPOSE
   
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   Advertising presented to you on this service can be based on your advertising
   profiles, which can reflect your activity on this service or other websites
   or apps (like the forms you submit, content you look at), possible interests
   and personal aspects.
   
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 * USE PROFILES TO SELECT PERSONALISED CONTENT 190 PARTNERS CAN USE THIS PURPOSE
   
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   Content presented to you on this service can be based on your content
   personalisation profiles, which can reflect your activity on this or other
   services (for instance, the forms you submit, content you look at), possible
   interests and personal aspects, such as by adapting the order in which
   content is shown to you, so that it is even easier for you to find
   (non-advertising) content that matches your interests.
   
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 * MEASURE ADVERTISING PERFORMANCE 680 PARTNERS CAN USE THIS PURPOSE
   
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   Information regarding which advertising is presented to you and how you
   interact with it can be used to determine how well an advert has worked for
   you or other users and whether the goals of the advertising were reached. For
   instance, whether you saw an ad, whether you clicked on it, whether it led
   you to buy a product or visit a website, etc. This is very helpful to
   understand the relevance of advertising campaigns.
   
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 * USE LIMITED DATA TO SELECT CONTENT 110 PARTNERS CAN USE THIS PURPOSE
   
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   Content presented to you on this service can be based on limited data, such
   as the website or app you are using, your non-precise location, your device
   type, or which content you are (or have been) interacting with (for example,
   to limit the number of times a video or an article is presented to you).
   
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