United States · Uyghur Forced Labor Prevention Act
UFLPA screening, checked against the live Entity List
Under the UFLPA, goods with a link to Xinjiang or to a listed entity are presumed to be made with forced labour and barred from US import. Libera screens your supplier names against the DHS UFLPA Entity List and OFAC sanctions at the time of the check, and records what it found alongside the risk score.
The rebuttable presumption
The Uyghur Forced Labor Prevention Act creates a rebuttable presumption that goods mined, produced or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region, or by entities on the UFLPA Entity List, are made with forced labour and therefore barred from entry into the United States. The burden sits with the importer to rebut it.
- Applies to inputs and components, not only finished goods
- Entity List additions can affect suppliers you already buy from
- Detentions are operational events: goods held, orders missed, customers affected
- Tracing obligations reach upstream, beyond the direct supplier
Live Entity List screening in Libera
Libera fetches the DHS UFLPA Entity List and the OFAC sanctions list at the moment a supplier is screened, rather than relying on a copy bundled months earlier. Names are normalised and compared, and a likely match raises the supplier's score with a named reason attached to the result.
- OFAC consolidated sanctions data fetched at check time
- DHS UFLPA Entity List parsed and cached briefly to stay current
- Name similarity is a signal to verify, never a determination
- A failed live check never silently blocks or alters a saved screening
A name match is a starting point
Company names transliterate inconsistently, subsidiaries trade under different names, and two unrelated businesses can share one. Libera treats every match as an indicator that a human must verify against the official list and your own supplier records before any commercial decision is taken.
Tracing below tier one
UFLPA exposure often sits in inputs — yarn, polysilicon, components — rather than in the supplier on your invoice. Libera models suppliers, sites and labour providers as separate nodes across tiers, so an upstream node with exposure is visible in your portfolio rather than hidden behind a compliant tier-one vendor.
Worker signals alongside list screening
List screening finds named entities. It does not find a recruitment agency charging fees, wages withheld at a site, or documents retained from migrant workers. Libera pairs list screening with a confidential worker reporting channel so both kinds of evidence land in the same risk picture.
What this is not
Libera is not a customs broker, does not prepare or file submissions, and takes no position on whether any specific shipment is admissible. It is a screening and documentation layer that helps your team see exposure earlier.
How Libera maps to the workflow
From a screening score to a documented human decision.
01
Screen suppliers
Every supplier, site and labour provider is scored on country prevalence, government response, sector intensity, workforce size and use of recruitment intermediaries, then checked against official sanctions and import-ban lists at the time of the check.
02
Open and verify worker access
A QR poster at agreed access points opens a confidential reporting page in the worker's own language. Access can be verified through announced or unannounced checks by the buyer or an independent auditor, and the result is recorded per site.
03
Receive confidential signals
Workers report without a name, phone number, account or precise location. Management never reads an individual account; only aggregate indicator counts reach the console.
04
Detect patterns
Signals are clustered by site, supplier and ILO indicator, so a repeated pattern becomes visible even when each report on its own looks minor.
05
Human review
When signals accumulate, the supplier's risk status is raised and flagged for human review. Libera never concludes that forced labour occurred — a person decides what happens next.
06
Case and remediation
A case file records the investigation timeline, evidence register, remediation actions with owners and due dates, and the documented outcome.
07
Monitor and document
Re-screening, access re-verification and an immutable activity log produce an exportable record of what was found, what was decided and what was done.
What this page is not
A name similarity match is an indicator for human verification, not a finding that a supplier is listed or that goods are inadmissible. Official lists and their scope change; always verify against the published source before acting. Libera does not provide customs, trade or legal advice.
Libera produces risk indicators for review. It does not determine that any company or person has committed an offence, does not guarantee compliance with any law, and is not legal advice. Every escalation requires human review.
Primary sources
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See the risk before it becomes the story.
Screen suppliers, open a confidential worker channel, verify access, investigate patterns and document remediation in one workflow.