Sayari Graph is a powerful investigative tool that can be leveraged to investigate prospective customers or distributors and comply with export control and Military End Use (MEU) regulations. Follow along with this tutorial in Sayari Graph for a real world example of how to use Sayari Graph for export control investigations. We’ll be using this case as an example, but the same data and methodologies will apply across geographies and industries.
Let’s say China Opto-Electro Industries Co., Ltd. has requested to buy equipment - and you’ve been tasked with conducting additional due diligence on the company to assess potential risk and determine whether the potential sale would be permissible and/or require an export license.
Entity profiles in Sayari Graph are constructed from all the attributes and relationships that Sayari has extracted from individual records related to an entity. Sayari also proactively identifies overt (e.g. an entity on the OFAC SDN list) and hidden risk (e.g. a company which has exported to a sanctioned entity) including over 20 risk factors specific to export controls and military end use.
The entity profile provides an abridged overview of key attributes as well as the sources that underpin the profile. Data extracted from records are reflected in the original language - often one that users don’t speak or read - so we have a Google Translate API built in which can be toggled on/off in the upper right corner. Translated text will be highlighted yellow.
Hover over the triangle icons next to the company’s name to preview the Risk Factors associated with the company - at a glance, we can see that China Opto-Electro’s government contracts and ownership present possible risk for us to assess further.
Scrolling down will provide abridged highlights from the other information tabs, which can be accessed in their entirety via the navigation bar on the left side of the screen. The Attributes tab can help confirm that this is the correct entity profile by matching identifiers, addresses, or other details to other documentation we might have. And the business purpose(s) provide visibility into the company’s activities - in this case a broad range including optoelectronics products, manufacturing, higher education, and the sale of a long list of products.
Direct relationships can be accessed via the Relationships tab which, like the Attributes tab, can be viewed en masse or filtered down to a specific subset. Click the down arrow to expand options for Relationships and click “Has Shareholder” to view China Opto-Electro’s direct owner(s).
Note that Sayari reflects relationships as they are presented in the original source - ownership can also be represented via “Subsidiary of” or “Has Beneficial Owner” relationship types, for example, if that is how a particular source describes those relationships.
From here, we can see that the ownership risks present on China Opto-Electro Industries are also present on its direct owner which doesn’t appear to be the entity on the NS-CMIC list, for example, and generating the ownership-based risk. We could click through to this company’s profile and view its shareholder(s) and continue up the chain manually, but instead let’s navigate to the Explore tab and the Beneficial Ownership subtab.
This tab allows us to investigate networks multiple degrees at a time - and some of the common workflows have presets available as subtabs (e.g. Beneficial Ownership and Downstream Holdings). In this case, we can now see the full ownership chain and better understand where the risks associated with China Opto-Electro Industries are coming from - China North Industries Group, also known as Norinco, is on the 1260H list as well as the NS-CMIC list and an indirect owner of China Opto-Electro Industries. And Norinco itself is owned by the State Owned Assets Supervision and Administration Commission (SASAC) of the State Council.
In this case, the ownership chain was fairly straightforward - but in cases where a company has multiple shareholders and where each of those entities also has multiple shareholders, accessing the full upstream ownership chain in one place can significantly improve efficiency.