Article - July 23, 2025

The Exiger Enhanced UFLPA Solution

Executive Summary

Three years since the implementation of the Uyghur Forced Labor Prevention Act (UFLPA), U.S. importers face increased pressure to prove that their supply chains aren’t tainted with forced labor. Compliance with the UFLPA presents significant challenges, including navigating opaque supplier relationships within China, gaps in available data on Chinese entities, and limited real-time detection of UFLPA risks. The Exiger enhanced UFLPA solution combines AI-powered technology with human subject matter expertise to solve these challenges and uncover forced labor risks across all tiers of the supply chain—enabling organizations to proactively detect, assess, and mitigate UFLPA risk at scale.

Overview

Effective June 21, 2022, the UFLPA establishes a rebuttable presumption that requires importers to present clear and convincing evidence to U.S. Customs and Border Protection (CBP) that their products are not manufactured, wholly or in part, using forced labor from the Xinjiang Uyghur Autonomous Region of China (Xinjiang).

The U.S. government continues to prioritize enforcement of the UFLPA, allocating millions of dollars to CBP to support UFLPA-related requirements. Since 2022, the UFLPA Entity List—which bans the import of goods from listed entities—has expanded to include 144 entities in China. However, compliance requirements for importers go well beyond simply screening their supply chains against this list. Importers must leverage advanced supply chain mapping technologies to effectively identify potential sources of UFLPA risk across all tiers of suppliers and their broader networks.

Challenges

Ensuring compliance with the UFLPA requires a nuanced understanding of complex and opaque supply chains linked to China. Key challenges include:

Intentional obfuscation of the use of forced labor by entities in China.
Data gaps that fail to accurately identify the sources of risk for forced labor outlined in the UFLPA.
Technology that cannot detect product-level risks connected to Xinjiang.
A lack of capabilities that can track changes to entities in real-time.
Transliteration errors pose challenges to the accurate identification of Chinese-language names.

How Exiger Helps

Exiger’s enhanced UFLPA solution combines AI-powered technology with human subject matter expertise to detect potential UFLPA violations at scale. Built alongside government experts and validated by leading non-profits, Exiger’s solution was created using the expertise of Dr. Laura Murphy, widely recognized as one of the world’s foremost scholars on the UFLPA.

Exiger’s methodology includes:

Identifying sources of risk as outlined in the UFLPA (e.g., the involuntary transfer of Xinjiang laborers to Chinese factories and facilities, companies co-located with prisons) using Chinese government data, geospatial information, Chinese and international trade records, and other data sources key to identifying product-level risks connected to Xinjiang.

Mapping out the broader corporate and commercial networks connected to those sources of risk.

Assigning a risk score and risk tag to accurately identify an entity’s level of complicity with forced labor schemes.

Continuous monitoring to identify changes to entities and networks in real-time.

Exiger’s methodology delivers multi-tier supply chain visibility, enabling accurate identification of UFLPA-related risks while reducing “noise.” This approach ensures our clients have clear, actionable insights to maintain compliance with the UFLPA. Request a demo to understand how the Exiger enhanced UFLPA solution can help your enterprise identify potential forced labor risks across the supply chain.