UFLPA Clear & Convincing Evidence Standard for SMBs | Compass

UFLPA Compliance: Beyond the Entity List for SMBs

As we navigate mid-2025, the Uyghur Forced Labor Prevention Act (UFLPA) challenges US importers, especially SMBs. While the UFLPA Entity List is known, the real hurdle is providing CBP with "clear and convincing evidence" to rebut the presumption of forced labor for detained shipments. This requires more than basic watchlist screening.

Deconstructing "Clear and Convincing Evidence" for SMB Import Compliance

CBP guidance demands robust due diligence, supply chain tracing, and supplier management – challenging for lean e-commerce compliance teams. Key issues for SMBs:

1. Integrating Disparate Data: Manually correlating supplier info, UFLPA Entity List status (which changes!), XUAR screening (Xinjiang geographical checks), and other red flags is error-prone.
2. Demonstrating a Systematic Process: Ad-hoc checks lack rigor. A repeatable, verifiable process for screening suppliers against lists and geographic constraints is needed, integrating OFAC and BIS screening.
3. Resource Constraints: SMBs need pragmatic, cost-effective solutions for foundational UFLPA screening and diligence.

The Compliance Gap: Fragmented Screening

Checking the UFLPA Entity List is vital but insufficient. Verifying supplier locations against the XUAR boundary is also essential. Fragmented checks (manual methods, separate tools for OFAC/BIS/UFLPA) create gaps and weaken the evidence trail for SMB import compliance.

Technology Enabler: Integrated UFLPA & Watchlist Screening

Tools that integrate these foundational checks are critical for SMBs to manage UFLPA risk effectively.

Compass Trade Systems provides focused, accessible trade compliance software:

• Simultaneous Checks: Screens suppliers against UFLPA, OFAC SDN, and BIS Entity Lists together.
• Built-in XUAR Screening: Automatically checks supplier addresses against the Xinjiang region boundary.
• Efficiency & Consistency: Replaces manual checks with rapid, automated trade screening.
• Foundational Evidence: Creates a centralized record vital for the due diligence package.

While not a complete UFLPA solution, automating these critical initial screening steps provides a crucial foundation, freeing SMB teams for deeper risk assessment.

Building Resilient Supply Chain Compliance

Meeting UFLPA demands requires moving beyond manual methods. Integrated, automated screening is becoming essential for credible due diligence.

Compass Trade Systems empowers SMB importers to navigate this complexity. We're launching soon – request early access!