The records are spread across too many places
Supplier documents, purchase records, transportation records, audits, screening results, and legal requests may sit in different systems, inboxes, portals, and folders.
For trade compliance teams at high-risk U.S. importers
When a UFLPA issue appears, the records needed to respond are often scattered across suppliers, systems, inboxes, brokers, and counsel.
Nomira is building a shared operating workflow that helps trade compliance teams see what information has been collected, what is still missing, who owns the next action, and what is ready for legal or outside-counsel review.
Designed to work alongside your current systems, customs broker, legal team, and outside counsel.
Nomira is currently working with selected U.S. importers to refine the initial workflow. Product access is not yet generally available.
The current process
How the current process breaks down
- 01
A UFLPA concern appears
A shipment is detained, a supplier is flagged, a customer asks for proof, or legal identifies possible exposure.
- 02
Trade compliance starts gathering information
The team requests supplier records, purchase documents, transportation records, audits, screening results, and other supporting information.
- 03
The information arrives from different places
Documents come from suppliers, internal systems, brokers, business teams, shared drives, and outside advisors.
- 04
The team discovers what is missing
Some records are incomplete, outdated, inconsistent, difficult to verify, or have no clear owner.
- 05
Trade compliance coordinates review and follow-up
The team assigns missing work, tracks open questions, and prepares the information for legal, broker, or outside-counsel review.
Today, much of this coordination happens through spreadsheets, email, meetings, and manual document folders.
Trade compliance owns the response, but the information needed to respond is controlled by many different people and systems.
A UFLPA concern can begin with a detained shipment, a supplier relationship, an entity-list match, a customer request, or a legal inquiry. The response then depends on information held across the company and outside it.
No one can quickly see what is missing
Teams may know that documents have been requested without knowing whether they are complete, current, consistent, or ready for review.
Responsibility is divided across teams
Trade compliance may coordinate the work, but supply chain, sourcing, legal, brokers, suppliers, and outside counsel each control part of the answer.
The process becomes an emergency under deadline
Missing records are often discovered only after a shipment, customer, broker, lawyer, or internal review has already created urgency.
Existing tools usually solve one part of the problem. The work between them is still manual.
Screening tools can flag risk. Supplier systems can store documents. Brokers can manage entry information. Legal teams and outside counsel can interpret the facts. But trade compliance teams may still have to connect those pieces through spreadsheets, email chains, shared folders, meetings, and repeated follow-up.
System 01
Risk and entity screening
System 02
Supplier and sourcing systems
System 03
Trade compliance systems
System 04
Customs broker systems
System 05
Legal and outside-counsel review
Manual work between them
Spreadsheets, email, shared folders, meetings, and repeated follow-up.
Nomira is not intended to replace those systems or advisors. It is being built to make the work between them visible and manageable.
One shared view of the records, gaps, owners, and next steps behind the UFLPA workflow.
Nomira is being built to help trade compliance teams manage the operating work that begins after a UFLPA concern appears.
- 01
See which information has been collected
Keep a clear record of the documents and supporting information already available.
- 02
Identify what is still missing
Surface missing, outdated, inconsistent, or incomplete records before they create a last-minute problem.
- 03
Assign clear ownership
Show which supplier, team, broker, advisor, or internal stakeholder owns each open item.
- 04
Track the work through review
Follow requests, open questions, follow-up, and review status in one shared process.
- 05
Prepare information for expert review
Organize the factual record so legal teams and outside counsel can review it without reconstructing the process from scattered files.
Built around the trade compliance leader, with every required handoff in view.
Primary reader
VP or Director of Trade Compliance
You are expected to coordinate the response, even when the records, systems, suppliers, and reviewers sit outside your direct control.
Others involved in the process
Trade compliance specialists
Find records, maintain trackers, follow up on missing information, and prepare materials for review.
Supply chain and sourcing
Control supplier relationships, upstream records, onboarding information, and operational follow-up.
Legal and outside counsel
Determine what can be relied upon, how information should be interpreted, and what may be used externally.
Customs brokers
Hold entry, shipment, and customs-process information and may coordinate requests during an active issue.
IT, security, and procurement
Determine whether data can be used and whether a new workflow can be responsibly adopted.
Show us where the current process breaks down.
The assessment begins with a recent UFLPA-related shipment, supplier, customer, broker, or legal workflow. Nomira maps how the work moved across people, systems, documents, and advisors, then determines whether the problem fits the initial Nomira workflow.
- 01
Choose one recent situation
Use a detention, near miss, customer request, supplier review, entity concern, or preventive planning process.
- 02
Walk through what your team did
Explain who became involved, which records were needed, where they were stored, and how follow-up was managed.
- 03
Identify where the work slowed or broke down
Focus on missing information, repeated follow-up, unclear ownership, review delays, and manual work.
- 04
Determine whether Nomira is a fit
If the problem matches the initial focus, Nomira may invite the company into a deeper design-partner discussion.
What the assessment covers
- The event or concern that started the work
- The records and information the team needed
- Where the information was stored
- The teams, suppliers, brokers, and advisors involved
- What was missing or difficult to obtain
- How the work was tracked
- Where review or follow-up slowed down
What the assessment does not cover
- Legal advice
- A legal sufficiency determination
- A decision about whether goods comply with UFLPA
- Review of confidential documents through the initial form
- A guarantee of design-partner selection
Build the first Nomira workflow around real importer operations.
Nomira is working with a limited number of U.S. importers to refine how the workflow should support real UFLPA preparation and response. The program is intended for teams with a specific, recurring process problem, not general interest in forced-labor compliance.
Best fit
- Meaningful exposure to high-risk suppliers, products, regions, or entities
- A recent detention, near miss, customer audit, supplier review, or recurring preparation burden
- A trade compliance owner who can explain the current process
- Willingness to involve legal, supply chain, security, procurement, a broker, or outside counsel when necessary
What participation may include
- Mapping one real workflow
- Reviewing a structured workflow design
- Identifying required controls, approvals, and data boundaries
- Giving feedback on how the process should fit existing systems and advisors
- Considering a later pilot if the workflow and commercial path are a fit
What participants receive
- A structured view of the current process and its major breakdown points
- Direct influence over Nomira’s initial workflow
- Early consideration for future pilot access
- No obligation to purchase
Qualification note: Nomira is prioritizing teams with a specific, recurring workflow problem and the ability to involve the stakeholders required to evaluate it.
The enforcement environment is established. The operating process inside many importers remains difficult.
UFLPA creates a clear legal and enforcement trigger for exposed importers. Nomira’s focus is the internal work required to find, organize, review, and maintain the information needed when that trigger becomes relevant.
The legal trigger is active
UFLPA’s rebuttable presumption has applied since June 21, 2022 to covered goods linked to Xinjiang or entities on the UFLPA Entity List.
Operational relevance
For exposed importers, a supplier or entity relationship can create an immediate need to locate and review supporting records.
The scope continues to change
In the 2025 strategy update, 78 entities were added, bringing the UFLPA Entity List to 144. New high-priority sectors included caustic soda, copper, lithium, red dates, and steel.
Operational relevance
Changes in entities and sectors can create new work for companies that previously considered a supplier, product, or sourcing path acceptable.
Enforcement creates real operating work
DHS reported that, as of August 1, 2025, CBP had stopped more than 16,700 shipments valued at almost $3.7 billion for further examination under UFLPA.
Operational relevance
When a shipment is stopped, teams may have to gather supplier, purchase, transportation, audit, and sourcing information under significant time pressure.
Future context: the EU Forced Labour Regulation becomes applicable on December 14, 2027. Nomira’s initial focus remains U.S. importers and UFLPA.
Start with the process, not sensitive documents.
The initial assessment asks for business context and a description of the workflow. It does not accept document uploads.
Do not include privileged, confidential supplier, personal, export-controlled, or other sensitive information in the initial request.
If a deeper review is appropriate, Nomira and the participating company must first agree on what information may be shared and how it should be handled.
Legal, security, procurement, broker, and outside-counsel participants can be included when the workflow requires them.
Nomira supports process organization. It does not provide legal advice or make compliance determinations.
Questions people ask before requesting an assessment.
Nomira is building a shared operating workflow for trade compliance teams managing UFLPA-related records, missing information, ownership, follow-up, and legal or outside-counsel review. Nomira is currently working with selected U.S. importers, and product access is not yet generally available.
When a UFLPA issue appears, the required information may be spread across suppliers, internal systems, inboxes, brokers, legal teams, and outside counsel. Trade compliance is expected to coordinate the response without a single view of what exists, what is missing, or who owns the next action.
The Nomira team reviews each request. If the company and workflow appear to fit the current focus, the team will contact you to reconstruct the process in more detail.
No. The assessment focuses on how information is collected, tracked, assigned, and prepared for review. Legal analysis and decisions about what may be relied upon or used remain with your legal team and outside counsel.
No. Nomira is designed to make the work between those systems and advisors easier to see and manage.
A U.S. importer with meaningful UFLPA exposure, a specific recurring workflow problem, and a trade compliance owner who can explain how the current process works.
Basic business context, your role, the type of situation involved, and a short non-sensitive description of the process problem. Do not submit documents through the initial form.
Tell us where the current UFLPA process is difficult to manage.
Start with a short, non-sensitive description. The Nomira team will review whether the company and workflow fit the current focus.