Federal contractors, subcontractors at every tier, and recipients of federal funds must certify where their equipment came from and who owns the companies that built it. Almost none of them can produce the evidence behind that signature. We can — on documents your supplier did not write, in a file that holds up after the container is stopped.
Figures from GAO reporting on DoD supply-chain visibility and from Govini's tier-one analysis. Sources cited in full on request — we do not publish a number we cannot show you the origin of.
Every federal supply-chain restriction of the last decade works the same way. The government does not audit your factory. It makes you represent something — that you do not use covered telecommunications equipment, that your magnets were not mined in a covered nation, that no prohibited entity owns the company that built your assembly — and then holds you to that representation.
What none of these regimes define is what a sufficient inquiry looks like. There is no prescribed form, no safe-harbour checklist, no minimum documentation standard. A contractor is left to certify on the strength of whatever it happens to know, which is usually its tier-one purchase orders and nothing beneath them.
That gap is not a rounding error. The government's own auditors report country-of-origin data on under ten percent of DoD's component and raw-material suppliers. The obligation to know sits with industry. The ability to know, for most of industry, does not yet exist.
This is the firm that built the method for closing it. Every file we issue is documented, reproducible, and explicit about where the inquiry stopped — because an origin claim that cannot say where it ends is not evidence. It is a guess on letterhead.
Every regime in this space asks the same three questions — who owns it, where was it made, and can you prove it. Most advisers rebuild the answer from scratch for each one and bill you each time. We build the evidence file once and answer all four from it, which is why our second engagement with a client costs you less than the first.
The representation behind FAR 52.204-24 and 52.204-25 is a certification, not a checkbox. We assemble and test the record that stands behind it — vendor by vendor, with the corporate chain resolved and the equipment authorizations reconciled.
The prohibition follows the money. Recipients and subrecipients of federal grants, loans and cooperative agreements carry it without ever holding a federal contract — broadband, EV charging, transit, municipal and utility programs alike. Most recipients do not know the clause reached them.
The only regime here that needs no federal nexus at all: it binds any importer of record, and it is enforced by detaining your cargo. On August 3 the Entity List grew by 43 names — its largest expansion ever — and the additions sit directly on solar, storage, and equipment bills of materials: a tier-one inverter maker, the aluminum behind frames and racking, battery foil, and the electrolytic capacitors inside nearly every power supply. The rebuttable presumption puts the evidentiary burden on you, at the port, after the container has already stopped. We watch the list daily and screen client vendor files against every addition. Screen your own vendor list now — free, in your browser.
The one gate in this space that a company can actually move. Where the content test is the barrier, we model the bill of materials against the domestic end-product threshold and the COTS exception, and map the substitution path — with a customs binding ruling routed through licensed counsel where the origin question is genuinely close. For infrastructure money, we track the Made in America waiver registers daily: an expiring non-availability waiver is a compliant supply chain with a published expiration date, and we tell you before the date does.
For facilities beginning construction after December 31, 2025, the material-assistance cost ratio decides whether your tax credit exists at all: fail the threshold — 40 percent for 2026 construction, ratcheting to 60 — and the entire credit is unavailable, not reduced. The prohibited-entity tests reach ownership, debt, board seats, and the fine print of IP licenses; the evidence lives in supplier cost data and contracts your counterparties treat as confidential. We build the substantiation file the statute assumes you already have — the same origin discipline, aimed at the largest number on your project's balance sheet — and the diligence package a §6418 credit buyer will actually accept.
Then it becomes an annuity, because the obligation does. These representations renew annually with your registration, and evidence goes stale faster than most companies expect — suppliers get acquired, plants move, ownership changes. We maintain the file and re-verify it on a calendar. Attestation programs from $15,000/year.
A plant visit proves a plant exists and shows you what stood on the floor the day you were in it. It proves nothing about the origin of components that arrived in cartons — which is the only question you were actually asked. Origin is proved on paper, by triangulation, and where it counts by asking someone other than your supplier. Anyone selling you a site visit as origin evidence is selling you a photograph.
Customs entry records, bills of lading, export declarations, chamber-issued certificates of origin, corporate registry filings, equipment-authorization grants. Every one of them was filed under penalty, for another purpose, often years before anyone thought to ask you this question — which is precisely what makes them worth having. A supplier's assurance is the weakest document in the file. It is where we start and never where we finish.
We cross-check records that would have to be falsified together to deceive us. Does the grantee code match the claimed applicant? Does the shipper on the bill of lading match the claimed manufacturer? Does the registry confirm the ownership chain to the disclosed level? Does the shipment volume make physical sense for that site? Inconsistency is the signal. Agreement across independent records is the finding.
We write to the named sub-supplier and obtain written confirmation that it supplies that part to that customer. This is the external-confirmation procedure any auditor would recognize on sight — and in the parts of Asia that publish no manifest data, it is not corroboration. It is the primary evidence. Firms that skip this step are not tracing your supply chain. They are reformatting your supplier's claims and charging you for the layout.
Where a site genuinely must be seen, we instruct an established inspection firm with people already in that city and pass the cost through at actuals with no markup. We would rather commission an inspector who is there every week than bill you for a plane ticket.
Every file is issued at a stated level of assurance under the Gatewell Protocol, the Group's published origin-evidence standard — documented, independently verified, or continuously monitored. The level tells your counterparty precisely how far the inquiry went, and certificates are checkable in the Group's public registry.
Most of this field is sold on urgency nobody checked. We read the primary text and we mark every line — in force, dated, or merely proposed. A client who reorganizes a supply chain around a rule that does not exist has been badly served, and will remember who served them.
| Date | Instrument | Status | Who it reaches |
|---|---|---|---|
| In force | Section 889(a)(1)(A) / (B) covered telecommunications prohibition, with FAR 52.204-24 / -25 representations | Law | All federal agencies, their prime contractors and subcontractors |
| In force | 2 CFR 200.216 — prohibition flowed to recipients and subrecipients of federal awards | Law | Grant, loan and cooperative-agreement recipients — no contract required |
| In force | UFLPA rebuttable presumption, enforced at the port — Entity List at 187 entities after the Aug 3, 2026 expansion, the largest ever | Law | Any importer of record — no federal nexus required |
| In force | Clean-energy credit FEOC restrictions — the material-assistance cost ratio (40% for 2026 construction, ratcheting to 60%) that voids the entire credit on failure | Law | §45Y/§48E facilities beginning construction after Dec 31, 2025; §45X components; §6418 credit buyers demanding diligence |
| 1 Jan 2027 | Covered-material origin proof escalates from “melted or produced” to “mined, refined, separated, melted, or produced” — magnets, tantalum, tungsten | Law | DoD contracts, flowed to all subcontract tiers with no dollar threshold |
| 1 Jan 2027 | Sensitive-materials waivers cease to issue absent a formal mitigation plan documenting sourcing efforts, removal steps and a timeline | Directive | DoD contractors relying on a covered-material waiver today |
| Pending | Beneficial-ownership and foreign-influence disclosure on unclassified DoD contracts and subcontracts above $5M | Proposed | An estimated 37,740 entities, roughly 57% of them small businesses |
| Pending | Implementation guidance for indentured bills of materials tracing to raw-material origin | Directed | Nobody yet — this instructs an agency to write rules; it is not a present obligation on any contractor |
Statuses verified against primary text and reviewed on a standing cycle. Where an item is proposed, we say so — and we will not price an engagement against a rule that does not exist.
Every engagement opens with a fixed-fee Exposure Diagnostic — two weeks, $7,500 to $15,000 depending on scope — which establishes which obligations actually reach you, which vendors carry the risk, and what the evidence gap is. Half is credited against the engagement that follows.
The diagnostic is also the pricing instrument. Vendor work is priced per vendor by depth of evidence: documentary review, review with independent supplier confirmations, or deep multi-tier trace. Your quote is one fixed number — a published base plus itemised, objective scope adders — so it reads as computed rather than negotiated.
Published fees are fixed and are not discounted — not for volume, not for speed, not for the promise of more work later. A price that moves under pressure tells you the first number was never the real one. Outside costs — laboratories, inspection firms, customs counsel — are billed to you directly at actuals, without markup, and we never hold client funds.
Two weeks. A fixed fee. A documented answer on which federal obligations reach your supply chain, and exactly what evidence stands behind the representations already carrying your signature. You will know both before anyone else asks you.
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