Daniel Murphy was investigating forced labor in Chinese seafood processing plants in 2023 when he hit upon what he described as a “very potent” methodology for flagging potential labor transfers from the Xinjiang Uyghur Autonomous Region.

Tracking the movement of Uyghurs and other repressed ethnic minorities from their homeland, he said, requires looking beyond government announcements, state media articles and other text-based material to videos and imagery posted on Chinese social media platforms, including workers’ own content showing them toiling on factory floors or appearing outside dormitories. Yet the risk signals in those posts have been “completely under-leveraged” by other risk intelligence solutions.

This more holistic view of human rights risk, which also provides a window into the lives of the people being exploited, formed the basis for Pamir Solutions, a company that employs a specialized compliance and risk management database to track state-imposed forced labor risks across China—not just within Xinjiang.

Beijing has pushed back against allegations of forced labor, saying its labor transfer programs are voluntary poverty alleviation measures aimed at improving living standards. Relying solely on Chinese state media, Murphy said, allows the government to control what companies learn about forced labor practices that could affect their supply chains.

On Tuesday, Murphy said that the Pamir Intelligence Platform was being made available to the Uyghur Forced Labor Prevention Act Entity List Office under the U.S. Department of Homeland Security. The goal, he said, was to turn “fragmented evidence” into “clear, entity-level intelligence” that can help the Entity List Office identify companies implicated in the use or facilitation of forced labor.

The uneven expansion of the Entity List has been a source of consternation for human rights groups because enforcement delays and difficulty mapping complex supply chains can allow companies to bypass bans by routing forced-labor-tainted materials through unlisted intermediaries in third countries. In July, DHS, on behalf of the interagency Forced Labor Enforcement Task Force it leads, announced the addition of 43 entries to the Entity List, the roster’s largest expansion and its first update since the end of the Biden administration in January 2025.

Customs and Border Protection has previously contracted with Oritain for origin-testing services and with Exiger, a supply chain AI and risk management company whose technology detects illicit transshipment. Pamir, which uses machine learning to scrape, parse and categorize vast amounts of unstructured video, image and social media data for its SaaS database, offers another tool. (The idea, Murphy said, was to “automate” him out of the picture and scale Pamir’s protocol.) But Murphy wants to make clear that Pamir isn’t a traceability platform. Rather, it conducts site-level investigations that follow the workforce to uncover forced labor risks that conventional traceability may miss.

“We don’t map supply chains,” he said. “We’ll never have one of our customers come onto our platform, conduct a risk assessment, and be told there may be this entity in their supply chain. We only risk assess based on the entities that we’re provided visibility on; we’re not extrapolating your Tiers 4, 5, 6.”

Pamir can, however, tell a customer who works at a site, where they came from, how they were recruited or transferred and which government bodies or intermediaries brought them there.

The platform is also “human first,” he said. All of Pamir’s intelligence is reviewed by human analysts because there can’t be any “AI slop in the picture” when it comes to risk intelligence that triggers C-suite concerns.

Amid a host of unknowns, if there’s one thing Murphy is certain of, it’s that DHS is increasingly looking beyond Xinjiang in its UFLPA enforcement—a shift he considers important given mounting evidence of forced labor elsewhere in China. He expects more additions to the Entity List, making visibility into worker movements all the more important. While existing supply chain tracing tools work well for tracking physical goods and raw materials by connecting corporate registries and bills of lading, shipping documents don’t show where workers go.

“DHS has signaled in both its enforcement strategy and its actual actions in terms of Entity List decisions and seizures at the border that the labor transfer system is as much of a concern as the forced labor practices within the region,” he said. “It’s really important that business has tools to get visibility into those risks because this has been a real gap for the global business community.”

What’s important for companies to understand, Murphy said, is that forced labor risk is dynamic. At the same time, brands shouldn’t feel overwhelmed or assume that China’s high-risk status makes sourcing from every part of the country equally risky.

“When we start to map out this labor transfer system, we see that risk is very highly concentrated in specific districts of China, as in sub-prefecture-level administrative zones, and that makes it almost predictable, or at least you’re able to model risk based on the location of a supplier,” Murphy said. “When you see that distribution of risk is actually quite concentrated, it enables you to overcome this sense of powerlessness that there’s no way to get ahead of a complex, shifting risk, because that’s really not the case.”