Alpha Covenant Holdings · Duty Sheet · generated 2026-10-25 17:46 UTC · free · all sheets

Transaction diligence — target vendor and supplier list read against the federal national-security and trade lists (CFIUS and export-control context)

Applies to: Buy-side M&A counsel, private-equity deal and compliance teams and CFIUS counsel reviewing a target's vendor, supplier and customer lists · Rule text: https://www.ecfr.gov/current/title-31/subtitle-B/chapter-VIII/part-800

The question the rule asks

For each name on the target's list, what did the Consolidated Screening List (which carries the BIS Entity List, Unverified and MEU lists and the Nonproliferation Sanctions), OFAC's SDN list, the DoD Section 1260H notice, the FARA registration file, the UFLPA Entity List, the FCC Covered List and SAM.gov print under the exact name — and which did not answer? 31 CFR Part 800 governs CFIUS filings and does not itself require a vendor screen; the screen is the acquirer's diligence choice, and exposure is counsel's conclusion.

The party this sheet is about

Wellpath LLC · keys supplied: UEI JL99G1YPJKK9 · matching: screening-2026-06f: every check is an exact-name (or exact-UEI / exact-NPI / exact-EIN / exact-CIK) lookup against the official file named on the line; nothing is inferred from similar names, owners or affiliates

Receipt r_60dd749d07394641 · read 2026-10-25 17:46:58 UTC · SHA-256 a997061a8869fa30a2c79c1dd7fef97365ab21348c9ea3b98617f57d67058685 · verify: https://alphacovenantholdings.com/r/r_60dd749d07394641

The official files that answer it, as read on that date

SourceRoleStateRecordsWhat it printed
Consolidated Screening List (trade.gov) — BIS, State and Treasury lists, OFAC SDN excluded here because it is read directlyanswers the questionanswered00 export-control or sanctions list entries (BIS, State, Treasury non-SDN) under this exact printed name
U.S. Treasury OFAC — Specially Designated Nationals and Blocked Persons List (SDN.CSV)answers the questionanswered0No entry under this exact name or listed alias on the SDN list fetched 2026-10-24.
DoD Section 1260H list (Chinese military companies operating in the United States) — entities and the statutory basis as published in the latest Federal Register notice of designationanswers the questionanswered00 DoD Section 1260H entries (name or alias as the notice prints it) under this exact printed name
FARA active registrants (DOJ Foreign Agents Registration Act eFile — registrants with an active registration, as the API prints them)answers the questionanswered00 active FARA registrations under this exact printed name
UFLPA Entity List (FLETF, 19 U.S.C. 4681) — complete list as published in the appendix to the latest Federal Register noticesupportinganswered00 UFLPA Entity List entries (name or alias as the FLETF prints it) under this exact printed name
FCC Covered List (47 CFR 1.50002) — producers and providers of covered communications equipment or services, as the Commission prints themsupportinganswered00 FCC Covered List row(s) whose printed producer name is contained in this name
SAM.gov Exclusions — Public Extract V2 (GSA, daily)supportinganswered0No entry under this exact name/UEI in the SAM extract fetched 2026-10-25 (SAM_Exclusions_Public_Extract_V2_26298.ZIP).
UN Security Council Consolidated List (all individuals and entities subject to Security Council sanctions measures, official XML)supportinganswered00 UN Consolidated List entity row(s) under this exact printed name or alias
SEC EDGAR (registrant submissions index, data.sec.gov)supportinganswered0EDGAR's entity index lists no registrant under this exact printed name (a registrant may file under a different printed name — see the EDGAR company search).
USAspending.gov (recipient name equals this name)supportinganswered1 registered recipient(s) equal this name; 24 active prime award(s), $3,830,809 obligated
SAM.gov entity registrationcross-sourcedid not answer — nothing stands in for it

What to record in the file

A roster receipt over the whole list (up to 500 names), each name's rows as printed with the list's own file date and the receipt SHA-256; a same-name row is a candidate for counsel to resolve, not a hit. Nothing here certifies that a supplier is or is not on a list — it prints what the lists printed on the date.

What this sheet does not decide

The receipt does not decide eligibility, responsibility, identity or compliance. It records what each official file printed for an exact key or exact printed name on a date. A same-name row is a candidate to be resolved by the reader, not a match. Answering the form's question is the applicant's or reviewer's act; this sheet puts the dated record beside it.

Full receipt (all sources, known limits, print record): screening record · Methodology: https://alphacovenantholdings.com/methodology · Corrections (free, public log): https://alphacovenantholdings.com/corrections