{"kind":"evidence_file","company":{"id":"c0223375-f706-4f86-8ad0-f057ceb0b80b","name":"ZhengHeng Group Co. Ltd.","mergedInto":null},"asOf":"2026-10-27T18:44:29.741Z","asOfBasis":"instant","generatedAt":"2026-10-27T22:06:57.783Z","claims":[{"predicate":"name","value":"zhengheng group co","source":"UK OFSI Consolidated List","sourceUrl":"https://ofsistorage.blob.core.windows.net/publishlive/2022format/ConList.xml","sourceRecordId":"16306","observedAt":"2026-08-28T12:00:58.035Z","confirmedAt":"2026-10-08T15:04:36.474Z","validFrom":null,"validTo":null,"supersededLater":null},{"predicate":"name","value":"zhengheng group co","source":"UK Sanctions List (FCDO)","sourceUrl":"https://sanctionslist.fcdo.gov.uk/docs/UK-Sanctions-List.xml","sourceRecordId":"16306","observedAt":"2026-09-13T15:02:01.058Z","confirmedAt":"2026-10-26T05:00:15.121Z","validFrom":null,"validTo":null,"supersededLater":null},{"predicate":"primary_country","value":"KH","source":"UK OFSI Consolidated List","sourceUrl":"https://ofsistorage.blob.core.windows.net/publishlive/2022format/ConList.xml","sourceRecordId":"16306","observedAt":"2026-08-28T12:00:58.039Z","confirmedAt":"2026-10-08T15:04:36.479Z","validFrom":null,"validTo":null,"supersededLater":null},{"predicate":"primary_country","value":"KH","source":"UK Sanctions List (FCDO)","sourceUrl":"https://sanctionslist.fcdo.gov.uk/docs/UK-Sanctions-List.xml","sourceRecordId":"16306","observedAt":"2026-09-13T15:02:01.062Z","confirmedAt":"2026-10-26T05:00:15.124Z","validFrom":null,"validTo":null,"supersededLater":null},{"predicate":"website","value":"www.zhenghengcambodia.com","source":"UK OFSI Consolidated List","sourceUrl":"https://ofsistorage.blob.core.windows.net/publishlive/2022format/ConList.xml","sourceRecordId":"16306","observedAt":"2026-09-13T14:35:45.601Z","confirmedAt":"2026-10-08T15:04:36.482Z","validFrom":null,"validTo":null,"supersededLater":null},{"predicate":"website","value":"www.zhenghengcambodia.com","source":"UK Sanctions List (FCDO)","sourceUrl":"https://sanctionslist.fcdo.gov.uk/docs/UK-Sanctions-List.xml","sourceRecordId":"16306","observedAt":"2026-09-13T15:02:01.064Z","confirmedAt":"2026-10-26T05:00:15.128Z","validFrom":null,"validTo":null,"supersededLater":null}],"listings":[{"listingId":"16306","regime":"UK OFSI","program":"Global Human Rights","state":"in_force","stateSince":"2026-08-28T12:00:58.054Z","recordedAt":"2026-08-28T12:00:58.054Z","designatedAt":"2023-12-07T00:00:00.000Z","validTo":null,"legalBasis":"The Global Human Rights Sanctions Regulations 2020","reason":"ZhengHeng Group Co. Ltd (“ZhengHeng Group”) is an involved person under the Global Human Rights Sanctions Regulations 2020 is an involved person under the Global Human Rights Sanctions Regulations 2020 because it has facilitated or provided support for or obtained benefit from activity that violates the to be free from slavery, not to be held in servitude or required to perform forced or compulsory labour Specifically, individuals were held at Long Bay Development premises owned by ZhengHeng Group where they were forced to work as scammers","sanctionType":"Asset freeze, Director Disqualification Sanction","documentUrl":null,"assertedBy":["UK OFSI Consolidated List","UK Sanctions List (FCDO)"],"sourceNow":"UK Sanctions List (FCDO)"}],"ownership":[],"lists":[{"source":"EU Consolidated Sanctions List","readAt":"2026-10-26T04:33:16.293Z","recordsRead":6269,"publishedAt":"2026-10-23T15:05:43.888Z","publishedAtBasis":"stated_in_file","publisherVersion":"globalFileId 185833","publisherRecordCount":null,"daysOldWhenRead":3,"detail":null,"statement":"Read on 26 October 2026. The publisher dates the file 23 October 2026, 3 days before it was read."},{"source":"Malaysia BNM financial consumer alert list","readAt":"2026-10-26T11:00:30.101Z","recordsRead":588,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 26 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"Malaysia SC investor alert list","readAt":"2026-10-26T09:01:45.100Z","recordsRead":1803,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 26 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"OFAC SDN","readAt":"2026-10-26T04:13:22.021Z","recordsRead":17561,"publishedAt":"2026-10-21T00:00:00.000Z","publishedAtBasis":"stated_in_file","publisherVersion":null,"publisherRecordCount":19471,"daysOldWhenRead":5,"detail":null,"statement":"Read on 26 October 2026. The publisher dates the file 21 October 2026, 5 days before it was read."},{"source":"Slovenia KPK business restrictions","readAt":"2026-10-15T11:03:08.201Z","recordsRead":4351,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 15 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"Switzerland SECO Sanctions List","readAt":"2026-10-26T09:03:48.311Z","recordsRead":7036,"publishedAt":"2026-10-20T00:00:00.000Z","publishedAtBasis":"stated_in_file","publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":6,"detail":null,"statement":"Read on 26 October 2026. The publisher dates the file 20 October 2026, 6 days before it was read."},{"source":"Türkiye MASAK asset freezes","readAt":"2026-10-22T12:00:24.158Z","recordsRead":2304,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 22 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"UK OFSI Consolidated List","readAt":"2026-10-08T15:05:56.072Z","recordsRead":5120,"publishedAt":"2026-06-03T00:00:00.000Z","publishedAtBasis":"newest_record_date","publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":127,"detail":"Newest designation in the file: 2025-12-19.","statement":"Read on 8 October 2026. The file carries no date of its own; its newest record is dated 3 June 2026, 127 days before it was read. Newest designation in the file: 2025-12-19."},{"source":"UK Sanctions List (FCDO)","readAt":"2026-10-26T05:02:22.241Z","recordsRead":5705,"publishedAt":"2026-10-16T00:00:00.000Z","publishedAtBasis":"stated_in_file","publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":10,"detail":null,"statement":"Read on 26 October 2026. The publisher dates the file 16 October 2026, 10 days before it was read."},{"source":"US CBP forced-labour orders (WRO & Findings)","readAt":"2026-10-27T13:00:22.528Z","recordsRead":63,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 27 October 2026. No date from the publisher is read for this file, so its age is not known here."},{"source":"US Consolidated Screening List","readAt":"2026-10-26T07:03:39.603Z","recordsRead":6479,"publishedAt":null,"publishedAtBasis":null,"publisherVersion":null,"publisherRecordCount":null,"daysOldWhenRead":null,"detail":null,"statement":"Read on 26 October 2026. No date from the publisher is read for this file, so its age is not known here."}],"reading":{"assessmentId":"b4b19c2c-b248-4946-976c-b2a70f077827","takenAt":"2026-09-06T17:13:41.592Z","methodology":"v4","level":"medium","overall":60,"digest":"bd437ffb931c881a72a33f49784f8db6961acb16","coverage":{"dimensions":[{"counts":{"found":1,"not_found":9},"sources":[{"name":"EU Consolidated Sanctions List","status":"not_found","attemptedAt":"2026-08-28T15:36:29.864Z"},{"name":"Malaysia BNM financial consumer alert list","status":"not_found","attemptedAt":"2026-08-31T15:51:29.907Z"},{"name":"Malaysia SC investor alert list","status":"not_found","attemptedAt":"2026-08-31T09:00:45.899Z"},{"name":"OFAC SDN","status":"not_found","attemptedAt":"2026-08-28T16:28:26.648Z"},{"name":"Slovenia KPK business restrictions","status":"not_found","attemptedAt":"2026-09-03T11:01:50.151Z"},{"name":"Switzerland SECO Sanctions List","status":"not_found","attemptedAt":"2026-08-31T09:01:35.798Z"},{"name":"Türkiye MASAK asset freezes","status":"not_found","attemptedAt":"2026-09-03T12:00:11.768Z"},{"name":"UK OFSI Consolidated List","status":"found","attemptedAt":"2026-08-28T15:20:44.438Z"},{"name":"US CBP forced-labour orders (WRO & Findings)","status":"not_found","attemptedAt":"2026-09-01T13:00:04.513Z"},{"name":"US Consolidated Screening List","status":"not_found","attemptedAt":"2026-08-28T15:54:36.663Z"}],"dimension":"sanctions"},{"counts":{"not_found":4},"sources":[{"name":"Malaysia BNM financial consumer alert list","status":"not_found","attemptedAt":"2026-08-31T15:51:36.262Z"},{"name":"Malaysia SC investor alert list","status":"not_found","attemptedAt":"2026-08-31T09:00:52.349Z"},{"name":"Slovenia KPK business restrictions","status":"not_found","attemptedAt":"2026-09-03T11:01:57.777Z"},{"name":"US CBP forced-labour orders (WRO & Findings)","status":"not_found","attemptedAt":"2026-09-01T13:00:11.700Z"}],"dimension":"debarment"}],"jurisdictions":[{"gap":"No company register for this jurisdiction has been connected to this system, and none has been examined.","reasons":["registered here"],"countryId":"KH","registers":[]}]},"ownership":null},"limits":["Whether each listing was in force is rebuilt from what was recorded here: when it was first read, when a source stopped or resumed carrying it, and when its published term ended. A listing in force at an authority before this system first read it is shown from that first read.","No ownership verdict is kept for this company. Verdicts are kept for companies registered where shareholders are read here: Estonia, Latvia and Poland."]}