LEI lookup for foreign-owned federal vendors.

The Legal Entity Identifier is a unique 20-character alphanumeric code issued under the ISO 17442 standard. GLEIF, the Global Legal Entity Identifier Foundation, oversees the system and operates the public lookup at search.gleif.org. One LEI per legal entity, supported by high-quality reference data, treated as a public good.

Three identifiers crowd this space and get confused constantly. They are not interchangeable:

LEI (global, ISO 17442)

Identifies a legal entity anywhere in the world. Maintained by GLEIF. Free to query. Voluntary in most jurisdictions, mandatory for some financial-market participants.

UEI (US federal procurement)

The 12-character identifier assigned at SAM.gov registration. The federal contracting identifier for legal entities. See our SAM.gov walkthrough.

CAGE (US procurement, location-anchored)

The 5-character DLA-issued code that identifies a physical performance location of a US entity. See CAGE code lookup. NCAGE is the foreign counterpart.

The LEI fills a gap the UEI was never designed to close: cross-border entity resolution. When a US-registered vendor with a UEI is owned by a holding company in Luxembourg, the UEI says nothing about Luxembourg. The LEI, paired with GLEIF Level 2 parent data, does.

The code itself is 20 characters, alphanumeric, with embedded checksum digits in the final two positions. The standard rests on four GLEIF-published principles, summarized at www.gleif.org/en/about-lei/iso-17442-the-lei-code-structure:

Global standard

A single standard recognized internationally, not a regional schema.

Single unique identifier

One code per legal entity. No duplicates, no parallel records for the same entity.

High-quality data

Reference data validated by accredited Local Operating Units (LOUs).

Public good

"A public good, available free of charge to all users." That phrasing matters: there is no licensing barrier, no tiered access, no per-query fee.

The federal answer is unambiguous. SAM.gov entity registrationstates: "As part of registration, we will assign you a Unique Entity ID." The LEI is not listed as a SAM precondition, not a substitute, not an alternative path. UEI is the federal procurement identifier.

So why does the LEI matter for federal vendors at all? Because the UEI is US-only. It identifies the entity that registered in SAM. It does not, on its own, surface that the SAM-registered entity is a wholly owned US subsidiary of a non-US holding company.

UEI scope

US federal procurement. Assigned at SAM registration. 12 characters. Required to receive a federal award.

LEI scope

Global. Assigned by GLEIF accredited issuers. 20 characters. Not federally required, but it is the handle that makes parent and ultimate-parent records findable across borders.

Practical pairing

For a foreign-owned US vendor: UEI identifies the US entity for SAM purposes; LEI identifies the same entity in the global registry, and Level 2 data exposes its non-US parent chain.

This is the part most procurement teams underuse. GLEIF Level 2 data captures who-owns-whom relationships across LEI-registered entities.

Per GLEIF: "Legal entities that have or acquire an LEI report their ‘direct accounting consolidating parent’ as well as their ‘ultimate accounting consolidating parent.’" And on access: "Any interested party can access and search the complete LEI data pool free of charge and without the need to register."

Direct parent

The next entity up the consolidation chain. The immediate accounting parent that consolidates the registrant.

Ultimate parent

The top of the consolidation chain. The entity that ultimately consolidates the registrant's financials, often a holding company in a different jurisdiction.

Self-reported, with caveats

Registrants self-report parent relationships. GLEIF defines exception flags for reasons a parent cannot be disclosed (consent withheld, no consolidating parent, jurisdictional restriction). Read the exception, do not assume absence of a parent record means absence of a parent.

Coverage gaps

Not every entity in the world has an LEI. If a US-registered vendor has no LEI, GLEIF cannot help on that lookup. Conversely, if the parent has no LEI, the registrant's Level 2 record may name the parent in free text without a linkable LEI reference.

Workflow: enter the US subsidiary's LEI at search.gleif.org, open the relationships tab, read the direct and ultimate accounting consolidating parent. If the ultimate parent sits in a covered foreign country or in a sanctioned jurisdiction, that finding shapes the rest of the diligence.

Federal procurement uses the term "covered foreign country" in a very specific, very narrow way. Per FAR 4.2101: "Covered foreign country means The People's Republic of China."

That is the entire definition under FAR Subpart 4.21. It pairs with the FAR 52.204-25 prohibitions on covered telecommunications equipment, which derive from Section 889(a)(1)(B) of the FY 2019 NDAA. If GLEIF Level 2 surfaces a Chinese ultimate parent on a US vendor in your stack, FAR 4.21 and Section 889 are the two regulatory anchors you read first.

Section 889 hardware path

Walk the hardware screen step by step in our Section 889 check. The clause prohibits federal contractors from using covered telecom equipment, regardless of whether the contract itself involves that equipment.

FAR 52.204-25 representation walk-through

See our FAR 52.204-25 walkthroughfor the rep-and-cert obligations and the offeror's reporting duties when covered equipment is identified after award.

Other statutes use broader country lists

DFARS prohibited-source clauses, ITAR (22 CFR 126.1), and EAR (15 CFR 740, 744, 746) reference broader and different lists. FAR 4.2101 is narrow and specific; do not generalize it to mean "any country of concern" in a different regulatory context.

OFAC's 50 Percent Rule, which treats entities owned 50% or more by one or more blocked persons as themselves blocked, is a separate compliance regime that often comes up the moment GLEIF surfaces a foreign parent chain. It is conceptually adjacent to LEI lookup, operationally distinct.

The canonical Treasury document is Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked, issued by OFAC on August 13, 2014. It replaced the prior guidance posted on February 14, 2008. The 2014 revision is still the operative rule and was paired with new FAQs covering layered ownership, non-controlling stakes, and aggregation across multiple blocked owners. Read the source document and OFAC's current FAQ set on the OFAC FAQs page before applying the rule to any specific ownership chain. The list of blocked persons is the Specially Designated Nationals (SDN) List, which OFAC updates without a fixed schedule.

GLEIF is one of the eight federal and global data sources DiligenceDesk integrates. Identity resolution starts with whatever you put in (legal name, UEI, CAGE), anchors to the SAM record, and pulls the GLEIF record where one exists. Where GLEIF Level 2 returns direct or ultimate accounting consolidating parents, those surface in the audit alongside SAM, ITA sanctions, and Section 889 hardware findings.

What DD does on GLEIF

Resolves the entity to its LEI where one exists, fetches Level 2 parent records, and surfaces the direct and ultimate accounting consolidating parents in the entity-identity section of the audit.

What DD does NOT do on OFAC 50%

DiligenceDesk does not perform OFAC 50 Percent Rule analysis. That is a specialized compliance step that requires sanctions-list matching, ownership-percentage modeling, and case-by-case judgment outside the scope of automated identifier lookup.

Methodology and data sources

Read the full eight-source list and the order of operations on the methodology page. For the broader sanctions context that sits next to (but distinct from) OFAC 50%, see the CSL guide.