The Defense Counterintelligence and Security Agency (DCSA) published a press release on May 9, 2025, announcing an updated Standard Form 328 (SF-328), Certificate Pertaining to Foreign Interest. The updated form was approved...more
6/25/2025
/ Beneficial Owner ,
Defense Contracts ,
Department of Defense (DOD) ,
Disclosure Requirements ,
Federal Contractors ,
FOCI ,
Foreign Affiliates ,
Foreign Ownership ,
Government Agencies ,
National Security ,
Press Releases ,
Reporting Requirements ,
Required Forms ,
Risk Management
U.S. Department of Defense (DOD) contractors with foreign ownership, control, or influence (FOCI) soon will face new requirements. Though cleared DOD contractors have long been bound by FOCI obligations, the new rule will...more
4/24/2025
/ Beneficial Owner ,
Covered Entities ,
Defense Contracts ,
Defense Sector ,
Department of Defense (DOD) ,
DFARS ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Federal Procurement Systems ,
Foreign Entities ,
Foreign Nationals ,
National Security ,
NDAA ,
Proposed Rules ,
Risk Mitigation ,
Subcontractors ,
Supply Chain
In the latest episode of "Are We All Clear?", host Molly O'Casey and national security attorney Antonia Tzinova discuss Section 847 of the National Defense Authorization Act (NDAA), aimed at mitigating Foreign Ownership,...more
The 11th episode of "Are We All Clear? Facilitating Security Clearances" explores the role of outside directors and proxy holders within the National Industrial Security Program Operating Manual (NISPOM) framework and their...more
In the ninth episode of "Are We All Clear? Facilitating Security Clearances," host Molly O'Casey and International Trade attorney Antonia Tzinova delve into the critical aspects of due diligence for facility and personnel...more
In the latest episode of "Are We All Clear? Facilitating Security Clearances," host Molly O'Casey engages in an insightful conversation with Antonia Tzinova, leader of Holland & Knight's CFIUS and Industrial Security Team....more
Facility security clearance (FCL) sponsorship packages for U.S. government contractors currently have a rejection rate of more than 50 percent. For initial and upgrade FCL packages, there is a 70 percent rejection rate. These...more
The Department of Defense's (DoD) Defense Counterintelligence and Security Agency (DCSA)1 hosted its 26th Annual Conference on Foreign Ownership, Control, or Influence (FOCI Conference) on Aug. 25, 2022, which was attended by...more
In a final rule effective Feb. 24, 2021, the U.S. Department of Defense (DoD) codified the National Industrial Security Program Operating Manual (NISPOM) in Title 32, Part 117 of the Code of Federal Regulations. Of primary...more
• The White House has issued a new Executive Order designed to promote the use of American-made products in all infrastructure projects receiving federal funding, another step in the Trump Administration's Buy American...more
2/7/2019
/ Aluminum Sales ,
Berry Amendment ,
Buy American Act ,
Construction Industry ,
Construction Project ,
Executive Orders ,
Federal Contractors ,
Federal Funding ,
Infrastructure Financing ,
Manufacturers ,
Steel Industry ,
Supply Chain ,
Trade Agreements Act ,
Trump Administration
• The Information Security Oversight Office (ISOO) has issued a Final Rule to its 32 C.F.R. Part 2004 National Industrial Security Program (NISP) Directive, which is the overarching policy for federal agencies involved in...more
7/6/2018
/ CFIUS ,
Data Security ,
Defense Contracts ,
Defense Security Service (DSS) ,
Department of Homeland Security (DHS) ,
Eligibility ,
Federal Contractors ,
Final Rules ,
FOCI ,
Information Security ,
National Security ,
New Rules ,
NISPOM ,
ODNI ,
Security Clearance