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DCSA Releases Updated Standard Form 328, Certificate Pertaining to Foreign Interests

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

DOD Proposed Rule Will Expand FOCI Requirements to Non-Classified Defense Contracts

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

Mitigating FOCI Under Section 847 [Video]

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

Podcast - FOCI Mitigation: SSAs, SCAs and Proxy Agreements [Video]

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

Podcast - Navigating M&A Due Diligence: Safeguarding Security Clearances [Video]

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

Decoding the Key Management Personnel Requirements [Video]

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

DCSA Updates Facility Security Clearance Package Submission Procedures

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

Top Insights from DCSA's Annual FOCI Conference

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

DoD Codifies NISPOM, Formalizes Certain Personnel Reporting Requirements and Eases FOCI Burden

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

White House Issues Executive Order Expanding "Buy American" Program - Directs Agencies to Promote Use of Domestic Materials in all...

• 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

Final Rule Revises National Industrial Security Program

• 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

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