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Beneficial Owner Department of Defense (DOD)

Holland & Knight LLP

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

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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

Pillsbury Winthrop Shaw Pittman LLP

847 Awaiting Takeoff: DCSA Issues Guidance on Expanded Scope of FOCI Assessments

Section 847, which will expand foreign ownership, control or influence requirements to non-classified contracts, is on track for implementation in 2026. Section 847 of the National Defense Authorization Act for FY 2020...more

Holland & Knight LLP

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

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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

PilieroMazza PLLC

Weekly Update for Government Contractors and Commercial Businesses – December 2024

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Corporate Transparency Act, Part 4: Reporting Requirements Temporarily Suspended - As you may have been following, PilieroMazza previously reported on the requirements of the Corporate Transparency Act (CTA) and the...more

Arnall Golden Gregory LLP

Three-Pronged Approach: The NDAA Prioritizes a Pro-Domestic Procurement Policy

On January 1, 2021, the National Defense Authorization Act for Fiscal Year 2021 (“NDAA”) was passed by Congress and became law, following an attempted veto by former President Donald Trump. The NDAA’s primary purpose is to...more

Miller Canfield

New Corporate Transparency Act Will Impose Beneficial Ownership Reporting Requirements on Many Companies, Particularly Small...

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The Corporate Transparency Act (CTA), part of the 2021 National Defense Authorization Act enacted into law on January 1, 2021, will impose new beneficial ownership reporting requirements on many companies. The stated purposes...more

Winstead PC

A Brave New World: U.S. Implements Company UBO Reporting Regime

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Effective as of January 1, 2021, Congress enacted - over President Trump's veto - the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 (the "NDAA"). As with any U.S. defense bill, the NDAA...more

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