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Recent Changes & Developments Regarding US Department of Defense Foreign Ownership, Control or Influence Mitigation

The Defense Security Service (DSS) has recently undergone several notable staffing changes and announced procedural developments relevant to companies under foreign ownership, control, or influence (FOCI).

DSS is the executive agent for the FOCI mitigation program on behalf of the US Department of Defense (DoD) and some 30 other departments or agencies of the US Government. In accordance with the National Industrial Security Program Operating Manual (NISPOM), foreign ownership of greater than five percent must be reported to DSS (along with other FOCI factors) and generally requires FOCI mitigation to allow a US entity to hold a DoD facility security clearance and thus be eligible to be awarded and perform on classified contracts. This client alert provides a summary of recent changes at DSS that could affect companies operating under or contemplating FOCI mitigation.

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