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April 16, 2020

Contract Management Magazine

By: Chris Griner, Gregory Jaeger, Christopher R. Brewster, Erin Bruce Iacobucci

The new decade is certain to bring new regulations governing companies doing business with the U.S. government—particularly those companies engaging in work with national security implications. Among the several changes on the horizon will be expanded reviews of foreign investments and alliances, new disclosure requirements (and potential regulations) for contractors holding facility security clearances, and rigorous export controls compliance.

In this article, Chris Griner, Greg Jaeger, Chris Brewster and Erin Bruce Iacobucci focus on an area of government review that previously was of concern principally to companies performing contracts on classified programs for the U.S. Department of Defense (DOD): “foreign ownership, control, or influence” (FOCI). As recent legislation has made clear, FOCI is no longer a subject that is limited to the classified contracting community. Going forward, companies performing on commercial contracts for DOD will need to familiarize themselves with the concept of FOCI, how it is defined, and, importantly, what FOCI mitigation could look like.

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Gregory Jaeger

Special Counsel

Washington, DC


Erin Bruce Iacobucci

National Security Consultant

Washington, DC