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February 13, 2017

Stroock Special Bulletin

By: Chris Griner, Shannon Reaves, Erin Bruce Iacobucci

On January 11, the Information Security Oversight Office (“ISOO”) of the U.S. National Archives published a proposed rule to amend the National Industrial Security Program Directive Number 1, including provisions on Foreign Ownership, Control or Influence (FOCI) mitigation and negation.  The proposed rule will have significant, if indirect, impact on foreign-controlled government contractors.

Having advised on hundreds of FOCI negation and mitigation cases over nearly 40 years, we understand how these programs work – and don’t work.  Some elements of the proposed rule make a lot of sense.  Others require clarification.  Still others strike us as mistaken.  For all of these reasons, we decided to file comments on the Proposed Rule. 
This Stroock Special Bulletin highlights some of the key issues in the comments we have filed.  Please let us know if you would like a copy of our full comments or the proposed rule.


Erin Bruce Iacobucci

National Security Consultant

Washington, DC