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Proposed Rule Issued to Implement Expanded FOCI Disclosure and Risk Mitigation Requirements for Defense Contractors
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Proposed Rule Issued to Implement Expanded FOCI Disclosure and Risk Mitigation Requirements for Defense Contractors
On May 7, 2026, the Department of Defense (“DoD”) issued a proposed rule that would fundamentally expand the scope of foreign ownership, control, or influence (“FOCI”) disclosure and risk mitigation requirements for a significant number of companies that serve the national defense. The proposed rule, together with DoD Instruction (“DoDI”) 5205.87 (issued in 2024), would for the first time require many contractors and subcontractors performing un…
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