Defense contractors, companies handling classified information, and any organization subject to DCSA (Defense Counterintelligence and Security Agency) FOCI evaluation — including companies seeking or maintaining facility security clearances (FCLs).
FOCI exists to prevent foreign governments, entities, or individuals from gaining unauthorized access to classified information or undue influence over cleared contractors. Companies must disclose foreign ownership, control, or influence and may be required to implement mitigation agreements (SSAs, SCAs, proxy agreements, VTAs). The standard is broad — "control" and "influence" extend beyond majority ownership to board seats, financial dependencies, technology transfer agreements, and more.
Map the full corporate ownership structure — including subsidiaries, affiliates, joint ventures, and financial relationships — to identify foreign connections that may not be obvious from direct ownership alone.
Identify foreign government ownership, control, or influence indicators across entities in non-English jurisdictions where corporate filings are in Mandarin, Arabic, Russian, or other languages.
Provide evidence and documentation to support FOCI mitigation submissions and ongoing monitoring for changes in ownership or influence.
Enable independent verification of entity relationships for contracting and compliance officers.
The National Defense Authorization Act includes provisions that restrict dealings with Chinese military companies (Section 1260H) and prohibit procurement of telecommunications equipment from covered entities (Section 889).
Controls the export and re-export of dual-use and defense-related items under EAR and ITAR, requiring end-user screening, item classification, and documentation to prevent controlled goods from reaching prohibited destinations.
Prohibits transactions with designated individuals, entities, and jurisdictions across OFAC, EU, UK, and UN sanctions lists — requiring continuous screening of counterparties, suppliers, and beneficial owners.