by C. Peter Dungan, Lyle F. Hedgecock on May 26, 2026
A new proposed Defense Federal Acquisition Regulation Supplement (DFARS) FARS Rule, DFARS Case 2021-D011 would:
Significantly expand the scope of foreign ownership, control or influence (FOCI) reviews that would have profound implications for any contractor doing business (or seeking to do business) with the Department of Defense (DoD) under a contract greater than $5 million, including, potentially, commercial contractors; and
Fundamentally change the role of the Defense Counterintelligence and Security Agency (DCSA) in connection with FOCI reviews by giving DCSA a central,
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