DoD Proposed Rule Would Extend FOCI Requirements to Unclassified Contracts Over $5 Million

Illustration of dotted lines connecting foreign ownership points on a globe to a shielded U.S. government building under a magnifying glass, representing foreign ownership, control, or influence (FOCI) review of defense contractors.

DoD’s newly proposed rule would extend FOCI disclosure and mitigation requirements to unclassified contracts over $5 million — sweeping in nearly 40,000 contractors and subcontractors, most of whom have never dealt with DCSA. Learn what the rule requires, who’s covered, and the steps your company should take before the July 6 comment deadline.

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Which Rules Survive the FAR Rewrite (FAR 2.0)?

A group of lawyers wearing suits collaborate on a large table in a well-lit office. Computers are open on their desks, and stacks of law books line the walls. They appear to be working intently on a legal project.

On April 15, 2025, President Trump issued Executive Order (“EO”) 14275 titled Restoring Common Sense to Federal Procurement (“FAR EO”), confirming rumors throughout early April that a rewrite of the Federal Acquisition Regulation (“FAR”) was under way. In an earlier article, we wrote about seismic changes in policy and reductions in federal contract and grant…

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Trump’s First Month: What is Taking Shape in Government Contracts?

President Trump’s second term has been defined by significant policy shifts and a realignment of federal spending, which have had knock-on effects for the Government Contracts community. This article summarizes key executive orders (“EOs”) from the Trump Administration that contractors should consider when reviewing current contracts and when bidding for future procurements. We also envision…

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