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Foreign Ownership Disclosure Requirements Department of Defense (DOD)

Holland & Knight LLP

Podcast - Navigating the Updated SF-328 Form

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In the 22nd episode of "Are We All Clear? Facilitating Security Clearances," host Marina O'Brien is joined by Washington, D.C., International Trade attorney Andrew McAllister to help break down the Defense Counterintelligence...more

Holland & Knight LLP

DCSA Releases Updated Standard Form 328, Certificate Pertaining to Foreign Interests

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The Defense Counterintelligence and Security Agency (DCSA) published a press release on May 9, 2025, announcing an updated Standard Form 328 (SF-328), Certificate Pertaining to Foreign Interest. The updated form was approved...more

Pillsbury Winthrop Shaw Pittman LLP

847 Awaiting Takeoff: DCSA Issues Guidance on Expanded Scope of FOCI Assessments

Section 847, which will expand foreign ownership, control or influence requirements to non-classified contracts, is on track for implementation in 2026. Section 847 of the National Defense Authorization Act for FY 2020...more

Holland & Knight LLP

GSA Mandates Disclosure of Foreign Ownership/Financing of High-Security Leased Spaces

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The General Services Administration (GSA) amended the General Services Administration Acquisition Regulations (GSAR) via an interim rule (Rule) – effective June 30, 2021 – to incorporate disclosure obligations of foreign...more

Pillsbury Winthrop Shaw Pittman LLP

New GSA Regulations Governing Foreign Ownership Disclosure

GSA issues new regulations requiring certification as to foreign ownership and foreign financing of high-security leased space. Effective June 30, 2021, GSA has adopted new regulations mandating the disclosure of foreign...more

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