FOCI

The Department of Defense proposed DFARS amendments covering foreign ownership, control, or influence (FOCI) disclosures and reviews for covered contracts and subcontracts generally valued above $5 million, including unclassified work. The proposal is not final; contractors can use the time before finalization to organize ownership records and assess subcontractor exposure.

The Defense Counterintelligence and Security Agency’s FY27 forecast identifies a $400 million–$500 million recompete for entity vetting support, with solicitation anticipated in Q1 FY27 and award in Q2 FY27. The forecast is planning information, not an active solicitation; key acquisition decisions—including competition method, set-aside, vehicle, and contract length—remain open.

The proposed EU Cloud and AI Development Act would create four cloud-sovereignty assurance levels for public-sector procurement, with potential requirements for data location, foreign access, and service continuity. Contractors serving European and U.S. markets should assess the proposal separately from U.S. FOCI and FedRAMP obligations; the analysis also notes proposed FOCI-related provisions for certain unclassified Department of War work above $5 million.

The Department of War (DoW) is seeking to expand Foreign Ownership, Control, or Influence (FOCI) disclosure obligations to unclassified contracts over $5 million. Concurrent congressional reforms could reduce this threshold to $500,000, increasing compliance pressures for defense contractors and enhancing government oversight of foreign influence risks.

The Department of War is proposing changes to FOCI disclosure requirements, now including unclassified contracts over $5 million. This development aims to mitigate foreign influence across the defense sector, particularly impacting smaller businesses and requiring updated compliance processes for stakeholders.