DoD Proposes Rule Expanding FOCI Review and Mitigation to Unclassified Contracts
Cohen Seglias – On May 7, 2026, the Department of Defense (DoD) issued a proposed rule implementing Section 847 of the National Defense Authorization Act for Fiscal Year 2020 that would expand Foreign Ownership, Control, or Influence (FOCI) requirements to unclassified DoD contracts. Historically, FOCI disclosures and possible mitigation measures have applied only to classified contracts.
