On May 7, 2026, the Department of Defense (“DoD”) issued a proposed rule that would fundamentally expand the scope of foreign ownership, control, or influence (“FOCI”) disclosure and risk mitigation requirements for a significant number of companies that serve the national defense. The proposed rule, together with DoD Instruction (“DoDI”) 5205.87 (issued in 2024), would for the first time require many contractors and subcontractors performing unclassified work to disclose their beneficial ownership and FOCI status to the Defense Counterintelligence and Security Agency (“DCSA”), register in the National Industrial Security System (“NISS”), and—as necessary—implement and maintain FOCI risk mitigation measures.

Click here to read the full alert.