Roundtable Discussion

How DCSA’s FOCI Scope is Expanding Beyond Foreign Owned Companies and Impacting Supply Chain

September 30, 2024 1:45pm

Jill M. McClune
US General Counsel
Avon Protection/Team Wendy

Richard Ray
FSO / TCO / ITPSO
Eutelsat America Corp.

Proposed changes to the National Defense Authorization Act (NDAA), Section 847 directs the U.S. Department of Defense to reduce reliance on services, supplies, or materials obtained from certain geographic areas, which may be controlled by adversarial countries. The change would also direct DoD to mitigate the risks to national security and the defense supply chain related to such a reliance. Announced in 2022, DoD is due to issue a report to congressional defense committees this year and is currently seeking input.

  • Determining which FOCI companies, non-FOCI companies, public trust contracts and third-party contractors are subject to increased scrutiny
  • Anticipating DCSA’s expectations and guidance
  • Analyzing the need for an Electronic Communication Monitoring Plan, or a Quality Management Plan, or an export license
  • Monitoring international suppliers and evaluating supply chain security and resiliency