5 Things Defense Contractors Need to Know About DoD’s Proposed Expansion of FOCI Requirements

The Department of Defense’s proposed expansion of Foreign Ownership, Control, or Influence (FOCI) requirements could significantly increase compliance obligations for many uncleared defense contractors, introducing new disclosure, reporting, and mitigation requirements tied to foreign ownership, investment, governance, financing, and business relationships.

BIS Enforcement Action Highlights Risks in De Minimis Calculations for Foreign-Made Items

A recent BIS enforcement action against Teledyne FLIR highlights the risks of misapplying the EAR’s de minimis rule in global supply chains. The case underscores the need for accurate valuation, proper classification of U.S.-origin content, and robust documentation to avoid significant export control penalties.