# Cleared Contractors Update FOCI Disclosures

A September 29, 2026 article describes foreign ownership, control, or influence (FOCI) reporting obligations for cleared contractors. Contractors seeking a facility security clearance must file Standard Form 328 (SF 328) and update it when material changes occur to ownership, control, company name, or address. A contractor negotiating a merger, acquisition, or takeover involving a foreign interest must notify the Defense Counterintelligence and Security Agency (DCSA) at the start of negotiations and coordinate that reporting with any separate Committee on Foreign Investment in the United States (CFIUS) review.

- Cleared contractors should prepare ownership and corporate records early to support SF 328 submissions and updates when material changes occur.
- Companies entering negotiations involving a foreign interest must notify DCSA at the start of negotiations; this timing can affect transaction planning and clearance operations.
- Procurement and corporate teams should coordinate DCSA reporting with any CFIUS review, since the reporting processes are separate.

**Jurisdictions:** federal
**Industries:** Defense & Military
**Topics:** Regulatory Compliance
**Published:** September 29, 2026

### Government Entities
- Defense Counterintelligence and Security Agency (DCSA)
- Committee on Foreign Investment in the United States (CFIUS)
- Department of Defense (DoD)

### Sources
- [Required FOCI Submissions | The Shifting Landscape for Foreign Ownership, Control, or Influence, Part 3 | PilieroMazza PLLC - JDSupra](https://www.jdsupra.com/legalnews/required-foci-submissions-the-shifting-6623701) - JD Supra