DoD Seeks “Unprecedented Level of Visibility” into the Supply Chain Under Newly Proposed Regulations

Short summary

The DoD proposed new regulations requiring any contractor with DoD contracts exceeding $5M to disclose foreign ownership and control status in the NISS system. Contractors must submit SF-328 forms before award, maintain eligible status, report ownership changes within 3 business days, and implement DCSA-mandated mitigation strategies within 90 days. The rule applies to all subcontractors with contracts exceeding $5M and may extend to commercial tech contracts.

• •DoD requires all $5M+ contractors to disclose foreign ownership/control status in NISS
• •Three-day reporting window for ownership changes; 90-day mitigation window for FOCI risks
• •Rule applies to subcontractors and may extend to commercial contracts with sensitive data

Generated with AI, which can make mistakes.