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STAY ELIGIBLE YEAR AFTER YEAR 

 

foci advisory &
Mitigation services

Foreign Ownership, Control, or Influence (FOCI) can affect your eligibility for defense contracts, and it doesn’t end once an agreement is signed.

Getting it right takes real expertise and a long-term partner who works alongside your counsel and stays with you as your obligations evolve.

How ISI FOCI Services work

ISI runs FOCI as a continuous program. We advise you before the Defense Counterintelligence and Security Agency (DCSA) evaluates your structure, deliver what your mitigation requires, own every recurring obligation, and engage DCSA on your behalf.

  1. Assess

    We evaluate your ownership, control, and influence exposure and identify what DCSA is likely to focus on.

  2. Prepare

    We advise on ownership, control, and governance structure while it is still yours to change, then build your SF-328, disclosure schedules, and support documentation.

  3. Mitigate

    We engage DCSA on your behalf and negotiate the terms of your mitigation instrument, so the agreement fits how your business actually runs.

  4. Sustain

    We own your recurring obligations calendar (reporting, required meetings, role-based training, and records), and manage the change condition packages that follow any material shift in ownership or governance.

Why Contractors Work With ISI

Working with ISI feels less like hiring a vendor and more like adding a team. You have someone at the end of the phone you trust, support for your board when it matters, and a team managing the paperwork and deadlines, calling you before something becomes urgent.

ISI works alongside executive teams and boards to streamline FOCI compliance.

  • We have served 900+ defense industrial base customers over 16 years.
  • Our FOCI program is led by Cate Pearson, President, Managed Security Services, who brings more than 17 years in government consulting and operations leadership.
  • Behind her is a bench of 60+ certified FSOs, so your program is never dependent on a single practitioner’s availability or bandwidth.

Does foci apply to you?

No matter where you are in the process, even if you’ve already submitted your SF-328 and are working a tight DCSA response window, we can step in and help you move fast. The earlier you engage, the more room you have to shape your structure before DCSA evaluates it.

  • Already cleared?

    FOCI applies the moment your ownership or governance structure changes.

  • Bidding on classified work for the first time?

    FOCI applies the moment you file your SF-328.

  • Never held a clearance?

    A proposed rule would extend FOCI review to unclassified contracts and subcontracts over $5M involving CUI, at any tier.

Want the full FOCI regulatory picture?

Our Understanding FOCI: A Comprehensive Guide covers mitigation instruments, governance obligations, and the proposed expansion rule. Without an eligible FOCI status, covered contracts can’t be awarded or modified. Check your exposure in two minutes with our FOCI Exposure Tool.

Check Your FOCI Exposure

ISI FOCI Advisory & Mitigation Services

ISI supports you at every stage of the FOCI lifecycle, whether you are filing your first Standard Form 328 (SF-328) or maintaining a board-level mitigation agreement that has been in place for years.

Know where you stand before dcsa

We review your ownership, board, and governance to flag control or influence exposure before it threatens a bid or an existing contract.

FILE WITH CONFIDENCE, THE FIRST TIME

We help you complete and file an accurate, DCSA-ready SF-328, so your submission moves through review without unnecessary back and forth. For FCL packages, Facility Control catches the errors that trigger most returns before DCSA ever sees them.

Plan Now for a Better Mitigation Outcome

DCSA determines your mitigation instrument based on your company’s structure, not the other way around. We help you shape that structure before a determination is made, so it is put forward in its best supportable form. From there, we draft the implementing documents your instrument requires and advise on where to push back.

Keep Your Board and Governance Audit-Ready

If you’re under a Security Control Agreement (SCA), Special Security Agreement (SSA), Voting Trust (VT), or Proxy Agreement (PA), we support your Government Security Committee and keep the governance documentation DCSA expects to see current. We don’t place outside directors or committee members, but we can introduce you to partners who do.

Meet SBR Requirements Without Building the Expertise In-House

For companies under an Special Board Resolution (SBR), we handle what DCSA increasingly requires, so you’re not standing up that capability yourself.

Separate What Needs to Be Separated

If your mitigation requires a technically or physically separated environment to handle CUI apart from a foreign parent, we design, build, and manage it as a dedicated engagement, drawing on the same in-house team that runs our managed IT services. Most FOCI advisors can tell you this is required. We’re also the ones who can build it.

 

New to foci because you've never held a classified contract?

The expansion rule (Section 847 of the FY2020 NDAA) will apply disclosure and mitigation requirements to many unclassified contracts for the first time. We map your ownership and build your SF-328 now, so the new rule doesn’t catch you flat-footed.

 
For more on what is driving this shift, see FOCI Expansion Rule: Will the Government and Industry Be Ready by October 1?

One ISI, One Accountable Partner

Contracts go to companies the government can trust. By integrating FOCI advisory and mitigation services into our FSO & Clearance and Managed IT & Cybersecurity services, you get one accountable team that holds both the expertise and technical capability to own the trust decision.

  • CMMC / DFARS 7012
  • 32 CFR Part 117 / NISPOM
  • Section 847 / FOCI
  • Whatever Comes Next

FREQUENTLY ASKED QUESTIONS

Do we need FOCI support if we have never held a classified contract?

Possibly, and sooner than you might expect. The proposed FOCI expansion rule would extend disclosure and mitigation requirements to unclassified contracts and subcontracts over $5 million that involve Controlled Unclassified Information (CUI), at any tier. If your company bids on or holds contracts at that value, we can help you map your ownership now, before the rule takes effect.

Not sure if this applies to you? Check your exposure in under two minutes with our FOCI Exposure Tool. There’s no wrong answer.
How long does FOCI mitigation typically take to put in place?

The timeline depends heavily on the complexity of your corporate structure and the type of mitigation instrument required by the Defense Counterintelligence and Security Agency (DCSA).

If you want to talk through your specific circumstances, reach out and we can walk through what it might look like for your business.
What happens if our ownership changes after we already have a mitigation agreement in place?
FOCI compliance doesn’t end with your first mitigation agreement. We keep your compliance reporting, schedules, and disclosures current year over year, and prepare the change condition package DCSA requires anytime your ownership, leadership, or governance structure shifts.
Will ISI replace our outside counsel?

We work alongside your outside counsel, bringing hands-on DCSA experience to the operational side of your mitigation plan: completing the SF-328, preparing disclosure schedules, and building the implementing documents your instrument requires. Your attorneys stay in the room for what only they can do: privileged legal advice, governance document drafting, and formal representation.

Instead of billing by the hour for every question, you have a team tracking your deliverables and deadlines year-round, so issues get caught before they become a problem.