Foreign Ownership, Control, or Influence (FOCI) action plan
flowchart
When an organization wants to determine whether it is under Foreign Ownership, Control, or
Influence (FOCI) and which (if any) FOCI mitigation action plan would likely be required of it to
obtain a facility security clearance (FCL), it may use our flowchart. Since this flowchart cannot
encompass all the factors that the Defense Security Service will likely examine (e.g. record of
compliance with U.S. laws, being a target of foreign espionage), it is possible that the Defense Security
Service could conclude that an organization is under FOCI to a greater degree than this flowchart
would indicate. However, this flowchart may be used by an organization to assess most of the factors
involved in FOCI. By doing so, an organization can determine which (if any) FOCI mitigation action
plan/agreement would most likely be required of it by the Defense Security Service.
Though we can consult on a client's Foreign Ownership, Control, or Influence (FOCI) and FCL issues,
the flowchart we've prepared can be a quick, more cost-efficient way for organizations to assess their
own FOCI. By doing so, an organization can determine whether the FOCI mitigation action plan that
would likely be required of it would be acceptable. If it becomes clear that the FOCI action plan that the
Defense Security Service would likely require would be unacceptable to the organization, then the
organization can factor that into its business planning.
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flowchart.
