PSC Comments on DFARS FOCI Proposed Rule
PSC submitted comments  on DFARS Case 2021-D011, Mitigating Risks Related to Foreign Ownership, Control, or Influence, reflecting the perspective of PSC member companies that support Department of War missions across the federal services, technology, and solutions sector. PSC supports risk-based efforts to protect national security and the defense industrial base, but cautions that the proposed rule could create acquisition delays, subcontractor barriers, and implementation uncertainty without additional guidance. PSC’s comments recommend clear procedures for NISS eligibility, DCSA review timelines, prime and subcontractor responsibilities, protection of SF 328 and ownership information, and practical implementation safeguards for companies newly subject to FOCI review.