---
title: FOCI Consulting Experts | SF-328 & Section 847 Support | Industry FSO
description: Expert FOCI consulting, SF-328 assistance, and Section 847 compliance support for DoD contractors. Navigate FOCI requirements without expensive law firm rates.
image: https://industryfso.com/hubfs/Website/Pages/Services/FSO%20featured%20image.webp
---
[](https://industryfso.com?hsLang=en)
- [About us](https://industryfso.com/about-us?hsLang=en)
- Services
- [All Services](https://industryfso.com/services?hsLang=en)
- [FSO Services](https://industryfso.com/fso-services?hsLang=en)
- [FCL Setup & Maintenance](https://industryfso.com/fcl-formation?hsLang=en)
- [DCSA Review Prep](https://industryfso.com/dcsa-security-reviews?hsLang=en)
- [Foreign Ownership (FOCI)](https://industryfso.com/foci-consulting)
- [Insights](https://industryfso.com/insights?hsLang=en)
[Speak to an Expert](https://industryfso.com/contact?hsLang=en)
- [About us](https://industryfso.com/about-us?hsLang=en)
- Services
- [All Services](https://industryfso.com/services?hsLang=en)
- [FSO Services](https://industryfso.com/fso-services?hsLang=en)
- [FCL Setup & Maintenance](https://industryfso.com/fcl-formation?hsLang=en)
- [DCSA Review Prep](https://industryfso.com/dcsa-security-reviews?hsLang=en)
- [Foreign Ownership (FOCI)](https://industryfso.com/foci-consulting)
- [Insights](https://industryfso.com/insights?hsLang=en)
[Speak to an Expert](https://industryfso.com/contact?hsLang=en)
FOCI Expansion | SF-328 | FY20 NDAA Section 847
# FOCI Consulting for Government Contractors
Navigate foreign ownership disclosures, FOCI assessments, and mitigation requirements with experienced industrial security professionals. Industry FSO provides practical consulting support for government contractors, without the expense of traditional law firm engagements.
[Speak With a FOCI Specialist](https://industryfso.com/contact?hsLang=en)
A Practical Alternative
# Not Every FOCI Issue Requires a Law Firm
Foreign ownership and control concerns often involve regulatory disclosures, security procedures, and government coordination rather than legal representation.
Industry FSO provides specialized assistance with these operational requirements, helping contractors address FOCI matters efficiently and cost-effectively. When legal counsel is necessary, we can work alongside your attorney.
- Specialized industrial security and FOCI experience
- Direct access to experienced consultants
- Practical, cost-conscious compliance support
- Assistance from assessment through mitigation
Our goal is straightforward: provide the specialized FOCI support your business needs, without unnecessary costs or complexity. Whether your situation calls for a straightforward disclosure review or a more involved mitigation strategy, we'll help you determine the right approach.
Foreign Interests Disclosure
## The SF-328 Doesn't Have To Be A Mystery
The SF-328 is used to disclose foreign interests and assess potential FOCI concerns. We help contractors understand the questions, review ownership information, and prepare accurate disclosures and supporting documentation.
[Get SF-328 Assistance](https://industryfso.com/contact?hsLang=en)
Foreign Ownership Made Simple
# FOCI Consulting Services
From initial ownership reviews to ongoing mitigation, our services address the practical requirements of FOCI compliance.
### FOCI Assessments & Compliance
Evaluate foreign ownership, investment, governance, and control structures to identify potential risks and disclosure obligations.
### SF-328 Preparation & Review
Prepare, review, and update SF-328 disclosures, including supporting ownership information and documentation.
### FY20 NDAA Section 847 Compliance
Assess how proposed Section 847 requirements may affect covered DoD contracts, including beneficial ownership disclosures and pre-award eligibility reviews.
### FOCI Mitigation & DCSA Support
Develop and implement mitigation measures, coordinate with DCSA and applicable government authorities, and maintain ongoing compliance.
Section 847 & Federal Procurement
# FOCI Reviews Are No Longer Just About Classified Contracts
FOCI requirements have traditionally been associated with companies pursuing or maintaining Facility Clearances. That is changing.
Under the proposed Section 847 implementing rule, certain DoD contractors and subcontractors pursuing contracts exceeding $5 million would face foreign ownership disclosure and eligibility requirements, including for covered unclassified work.
These proposed requirements could introduce FOCI reviews into the procurement process for companies that have never held an FCL.
Ownership & Control
## Don't Let Foreign Ownership Be a Roadblock
Foreign investment, corporate restructuring, and international business relationships can create FOCI considerations. Understanding how these interests affect your contracting obligations is the first step toward addressing them.
Our team provides assistance with:
- Foreign ownership and control assessments
- Beneficial ownership disclosures
- SF-328 preparation and updates
- Foreign investor and acquisition reviews
- FOCI mitigation planning
- KMP clearance and exclusion requirements
- FCL eligibility and sponsorship support
- Government reporting and coordination
- Ongoing FOCI compliance monitoring
Meet The Team
## Experience That Goes Beyond the Paperwork
Our team combines corporate security leadership, federal industrial security experience, and specialized knowledge of foreign ownership and FOCI matters.
Sarah Phillips - President
12+ years as an in-house corporate FSO.
David Waiter - FSO
Experienced industrial security professional specializing in FCLs, FOCI, and DCSA requirements
Sarah Beauregard - FSO, FCL Expert
16+ years experience working in the federal government in the field of industrial security.
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Rodney Shull - Security Specialist
Decades of experience in industrial security and cybersecurity.
Chad Nix - FOCI Expert
Over 25 years experience in corporate security, with focus on FOCI and foreign ownership.
Official Guidance and Resources
### Understanding FOCI Requirements
Foreign ownership and investment can introduce additional compliance considerations for government contractors, particularly when pursuing classified work or contracts subject to foreign ownership reviews. Understanding how FOCI is evaluated, what information must be disclosed, and when mitigation may be required can help organizations prepare for these requirements.
The resources below include official guidance from the [Defense Counterintelligence and Security Agency (DCSA)](https://www.dcsa.mil/FOCI/When/), the latest [SF-328 form and instructions](https://www.gsa.gov/reference/forms/certificate-pertaining-to-foreign-interests), and information on [NDAA Section 847](https://www.dcsa.mil/Section847/), which extends FOCI scrutiny to certain DoD contracts and subcontracts exceeding $5 million. Contractors navigating more complex ownership structures can also review DCSA's guidance on [FOCI mitigation agreements](https://www.dcsa.mil/Industrial-Security/Entity-Vetting-Facility-Clearances-FOCI/Foreign-Ownership-Control-or-Influence/Mitigation-Agreements/) and the [mitigation process](https://www.dcsa.mil/mc/isd/foci/cimp/).
### Foreign Ownership, Control or Influence
DCSA guidance on identifying foreign influence, evaluating FOCI concerns, and implementing mitigation measures.
[View Resource](https://www.dcsa.mil/FOCI/When/)
### Certificate Pertaining to Foreign Interests
Access the official SF-328 form used to disclose foreign ownership, control, and other foreign interests.
[View Resource](https://www.gsa.gov/reference/forms/certificate-pertaining-to-foreign-interests)
### NDAA Section 847 Resources
DCSA information on Section 847, covered contracts, beneficial ownership disclosures, and pre-award FOCI reviews.
[View Resource](https://www.dcsa.mil/Section847/)
### 32 CFR § 117.11 — FOCI
Review the NISPOM provisions governing FOCI determinations, reporting obligations, and mitigation requirements for cleared contractors.
[View Resource](https://www.ecfr.gov/current/title-32/subtitle-A/chapter-I/subchapter-D/part-117/section-117.11)
Get in Touch
## Have a FOCI Question? Let's Talk.
Whether you're preparing an SF-328, evaluating foreign ownership concerns, or navigating new contracting requirements, our team can help you understand your obligations and identify the next steps.
## Resources
Guides, checklists, and reference materials to help defense contractors navigate FCL requirements, FSO responsibilities, and DCSA expectations.
[Insights](https://industryfso.com/insights?hsLang=en)
#### [ April 17 2026 Facility Clearances (FCLs) for Defense Startups For many defense startups, obtaining a Facility Clearance (FCL) feels like a chicken-and-egg problem. You need an FCL to work on classified contracts—but you can't get one without being sponsored for classified work. It's an even taller hurdle for startups with complex ownership structures or intern... FCLs](https://industryfso.com/foci-consulting)
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**Services**
- [Overview](https://industryfso.com/services?hsLang=en)
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- [DCSA Review Prep](https://industryfso.com/dcsa-security-reviews?hsLang=en)
- [FOCI](https://industryfso.com/foci-consulting)
**About**
- [About Us](https://industryfso.com/about-us?hsLang=en)
- [Insights](https://industryfso.com/insights?hsLang=en)
**Contact**
- [Contact Us](https://industryfso.com/contact?hsLang=en)
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---
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