Companies facing Foreign Ownership, Control, or Influence (FOCI) requirements often have an immediate question: How much will it cost to get help?
The answer depends on the company's ownership structure, the complexity of its foreign interests, and the type of assistance required.
At Industry FSO, our FOCI consulting rate is approximately $300 per hour. This provides contractors with access to experienced industrial security professionals at a rate that is generally more affordable than engaging a specialized law firm for comparable compliance support.
For some companies, FOCI assistance may involve a relatively straightforward ownership assessment or help completing an SF-328. For others, it may involve implementing a Special Security Agreement (SSA), coordinating with DCSA, and maintaining ongoing compliance procedures.
Understanding how FOCI consulting is priced can help contractors obtain the expertise they need without paying for services they don't.
There is no standard government-established fee for FOCI consulting services.
The total cost generally reflects the scope and complexity of the work involved.
Several factors can influence pricing.
A company with one minority foreign investor may require considerably less analysis than a business owned through multiple domestic and foreign holding companies.
More complicated ownership structures can involve:
Understanding these relationships may require reviewing capitalization tables, shareholder agreements, organizational charts, and other corporate records.
FOCI requirements vary depending on why the company is being reviewed.
A contractor applying for its first Facility Clearance (FCL) may need assistance preparing its SF-328 and supporting documentation.
An existing cleared contractor undergoing an acquisition may require additional coordination with DCSA and evaluation of potential changes to its FOCI status.
Other companies may need assistance preparing for foreign ownership reviews associated with certain Department of Defense (DoD) procurements.
If DCSA determines that a company requires formal FOCI mitigation, the scope of work may increase.
Depending on the circumstances, mitigation could involve a Board Resolution, Security Control Agreement (SCA), Special Security Agreement (SSA), Proxy Agreement, or Voting Trust Agreement.
More comprehensive arrangements can require independent directors, a Government Security Committee (GSC), security plans, and additional compliance procedures.
For more information, see FOCI Mitigation Explained: How Companies Address Foreign Ownership Concerns.
Some companies need help with a specific disclosure or government request. Others require continuing support to maintain approved mitigation arrangements.
Ongoing work may include GSC coordination, security plan updates, DCSA communications, compliance reviews, and reporting of relevant corporate changes.
The duration and frequency of these activities can significantly affect the overall cost.
FOCI consultants may offer different pricing arrangements depending on the nature of the engagement.
Hourly billing may be appropriate for narrowly defined questions or situations where the required work is difficult to estimate.
Industry FSO's hourly FOCI consulting rate is approximately $300.
This can be a practical option for contractors needing help with an SF-328, reviewing foreign ownership documentation, or responding to a specific DCSA inquiry.
For perspective, a project requiring five hours of consulting support would cost approximately $1,500 at that rate, while a ten-hour engagement would cost approximately $3,000.
These are illustrative calculations rather than estimates for any particular FOCI matter. The actual effort depends on the company's circumstances.
A fixed-fee arrangement may be suitable when the work has a clearly defined scope.
Examples include:
Industry FSO can evaluate the anticipated level of effort and discuss project-based pricing when appropriate.
A defined scope helps contractors understand the expected cost before work begins.
Companies with continuing FOCI responsibilities may benefit from a recurring consulting arrangement.
Monthly support can be appropriate for contractors operating under an SSA, SCA, or another mitigation agreement that requires ongoing administration.
A retainer may cover recurring compliance activities, coordination with company leadership, DCSA communications, and maintenance of required security procedures.
The appropriate scope depends on the company's mitigation requirements and internal security capabilities.
The SF-328, Certificate Pertaining to Foreign Interests, is a common starting point for FOCI consulting engagements.
Although the form contains nine substantive questions, completing it may require substantial supporting documentation.
A small business with a few individual owners and limited foreign relationships may be able to complete much of the form internally.
A company with multiple foreign investors, complex voting rights, or several ownership tiers may require additional assistance.
FOCI consultants can help:
At Industry FSO's approximate rate of $300 per hour, contractors can obtain targeted assistance without necessarily committing to a large legal engagement or an ongoing consulting contract.
The total cost depends on the amount of research, documentation, and review required.
For a practical walkthrough, see How to Complete the SF-328: A Step-by-Step Guide.
FOCI mitigation is often more involved than preparing an initial disclosure.
For example, a company operating under an SSA may need to establish and maintain:
The initial implementation effort may be substantial, particularly when the company must establish new governance and security procedures.
After implementation, ongoing responsibilities may be more predictable.
For this reason, some contractors separate mitigation support into two phases:
Initial implementation: A defined project covering the preparation and establishment of required security procedures.
Ongoing compliance: A recurring arrangement supporting the administration and maintenance of the approved mitigation requirements.
This approach can help companies distinguish one-time implementation costs from continuing operational expenses.
In many circumstances, yes.
Law firms specializing in government contracts, national security, and foreign investment matters may charge substantially higher hourly rates than industrial security consultants.
Those rates can be justified when a matter involves legal interpretation, corporate transactions, or negotiation of binding agreements.
However, not every FOCI-related task requires an attorney.
For example, preparing supporting documentation for an SF-328, maintaining a TCP, or coordinating routine GSC activities may be better suited to an experienced industrial security professional.
At approximately $300 per hour, Industry FSO offers a cost-conscious alternative for this type of work.
The distinction is especially relevant when a company needs ongoing assistance. Using a law firm to perform routine security administration can become expensive over time.
That does not mean contractors should avoid attorneys.
Legal counsel may be necessary when a company is negotiating a complex mitigation agreement, restructuring ownership rights, or addressing significant legal questions.
In some situations, the most efficient arrangement involves both professionals: an attorney handles the legal matters while a FOCI consultant manages the industrial security and compliance work.
Read FOCI Consultant vs. FOCI Attorney: Which Do You Need? for a detailed comparison.
Yes. One of the most effective ways to control consulting costs is to prepare accurate corporate documentation before engaging outside assistance.
Companies can often reduce unnecessary work by organizing:
It is also helpful to identify the specific assistance needed.
A company that only requires help completing an SF-328 may not need an ongoing FOCI compliance engagement.
Conversely, a company operating under a comprehensive mitigation agreement may benefit from recurring support rather than repeatedly engaging consultants for individual tasks.
Clearly defining the scope can help prevent unexpected costs.
Section 847 of the FY2020 National Defense Authorization Act established a framework for reviewing foreign ownership risks among certain DoD contractors and subcontractors, including companies performing unclassified work.
The May 2026 proposed DFARS rule describes additional beneficial ownership and FOCI disclosure requirements for certain covered DoD contracts exceeding $5 million.
If implemented as proposed, these requirements could create new compliance responsibilities for companies that have never needed an FCL.
Some contractors may need assistance reviewing ownership structures, preparing an SF-328, or responding to government questions.
Others may be able to handle the disclosures internally.
The level of outside assistance should depend on the complexity of the company's circumstances and the requirements applicable to its contracts.
For more information, see NDAA Section 847 Explained: What Government Contractors Need to Know.
Before engaging a consultant, contractors should understand the proposed scope of work and how fees will be structured.
Useful questions include:
A clear scope of work is often more useful than comparing hourly rates alone.
FOCI consulting costs depend on the company's circumstances, but getting an initial estimate should be straightforward.
Industry FSO provides specialized FOCI consulting at approximately $300 per hour, with project-based and recurring arrangements available depending on the scope of work.
Our services include SF-328 preparation, foreign ownership assessments, DCSA coordination, mitigation implementation, and ongoing FOCI compliance.
We focus on providing practical industrial security expertise without requiring contractors to engage a law firm for work that does not demand legal representation.
Learn more about our FOCI consulting services or contact Industry FSO to discuss your requirements and obtain an estimate.