The New Reporting Requirements for Contractors in Unclassified Environments: Under the Expanded Scope of SF-328

International Trade attorney Andrew McAllister will speak at the American Conference Institute's (ACI) 9th National Forum on FOCI, a Holland & Knight-sponsored program focused on compliance and reporting obligations affecting government contractors. During his session, Mr. McAllister will address recent updates to the SF-328 form regarding foreign ownership, control or influence (FOCI). He will explain how its expanded scope now applies to certain contractors operating in unclassified environments, providing the Defense Counterintelligence and Security Agency (DCSA) with deeper visibility into foreign relationships. He will discuss the challenges associated with navigating expanded ownership reporting requirements, share best practices for completing the revised form and clarify how much information must be provided beyond standard legal and financial disclosures. The presentation will additionally outline when to use the updated SF-328 after initial submissions, including during FOCI reviews, ownership changes and renewals. Beyond logistical and submission questions, speakers will highlight key considerations for facility security officers (FSOs) to ensure compliance with the evolving reporting obligations, when attendees will have the opportunity to participate in mock form exercises and interactive discussions to reinforce practical application of these new requirements.