FOCI Mitigation Agreement Initialization

The Defense Counterintelligence and Security Agency (DCSA) oversees Foreign Ownership, Control or Influence (FOCI) mitigation instruments (reference NISPOM paragraph 2-303): Security Control Agreement (SCA), Special Security Agreement (SSA), Proxy Agreement (PA) and Voting Trust Agreement (VTA). Imminent Federal can develop the agreements and negotiate with DCSA to get your company approved under a FOCI Mitigation Agreement appropriate for your needs.

The difference between the Proxy Agreement and the Voting Trust Agreement is that under the Voting Trust Agreement the foreign owner transfers legal title in the company to the Trustees that are approved by DCSA.