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Are We All Clear? Facilitating Security ClearancesAuthor: Holland & Knight
Are We All Clear? Facilitating Security Clearances is a podcast series brought to you by Holland & Knight's Facility Security Clearance team. Over the course of this series, our attorneys will help take the mystery out of obtaining and maintaining security clearances for government contractors throughout the business life cycle. So are you ready to dive in and find out? Are we all clear? Language: en Genres: Education, Government Contact email: Get it Feed URL: Get it iTunes ID: Get it |
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Navigating the Updated SF-328 Form
Episode 22
Tuesday, 8 July, 2025
In the 22nd episode of "Are We All Clear? Facilitating Security Clearances," host Marina O'Brien is joined by Washington, D.C., International Trade attorney Andrew McAllister to help break down the Defense Counterintelligence and Security Agency's (DCSA) changes to the Standard Form 328 (SF-328), also known as the Certificate Pertaining to Foreign Interest. Mr. McAllister explains that the main goals of the updates are to reduce processing timelines by placing an emphasis on more thorough submissions as well as align with the expanded efforts to assess and mitigate foreign ownership, control or influence (FOCI) following the implementation of Section 847 of the National Defense Authorization Act (NDAA). One of the most significant changes to the document is in Question B, where the threshold of foreign revenue has been lowered from 30 percent to 15 percent, which will qualify a much higher number of companies. Importantly, Mr. McAllister clarifies that listeners who have previously submitted documents should not be alarmed — if you submitted or signed an SF-328 form prior to May 12, 2025, the old form is acceptable — but moving forward, any new actions must be conducted using the new form.
