The world is being quietly rearranged by people who write very long documents.


The title they went with Defense Federal Acquisition Regulation Supplement: Mitigating Risks Related to Foreign Ownership, Control, or Influence (DFARS Case 2021-D011) Noisy translates that to

The Pentagon finally wants to know who it’s actually paying


The Department of Defense is proposing new rules that require defense contractors to disclose their true beneficial owners. Currently, "opaque ownership" allows entities to hide behind layers of shell companies. This update forces them to reveal the actual humans who pull the strings.
before Opaque ownership allowed
after Beneficial owners disclosed
For years, the Pentagon has been writing checks to companies it didn't fully understand. Investigations have found adversaries using front companies to win US military contracts, effectively getting paid to sit inside our supply chain. These rules are a massive, overdue effort to stop US tax dollars from accidentally funding the industrial base of its rivals.
who wins The Department of Defense benefits from increased transparency and reduced risk of foreign influence.
who loses Defense contractors who previously used opaque ownership structures will bear the cost of increased disclosure and compliance.
beneficial ownership the actual person or people who ultimately own or control a company, even if it's hidden behind other companies or legal structures
foreign ownership, control, or influence (FOCI) when a foreign government or entity has the power to direct or affect the operations of a US company, especially one working on defense contracts
Our bet: a wave of "small, domestic" firms will suddenly vanish or sell off once they’re forced to list their owners. Watch for a spike in contract terminations over the next year as the Pentagon realizes just how many "patriotic" suppliers were actually controlled by foreign interests.
The thing the document buries
The rule implements 'elements of a DoD policy' in addition to specific sections of two National Defense Authorization Acts.

If you insist
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