FOCI Factors
(Refer to Directive Type Memorandum (DTM) 09-019 – “Policy Guidance for Foreign Ownership, Control or Influence (FOCI)”

The following factors relating to the company, the foreign interest, and the government of the foreign interest are considered in determining if a company is under FOCI, its eligibility for a facility clearance and the protective measures required:

• Record of economic and government espionage against U.S. targets,
• Record of enforcement and/or engagement in unauthorized technology transfer,
• Type and sensitivity of the information requiring protection,
• Nature and extent of FOCI,
• Record of compliance with pertinent US laws, regulations and contracts and
• The nature of any bilateral and multilateral security and information exchange agreements that may pertain, and
• Ownership or control, in whole or in part, by a foreign government.