NISPOM Revised to Incorporate DSS and GCA Requirements
Client Alert | 1 min read | 08.08.18
On August 1, 2018, DoD published the National Industrial Security Program: Industrial Security Procedures for Government Activities (“Volume 2”), which finally replaces the 1985 Industrial Security Regulation much as the original National Industrial Security Program Operating Manual (NISPOM) had replaced the Industrial Security Manual applicable to contractors. Volume 2 prescribes security practices applicable to U.S. government activities and includes an extended discussion of facility security clearances (FCLs), including examples of documentation that sponsoring agencies can use to justify an FCL, an exception for continued FCL processing even if it cannot be completed in time to qualify the company for participation in a procurement action, and uniform criteria for identification of key management personnel for various business structures. Volume 2 also establishes detailed procedures for DSS oversight of contractor investigations of compromised information, DSS processing of limited access authorization, and DSS requirements for international security programs including foreign government and contractor access to U.S. classified information.
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Client Alert | 7 min read | 06.24.26
On June 17, 2026, the U.S. Department of Justice’s (DOJ( National Security Division (NSD) announced that it had issued a declination for Robert Bosch GmbH (Bosch) relating to potential violations of the Export Control Reform Act, 50 U.S.C. § 4819 (ECRA). Specifically, the DOJ declined to criminally prosecute Bosch’s violations of the Export Administration Regulations’ (EAR) Foreign Direct Product Rule (FDPR), which apparently resulted from two Bosch subsidiaries’ export of products and software manufactured with equipment that was the direct product of U.S. software or technology to Huawei Technologies Co., Ltd. and its “Entity List” affiliates, including Huawei Tech. Investment Co., Ltd., Hong Kong (collectively, Huawei). The same day, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a parallel civil administrative settlement with Bosch.
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