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Allison Skager

Counsel
Counsel
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Areas of Focus

Overview

Allison Skager advises on legal issues related to complex transactions involving federal, state, and local government contractors, including national security reviews. Allison provides practical guidance tailored to companies’ unique priorities—her clients range from startups pursuing their first federal award to mature contractors and financial sponsors tackling high stakes structuring and compliance questions.

Career & Education

    • University of Southern California, Gould School of Law, J.D.
    • University of California, Los Angeles, B.A.
    • University of Southern California, Gould School of Law, J.D.
    • University of California, Los Angeles, B.A.

    • California
    • California

Allison's Insights

Client Alert | 2 min read | 05.14.26

Proposed DFARS Rule Could Require Disclosures and Mitigation Related to Foreign Ownership, Control, and Influence (FOCI) on Certain Unclassified Contracts

On May 7, 2026, the Department of War issued the long-awaited Proposed Rule to implement Section 847 of the FY 2020 National Defense Authorization Act (NDAA) regarding Foreign Ownership, Control or Influence (FOCI) requirements for contractors. The proposed rule would expand the applicability of FOCI reviews, requiring contractors and subcontractors on unclassified “covered contracts” — defense contracts and subcontracts valued in excess of $5 million that are not for commercial products and services — to submit FOCI disclosures to the Defense Counterintelligence and Security Agency (DCSA) for FOCI risk assessment (and as applicable, mitigation) as part of contract award. This would effectively require DCSA assessment and adjudication of FOCI considerations prior to contract award. Thus, both cleared and uncleared defense contractors would be subject to the rigorous DCSA disclosure requirements, scrutiny, and FOCI mitigation. Crowell discussed the Section 847 requirements in a prior alert....

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Representative Matters

Government Contracts Transactions, M&A, Diligence

  • M&A; Investments. Support for private equity, venture capital, and strategic clients acquiring/investing in U.S. government contractors, including due diligence and risk analysis, structuring advice, transaction document negotiation, post-investment compliance counseling, and sale support.
  • National Security Reviews. Assist clients undergoing reviews conducted by the Committee on Foreign Investment in the United States (CFIUS) and the Defense Counterintelligence Security Agency (DCSA).
  • Post-Close Support. Administrative packages including novation and change-of-name/conversion packages; customer notices; facility security clearance packages; System for Award Management (SAM) registration and supplier portal updates; integration support.
  • Contract Negotiation. Contract drafting and negotiation for agreements with higher and lower-tier partners.

Government Contracts Compliance

  • Compliance Programs and Training. Review, development, and enhancement of government contracts compliance policies and procedures. Training for companies on the unique risks and requirements that go hand-in-hand with selling to the U.S. government.
  • Flow-Downs. Federal Acquisition Regulation (FAR) & FAR supplement flowdown analysis and counseling for prime contractors, subcontractors, and suppliers.
  • System for Award Management. Issue resolution and compliance counseling in connection with SAM.gov registrations and CAGE codes.

State and Local Practice

  • Contract Negotiation. Contract negotiation with state and local agencies and counseling in connection with state/locality-specific contractual compliance requirements.
  • Ethics & Compliance. Advice on ethical restrictions and requirements under state and local government procurement regulations, including related to gifts/gratuities, discounts, lobbying, and hiring former government employees (e.g., “revolving door”).
  • Regulatory Surveys and Playbooks. Analysis of state procurement regulations related to sole source procurement and restrictions on contract terms such as indemnification and limitation of liability.

Allison's Insights

Client Alert | 2 min read | 05.14.26

Proposed DFARS Rule Could Require Disclosures and Mitigation Related to Foreign Ownership, Control, and Influence (FOCI) on Certain Unclassified Contracts

On May 7, 2026, the Department of War issued the long-awaited Proposed Rule to implement Section 847 of the FY 2020 National Defense Authorization Act (NDAA) regarding Foreign Ownership, Control or Influence (FOCI) requirements for contractors. The proposed rule would expand the applicability of FOCI reviews, requiring contractors and subcontractors on unclassified “covered contracts” — defense contracts and subcontracts valued in excess of $5 million that are not for commercial products and services — to submit FOCI disclosures to the Defense Counterintelligence and Security Agency (DCSA) for FOCI risk assessment (and as applicable, mitigation) as part of contract award. This would effectively require DCSA assessment and adjudication of FOCI considerations prior to contract award. Thus, both cleared and uncleared defense contractors would be subject to the rigorous DCSA disclosure requirements, scrutiny, and FOCI mitigation. Crowell discussed the Section 847 requirements in a prior alert....

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Insights

Client Alert | 2 min read | 05.14.26

Proposed DFARS Rule Could Require Disclosures and Mitigation Related to Foreign Ownership, Control, and Influence (FOCI) on Certain Unclassified Contracts

Blog Post | 04.22.26

SBIR/STTR Programs Reauthorized After Six-Month Lapse

Client Alert | 4 min read | 04.14.26

SBIR/STTR Programs Reauthorized After Six-Month Lapse

Client Alert | 2 min read | 02.12.26

Treasury Seeks Public Input on CFIUS Known Investor Program and Streamlining of Foreign Investment Reviews

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Practices

Allison's Insights

Client Alert | 2 min read | 05.14.26

Proposed DFARS Rule Could Require Disclosures and Mitigation Related to Foreign Ownership, Control, and Influence (FOCI) on Certain Unclassified Contracts

On May 7, 2026, the Department of War issued the long-awaited Proposed Rule to implement Section 847 of the FY 2020 National Defense Authorization Act (NDAA) regarding Foreign Ownership, Control or Influence (FOCI) requirements for contractors. The proposed rule would expand the applicability of FOCI reviews, requiring contractors and subcontractors on unclassified “covered contracts” — defense contracts and subcontracts valued in excess of $5 million that are not for commercial products and services — to submit FOCI disclosures to the Defense Counterintelligence and Security Agency (DCSA) for FOCI risk assessment (and as applicable, mitigation) as part of contract award. This would effectively require DCSA assessment and adjudication of FOCI considerations prior to contract award. Thus, both cleared and uncleared defense contractors would be subject to the rigorous DCSA disclosure requirements, scrutiny, and FOCI mitigation. Crowell discussed the Section 847 requirements in a prior alert....

View All Insights