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Stephanie L. Crawford

Counsel
Counsel
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VCard
VCard

Areas of Focus

Overview

Stephanie Crawford is a trusted counselor to a broad range of industries facing reorganizations, transactions, national security issues, and questions of supply chain management. Stephanie provides related mergers and acquisitions, counseling, litigation, international arbitration, and investigations services to clients in the aerospace and defense, communications, energy, information technology, and consumer products sectors.

Stephanie has substantial experience with both buy-side and sell-side transactions. She has led government contracts diligence for numerous private equity entities and defense contractors. She assists clients with navigating post-closing government requirements, including unique license transfers and approvals; novation and change of name regulations; and Defense Counterintelligence and Security Agency communications and foreign ownership, control, and influence (FOCI) mitigation.

Stephanie counsels clients on supply chain, sourcing, and national security regulations and requirements. Such counseling includes compliance with the Defense Production Act, including priority orders, ratings and associated regulations; the Public Readiness and Emergency Preparedness Act; and National Industrial Security Program Operating Manual (NISPOM) regulations. She is also known for her ability to solve immediate and business-threatening System for Award Management (SAM) and Defense Logistics Agency (DLA) CAGE Code problems.

Stephanie defends government contractors facing potential tort litigation with a nexus to their government contracts and facing supply chain and national security-related investigations, litigation, and arbitrations.

Stephanie's pro bono practice focuses on a broad range of veterans' issues, including disability ratings and discharge upgrades.

Career & Education

    • University of Maryland School of Law, J.D., 2016
    • Indiana University of Pennsylvania, Robert E. Cook Honors College, B.A., economics, international studies, and history, 2011
    • University of Maryland School of Law, J.D., 2016
    • Indiana University of Pennsylvania, Robert E. Cook Honors College, B.A., economics, international studies, and history, 2011

    • District of Columbia
    • Maryland
    • U.S. Court of Federal Claims
    • U.S. Court of Appeals for Veterans Claims
    • District of Columbia
    • Maryland
    • U.S. Court of Federal Claims
    • U.S. Court of Appeals for Veterans Claims

Stephanie'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

  • Leading buy-side government contractor acquisition diligence for private equity firms, including small businesses and carve-out acquisitions.
  • Supporting sell-side government contractor transactions, including complex carve-out transactions.
  • Representing a defense contractor in litigation and international arbitration facing a challenge to an offset contract relationship, including tortious interference claims.
  • Conducting due diligence or compliance reviews for defense contractors, industrial and information technology equipment and component part manufacturers, a personal transportation consumer product manufacturer, and an international automotive parts manufacturer.
  • Guiding government contractors through foreign ownership, control, or influence mitigation and facility clearance requests and reporting requirements.
  • Counseling clients on compliance with the FY 2019 National Defense Authorization Act Section 889 and subsequent regulations (including sourcing restrictions on Huawei and other covered telecommunications and video surveillance equipment and services providers).
  • Advising clients on emerging printed circuit board and microelectronics sourcing and supply chain risk management compliance requirements.

Stephanie'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 | 03.16.26

AI for Government: 7 Days for Contractor Comments on GSA Proposed Contract Clause for AI Systems

Client Alert | 12 min read | 03.13.26

AI for Government: 7 Days for Contractor Comments on GSA Proposed Contract Clause for AI Systems

Blog Post | 02.20.26

Section 5949 Proposed Rule Puts the FAR Council’s Chips on the Table

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Practices

Stephanie'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