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Global Trade & Sanctions LawPublished on:
ISOO Guidance on Facility Security Clearances for Joint Ventures
On October 5, 2023, the National Archives Information Security Oversight Office (ISOO) released a joint notice to provide guidance on facility clearances for joint ventures (JVs) in the National Industrial Security Program (NISP). This guidance addresses the interaction of NISP requirements and an October 16, 2020 Small Business Administration (SBA) rule on JVs and also aims to clarify confusion arising from a Government Accountability Office (GAO) decision interpreting the SBA 2020 rule. The ISOO joint notice concludes that the SBA rule on JVs does not materially alter the requirements under the NISP concerning which entities are required to obtain facility security clearances (FCL) and a NISP Cognizant Security Agency (CSA) (such as the Defense Counterintelligence and Security Agency) will continue to make these determinations.
