ARTICLE · 26 JUNE 2025

DCSA Releases Updated Standard Form 328, Certificate Pertaining To Foreign Interests

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The Defense Counterintelligence and Security Agency (DCSA) released an updated Standard Form 328 (SF-328), which went into effect on May 12, 2025.

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Antonia Tzinova

Robert Friedman

Andrew McAllister

Marina Veljanovska O'Brien

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Highlights

The Defense Counterintelligence and Security Agency (DCSA) released an updated Standard Form 328 (SF-328), which went into effect on May 12, 2025. The new SF-328 includes several changes to questions, comprehensive instructions reflecting more detailed disclosure requirements and a new Statement of Full Disclosure of Foreign Affiliations.
The National Industrial Security System (NISS) has already deployed the updated SF-328, and any facility security clearance applications or changed condition packages initiated or submitted on or after May 12, 2025, will be required to use the updated form.
Packages submitted and initiated in NISS prior to May 12, 2025, will not be returned to the contractor for an updated SF-328. Further, contractors are not expected to submit a new SF-328 solely because the form has been updated and will need to submit a new SF-328 only in certain circumstances, as detailed in this Holland & Knight alert.

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