Defense Security Service Puts Phone Log Requirement On Hold

James D. Harris, Senior Counsel at our Holland and Knight Washington-DC office

The Defense Security Service (DSS) on Nov. 8, 2017, issued a Memorandum for Cleared Companies Operating Under Foreign Ownership, Control or Influence Mitigation Agreements Administered by the Defense Security Service. The new memorandum serves as official cancellation of the phone log requirements described in the Electronic Communications Plan (ECP) template – an important piece of DSS' foreign ownership, control, or influence (FOCI) mitigation program. DSS advised that the memorandum may be used as a reference during a FOCI company's next scheduled security vulnerability assessment.

Communication with foreign owners has been the subject of FOCI mitigation controls going back many decades. In addition to notification procedures for face-to-face visits, controls have been applied to other forms of communication such as telephone, videoconference, email and direct messaging.