FOCI Mitigation refers to which entity?

• A. The legal entity that signed the FOCI Mitigation Instrument
• B. The foreign government
• C. The DoD contracting officer
• D. The end customer

Answer: (A)

FOCI Mitigation is about binding the responsible contractor to controls that reduce foreign influence on a sensitive program. The instrument that formalizes these controls is a legal agreement between the government and the entity that actually holds the contract and is subject to the FOCI safeguards. That signer—the legal entity—carries the obligations to implement and maintain the mitigations, report as required, and ensure governance aligns with the mitigation terms. The foreign government isn’t the signer, the DoD contracting officer represents the government but signs on behalf of the government rather than binding the contractor, and the end customer is not the signer. So the entity that signs the FOCI Mitigation Instrument is the contractor’s own legal entity.