Which term describes the instruments and agreements put in place to reduce the effect of FOCI on a company's management decisions?

• A. FOCI Action Plan
• B. Foreign National
• C. Foreign Investment
• D. Foreign Government Information

Answer: (A)

When a company falls under FOCI, the goal is to put formal controls in place that reduce foreign influence over how the company is run. The instruments and agreements used to achieve that are collectively known as the FOCI Action Plan. This plan lays out concrete governance and oversight measures—like independent or US-based management oversight, restricted access to sensitive information, and specific contractual safeguards—that ensure key management decisions aren’t unduly swayed by foreign interests and remain aligned with security requirements. The other terms describe people or types of information, not the set of mitigation tools: a foreign national is an individual, foreign investment is money from abroad, and foreign government information refers to sensitive data.