- Industrial Security
- Field Operations
- Foreign Ownership, Control or Influence (FOCI)
- - FOCI News and Updates
- - FOCI Mitigation Instruments
- - In-Process Companies
- - Foreign Acquisitions
- - Required Documentation
- - FOCI Action Plan
- - Implementation Procedures
- - National Interest Determinations
- - ODs/PHs/VTs
- - Facility Security Officers
- - DSS FOCI Conferences
- - FOCI FAQs
- - FOCI Contacts
- International Division
- Policy
Electronic Communications Plan (ECP)
An Electronic Communications Plan (ECP) is required for Security Control Agreements, Special Security Agreements, Proxy Agreements, and Voting Trusts. Within the ECP the Government Security Committee (GSC) establishes written policies and procedures assuring electronic communications between the FOCI Company and its subsidiaries and the Affiliates do not disclose classified information or export controlled information without proper authorization. The ECP also ensures that the Affiliates cannot exert influence or control over the FOCI Company's business or management in a manner that could adversely affect the performance of classified contracts.
A completed ECP consistent with the DSS Template ECP must be submitted to DSS within 45 days of the execution of the mitigation agreement. Failure to submit this document within the requisite 45 days may negatively impact a FOCI company's Facility Security Clearance (FCL).
DSS released an updated ECP template for use by facilities under foreign ownership, control or influence (FOCI) mitigation. DSS has updated the ECP Template based on an internal review of the document; feedback from Outside Directors/Proxy Holders; and feedback from Industry. This version replaces the previous ECP template released on 6/28/10.
ECP Summary of Changes:
- Clarification on Teleconference and Video Teleconference requirements (See sections 1, 17.1, and 17.3 of the ECP Template).
- Monitoring configuration changes and defining which ECP changes require prior approval by DSS (See section 8.1 and the addition of attachment 4 "ECP Revision Log").
- Export Control Procedures (Section 16). The addition of the sentence: "If a third party provider is administering the Company's network, please describe the Company's procedures in place to ensure that export control violations do not occur with respect to the third party provider's administration of the Company's network."
- Attachment 3 - The User Acknowledgement language has been revised to reflect that employees must be briefed on the purpose of the ECP and their responsibilities under the plan.
