Comment on FR Doc # 2026-09067

To: Defense Acquisition Regulations System (DARS) Department of Defense Attn: Ms. Heather Kitchens, 571-296-7152 https://www.regulations.gov Subject: Public Comment — Proposed Rule, Mitigating Risks Related to Foreign Ownership, Control, or Influence (DFARS Case 2021-D011) From: Satyadhar Joshi Alumnus, International MBA — Bar-Ilan University, Israel Alumnus, M.S. Information Technology — Touro College, New York, USA ORCID: 0009-0002-6011-5080 satyadhar.joshi@gmail.com Dear Ms. Kitchens and the Defense Acquisition Regulations System, I write as an independent researcher to submit formal public comment on the proposed rule to amend the Defense Federal Acquisition Regulation Supplement (DFARS) to mitigate risks related to foreign ownership, control, or influence (FOCI), as announced in Federal Register Volume 91, Issue 88 (May 7, 2026), FR Doc. No. 2026-09067, DFARS Case 2021-D011. I support this proposed rule. The threat posed by foreign adversaries gaining unauthorized access to DoD information, intellectual property, and critical technologies through ownership, control, or influence of U.S. defense contractors is documented and escalating. The proposed rule's implementation of sections 847 and 819 of the National Defense Authorization Acts for Fiscal Years 2020 and 2021 provides unprecedented visibility into contractor ownership structures and is essential to securing the defense supply chain. Summary of Comments My comments address the national security imperative and implementation considerations of the proposed rule. In brief: National Security Imperative. The proposed rule is critical to national security and should be finalized expeditiously. It provides the foundational data required to understand and mitigate foreign-based risks in the defense supply chain, aligns with Executive Orders 14017 and 14028, and serves as a critical upstream defense against threats entering the supply chain. Burden Estimates and Small Business Impact. The DoD's burden estimates appear reasonable, but AI automation could substantially reduce respondent burden. The estimated 10-minute verification time for offerors could be reduced to near-zero through automated verification and continuous monitoring. The rule's application to small businesses (57% of impacted entities) must be carefully calibrated. Enhancing Quality and Utility of FOCI Information. A machine-readable data schema for FOCI and beneficial ownership disclosures, AI validation tools for SF-328 completeness and accuracy, and a centralized DoD analytics capability would substantially enhance the value of collected information. Minimizing Respondent Burden Through Automation. AI-driven continuous monitoring of beneficial ownership changes, automated NISS eligibility verification, and AI-generated risk mitigation strategy recommendations could reduce respondent burden while improving security outcomes. DoD should issue guidance endorsing AI-assisted compliance tools and support API integration with NISS. Subcontractor Compliance. AI can automate tracking of subcontractor NISS eligibility status and continuous monitoring of FOCI risk indicators across the supply chain, substantially reducing the burden of compliance for prime contractors. I attach hereto a full academic paper, "Artificial Intelligence for Corporate Governance in the U.S. Defense Industrial Base: A Scholar-Practitioner Framework for Mitigating Risks Related to Foreign Ownership, Control, and Influence," which develops these comments in detail, grounds them in established governance theory, and provides specific implementation recommendations for DoD and the contractor community. I appreciate the opportunity to contribute to this important national security policy discussion and welcome any follow-up questions. Respectfully submitted, Satyadhar Joshi Independent Researcher ORCID: 0009-0002-6011-5080 June 17, 2026