's shadow, the rules are made contractually.
As a first step, the company's existing policies and procedures relevant to insider threats should be reviewed for compliance with NISPOM
, supra note 238, 10-1-1 to 10-7-4; see Exec.
person employed by a foreign incorporated subsidiary of a company incorporated in the United States must be treated as a "foreign person" for purposes of access to information controlled by both the ITAR and the NISPOM
. Although there does not appear to be any specific guidance in the EAR, it is recommended that for due diligence purposes, the same consideration is given to information controlled by the EAR as for ITAR-controlled information.
The contractor shall establish procedures to ensure that foreign visitors are not afforded access to classified information and other export-controlled technical data except as authorized by an export license, approved visit request, or other exemption to the licensing requirements (NISPOM
These orders tend to exceed the requirements of the NISPOM
prescribes various FOCI negation arrangements.
These DSS regulations can be found in a publication called the National Industrial Security Program Operating Manual (NISPOM
The requirements of the Department of Justice's industrial security program are changing as the Industrial Security Manual (ISM) is replaced with the National Industrial Security Program Operating Manual (NISPOM
According to the DSS, a Superior rating is reserved for contractors that consistently and fully implement the requirements of the National Industrial Security Program Operating Manual (NISPOM
) in an effective fashion, resulting in a security posture that is superior to other contractors of similar size and complexity.
As compared to other contractors, a superior rating is reserved for contractors who have systematically and fully carried out the needs of the National Industrial Security Program Operating Manual (NISPOM
) in an effective fashion resulting in a superior security posture.
They can even upgrade their instruments to NISPOM