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DEFENSE & GOVERNMENT CONTRACTING

Know Your Customer verification

Know Your Customer verification in Defense and Government Contracting sits at the intersection of two distinct regulatory authorities: the U.S. Financial Crimes Enforcement Network, which sets beneficial ownership and customer due diligence standards under the Corporate Transparency Act framework, and the Defense Contract Audit Agency, which scrutinizes contractor identity and ownership disclosures during cost and pricing reviews. Contractors holding or pursuing federal awards are mapping KYC obligations across both tracks simultaneously, particularly as FinCEN's beneficial ownership reporting rules tighten disclosure requirements for entities that flow through defense supply chains.

Watch

  • FinCEN beneficial ownership reporting deadlines for existing entities created before January 2024
  • DCAA audit scrutiny of foreign ownership, control, and influence disclosures in contractor submissions
  • Proposed updates to DFARS clause 252.204-7008 affecting contractor identity verification at onboarding
  • State Department Directorate of Defense Trade Controls guidance on KYC for ITAR-licensed parties

Recent material activity in Defense & Government Contracting

Active monitoring in place across Defense & Government Contracting. Material developments related to know your customer verification will appear here as they are published.