DSCA Tightens Enhanced Monitoring Criteria for FMS Articles

DSCA’s new guidance means some FMS articles will face tighter post-sale controls before they can be transferred to foreign partners. Items involving critical program information, embedded cryptography, or high diversion risk may be put under Enhanced End Use Monitoring, which can require certified storage sites, serial-number inventories, security notes in the Letter of Offer and Acceptance, and, in some cases, U.S. custody or electronic monitoring. DSCA says EEUM designations now require senior-level endorsement from the military department or implementing agency, so the process should be more formal and better justified, but also more consequential for sensitive sales.