Lenders may not be allowed to see parts of their collateral, and foreign owners may need to be walled off from the business through mitigation agreements.
Across the 3 regimes
United Kingdom
Classified information is defined in the Procurement Act. Contractors holding it work under the Government Security Classifications and security conditions in the contract, with List X clearance for higher classifications.
United States
NISPOM (32 CFR Part 117) facility clearances, with foreign ownership, control or influence (FOCI) mitigated by board resolutions, security control agreements or proxy agreements.
EU and NATO
Directive 2009/81/EC lets authorities set security of information requirements. Member states recognise equivalent security clearances.
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Related
- Tool: Deal clearance navigator: NSI Act, CFIUS, EU screening and FCC
- Tool: Defence finance clause library
- Tool: Defence finance clause library
- Checklist: Defence target due diligence checklist
General information on public law and standard terms as at 28 Oct 2026, not legal advice on any contract or transaction. Quoted wording is checked against the official text linked to it.