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News | March 4, 2022

DCSA oversight of NISPOM Rule’s SEAD 3 requirements began March 1

Defense Counterintelligence and Security Agency (DSCA) Industrial Security Representatives (ISRs) began incorporating the assessment of compliance with Security Executive Agent Directive (SEAD) 3 reporting requirements into scheduled security reviews, DCSA announced on March 1.

SEAD 3 – released by the Office of the Director of National Intelligence – established reporting requirements for employees working in sensitive positions, including clarification and guidance on reportable activities for cleared contractors under DOD cognizance.

The reporting requirements as detailed in 32 Code of Federal Regulation, Part 117, “National Industrial Security Program Operating Manual (NISPOM),” became effective as a federal rule on Feb. 24, 2021. The NISPOM Rule replaced the existing DOD policy (DOD 5220.22-M) and provided contractors no more than six months from the effective date to comply.

Although implementation of the new NISPOM Rule came into effect on Aug. 24, 2021, DCSA informed facility security officers and security professionals throughout cleared industry that SEAD 3 oversight areas of security reviews for facility compliance would not begin until March 1, 2022.

DCSA Industrial Security Representatives are now implementing criteria clarified in Industrial Security Letter (ISL) 2021-02, “SEAD 3, Clarification and Guidance on Reportable Activities" for cleared contractors under DoD cognizance. The ISL clarifies reporting requirements for all covered individuals with access to classified information while advising cleared contractors that they must implement the change outlined in the NISPOM Rule.

Furthermore, an amendment to the rule was issued that moves one specific part of the SEAD 3 reporting requirements – foreign travel – to an implementation date of Aug. 24, 2022. Cognizant Security Agency guidance for SEAD 3 (itemized in ISL 2021-02 for those under DoD cognizance) can be found on the DCSA website, under ‘Industry Tools’ as well as on the NISPOM Rule webpage.

Resources for SEAD 3 implementation can be found at https://www.dcsa.mil/mc/ctp/NISPOM-Rule and include Industry SEAD 3 Reporting Webinar Recording; SEAD 3 Frequently Asked Questions (scroll down the page to locate and click the FAQs tab); and a SEAD 3 Reporting Desk Top Aid. Click here to view the ISL.

Additional industrial security letter guidance for 32 CFR Part 117, NISPOM Rule (insider threat, SF-328, DISS, and consolidated article) that have been coordinated through the National Industrial Security Program Policy Advisory Committee continue to be processed and coordinated for issuance. Cleared industry will be informed when they are approved and posted.

The latest SEAD3 Industry Reporting Desktop Aid is available at: https://www.dcsa.mil/Portals/91/Documents/CTP/tools/SEAD3_REPORTING_DESKTOP_AID_FOR_CLEARED_INDUSTRY.pdf.