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As of March 1, 2017 the Foreign Military Financing of Direct Commercial Contracts guidelines changed. This also includes revisions to the Contractor Certification and Agreement. During this webinar, we will discuss:

  • Inapplicability of the Buy American Act and Trade Agreement Act
  • Hypothetical examples
  • Revised DCC methodology for determining U.S. and non-U.S. content
  • Use of first tier subcontractor certification
  • Reasonable travel expenses
  • Uses of FMF for non-U.S. spare parts
  • Waiver requests of guidelines requirements
  • Clarification of the term “commercial market” for DCCs
  • Purchasing company’s consideration of non-U.S. content in price competition
  • Higher threshold for DCC Compliance Audits
  • Pricing review threshold for sole source contracts
  • Cost audit threshold for sole course contracts
  • Consequences of non-compliance with DCC guidelines requirements