Due Diligence

FRE is a risk assessment process designed to protect U.S. intellectual property and defense capabilities. The evaluation process confirms or denies reported foreign interests and associations while uncovering unreported factors representing potential conflicts of commitment or interest. As it pertains to congressional requirements for the SBIR and STTR Programs, foreign risk evaluation primarily focuses on

Capitalization Table Assessment  Know your investors: Where are your investors headquartered? Who are the key stakeholders in that business? Do any individuals have potential foreign countries of concern affiliations? Are there any agreements with investors regarding IP that increases malign tech transfer risk?  Employee Assessment  Know your employees: Do your company executives or individuals involved with the SBIR and/or

The Army SBIR|STTR FRE team conducts evaluations by cross-referencing company submitted disclosures with a combination of publicly available information (PAI), commercially available information (CAI), open-source research, and commercial business intelligence tools. 

No – the Army SBIR|STTR FRE team will independently assess each proposal using the standard foreign risk evaluation process. For proposals exhibiting significant risk indicators, such as covered individuals with foreign countries of concern affiliations or investment, the FRE team will conduct enhanced deep dive reviews on the indicated risk and overall proposal. The presence of individual risk indicators will not cause the team

See Risk Factors above and also reference 2026 Department of War (DoW) SBIR and STTR Foreign Risk Evaluation Program Common Decision Matrix. 

The Army SBIR|STTR FRE team assesses both company disclosures and business intelligence data through our providers. Once a small business submits a proposal via DSIP, the team identifies any discrepancies between the forms, and/or foreign nexus, and/or other business concerns from the business intelligence data to produce a Secondary Review report. The team uses the Secondary Review report to triage proposals

The SBIR and STTR Extension Act of 2022 (Extension Act), Public Law 117–183 (Sep. 30, 2022), which amended section 9 of the Act, 15 U.S.C. 638(g)(13)–(17), (o)(17)–(21), and (vv), and the Small Business Innovation and Economic Security Act of 2026 (Economic Security Act), Public Law 119–83 (Apr. 13, 2026), jointly require small businesses applying for SBIR or STTR awards to disclose information about the applicant’s