Action Kit: FCAS Two-Fighter Restructuring

Event Type: Policy Change

Severity: MEDIUM

Impact Areas: European defense partnerships, transatlantic cooperation, fighter aircraft development, ITAR (International Traffic in Arms Regulations)/EAR compliance

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Immediate Actions (This Week)

• [ ] Review active ITAR/EAR authorizations for any European defense partnerships, particularly with Airbus, Dassault, or German/French/Spanish defense entities. Document current technology transfer agreements and export licenses.
• [ ] Audit current teaming agreements with European partners on sixth-generation fighter systems, advanced avionics, or combat air system components. Identify clauses related to program restructuring or work share changes.
• [ ] Assess exposure to FCAS supply chain disruption — inventory any subcontracts, component supply agreements, or R&D partnerships tied to the unified FCAS program that may be affected by a two-fighter split.
• [ ] Brief executive leadership and BD teams on potential impacts to European defense strategy, including implications for U.S.-European co-development programs and Foreign Military Sales opportunities.
• [ ] Flag affected opportunities in pipeline — identify any active pursuits involving European fighter modernization, transatlantic defense cooperation, or sixth-generation air combat technologies that may require strategy adjustment.

Short-Term Actions (30 Days)

• [ ] Conduct strategic positioning analysis — evaluate whether a two-fighter FCAS creates new market entry points for U.S. contractors in avionics, mission systems, sensors, or electronic warfare subsystems for either the French-led or German-led variant.
• [ ] Engage with Defense Security Cooperation Agency (DSCA) and State Department contacts to understand how FCAS restructuring may affect Foreign Military Sales policy, technology release decisions, or transatlantic defense industrial base initiatives.
• ] **Review and update CMMC (Cybersecurity Maturity Model Certification)/NIST 800-171 (NIST Special Publication 800-171) controls** for any CUI (Controlled Unclassified Information) related to European defense partnerships. Ensure information barriers are in place if working with competing FCAS factions. Reference the [CMMC Compliance Guide (/insights/cmmc-compliance-guide) for control family mapping.
• [ ] Update capture plans for Air Force and Navy sixth-generation fighter programs (NGAD, F/A-XX) — assess whether European fragmentation strengthens U.S. domestic programs or creates opportunities for transatlantic technology insertion.
• [ ] Initiate outreach to European subsidiaries or partners (if applicable) to understand their positioning relative to the French vs. German fighter tracks and identify potential teaming or supply chain realignments.
• [ ] Monitor Congressional defense committees for reactions to FCAS restructuring, particularly regarding implications for NATO interoperability, U.S. fighter exports (F-35), and defense industrial base resilience.

Long-Term Actions (90+ Days)

• [ ] Develop dual-track European engagement strategy — prepare capability statements and partnership proposals tailored separately to French-led and German-led fighter programs, recognizing divergent requirements and industrial policies.
• ] **Invest in ITAR/EAR compliance infrastructure** for managing parallel European partnerships that may have conflicting technology protection requirements. Consult the [Secure Operations Guide (/insights/secure-operations-guide) for segregated CUI handling protocols.
• [ ] Position for post-FCAS opportunities — identify subsystem, sustainment, and modernization opportunities that emerge from a two-fighter solution, including potential for U.S. technology insertion in avionics, weapons integration, or mission systems.
• [ ] Strengthen relationships with U.S. Air Force and Navy on sixth-generation fighter programs, emphasizing lessons learned from European program fragmentation and the value of unified requirements and industrial base coordination.
• [ ] Evaluate long-term European defense market strategy — assess whether FCAS fragmentation signals broader challenges in multinational European defense programs (e.g., MGCS tank, European drone programs) and adjust market entry strategies accordingly.
• [ ] Prepare for potential FMS opportunities if either France or Germany seeks U.S. technology partnerships to de-risk their respective fighter programs, particularly in areas like stealth, sensor fusion, or advanced manufacturing.

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Compliance Checklist

This event primarily affects international defense cooperation and technology transfer compliance. Contractors with European partnerships should verify:

ITAR/EAR Export Controls

• [ ] Current Technical Assistance Agreements (TAAs) with European partners are reviewed for scope limitations if FCAS splits into competing programs
• [ ] Export licenses for defense articles or technical data shared with French, German, or Spanish entities are documented and current
• [ ] Retransfer authority is clearly defined if European partners may share U.S.-origin technology between the two fighter programs
• [ ] Deemed export controls are in place for any foreign nationals from FCAS countries working on U.S. fighter programs or sensitive technologies

DFARS (Defense Federal Acquisition Regulation Supplement) and Supply Chain Security

• [ ] DFARS 252.204-7012 (Safeguarding Covered Defense Information) controls are applied to any CUI shared with or received from European defense partners
• [ ] DFARS 252.225-7049 (Buy American—Free Trade Agreements—Balance of Payments Program) is evaluated if sourcing components from European FCAS suppliers
• [ ] Supply chain risk assessments updated to reflect potential disruption or fragmentation of European defense industrial base

CMMC and Cybersecurity

• ] **NIST 800-171 controls** (particularly Access Control, System and Communications Protection, and Media Protection families) are enforced for any CUI related to European partnerships. See the [CMMC Compliance Guide (/insights/cmmc-compliance-guide) for implementation guidance.
• [ ] Information barriers established if simultaneously supporting competing French and German fighter programs to prevent unauthorized CUI disclosure
• [ ] Incident response procedures updated to include notification requirements for both U.S. and European authorities if a cyber incident affects transatlantic defense data
• ] **CUI handling procedures** reviewed for compliance with both U.S. requirements and European equivalents (e.g., EU classified information, national security classifications). Reference the [CUI-Safe CRM Guide (/insights/cui-safe-crm-guide) for managing controlled information in business development systems.

Foreign Military Sales (FMS) and DSCA Coordination

• [ ] FMS case documentation reviewed if currently supporting European fighter programs through U.S. government channels
• [ ] Technology release policies confirmed with DSCA and State Department for any U.S. technology proposed for integration into French or German fighter variants

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Resources

Regulatory and Policy Guidance

• ITAR Regulations (22 CFR 120-130) (https://www.ecfr.gov/current/title-22/chapter-I/subchapter-M) — International Traffic in Arms Regulations governing defense article exports
• EAR Regulations (15 CFR 730-774) (https://www.ecfr.gov/current/title-15/subtitle-B/chapter-VII/subchapter-C) — Export Administration Regulations for dual-use items
• DFARS 252.204-7012 (https://www.acquisition.gov/dfars/252.204-7012-safeguarding-covered-defense-information-and-cyber-incident-reporting) — Safeguarding Covered Defense Information
• NIST SP 800-171 (NIST Special Publication 800-171) Rev 2 (https://csrc.nist.gov/publications/detail/sp/800-171/rev-2/final) — Protecting Controlled Unclassified Information
• DSCA Foreign Military Sales Overview (https://www.dsca.mil/programs/foreign-military-sales-fms) — Foreign Military Sales program guidance

Agency and Program Information

• Defense Security Cooperation Agency (https://www.dsca.mil/) — Oversees U.S. government-to-government defense sales and technology transfer
• Department of State Directorate of Defense Trade Controls (https://www.pmddtc.state.gov/) — ITAR licensing and compliance
• Air Force Life Cycle Management Center (https://www.aflcmc.af.mil/) — Manages fighter aircraft programs including NGAD
• SAM.gov (System for Award Management) Contract Opportunities (https://sam.gov/content/opportunities) — Federal contracting opportunities database

Internal Cabrillo Club Resources

• Secure Operations Guide (/insights/secure-operations-guide) — Comprehensive framework for CUI handling, ITAR compliance, and secure business operations
• CMMC Compliance Guide (/insights/cmmc-compliance-guide) — Step-by-step implementation guidance for CMMC Level 2 and NIST 800-171 controls
• CUI-Safe CRM Guide (/insights/cui-safe-crm-guide) — Best practices for managing controlled information in business development and capture systems

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How Cabrillo Club Automates This

Cabrillo Signals War Room has already detected this FCAS restructuring event and delivered this briefing to your dashboard within minutes of the announcement. The War Room continuously monitors defense policy shifts, international cooperation program changes, and European defense industrial developments across hundreds of sources — ensuring you're alerted to events like this before they appear in mainstream defense media. For this event specifically, War Room flagged the policy change, assessed its severity based on your company's European partnership profile and NAICS code exposure, and automatically generated this Action Kit with tailored compliance and business development guidance.

Cabrillo Signals Match Engine is automatically rescoring opportunities in your pipeline that involve European defense partnerships, sixth-generation fighter technologies, or transatlantic cooperation programs. If you're tracking Air Force NGAD opportunities, Navy F/A-XX pursuits, or any Foreign Military Sales involving fighter aircraft, Match Engine has updated relevance scores to reflect the shifting competitive landscape — European program fragmentation may strengthen U.S. domestic fighter programs and create new technology insertion opportunities. The engine also flags teaming agreement risks if you have partnerships with entities on opposite sides of the FCAS split.

Cabrillo Signals Intelligence Hub allows you to configure saved searches for follow-on developments related to this event. Set up alerts for solicitations matching NAICS codes 336411 (Aircraft Manufacturing), 541712 (R&D in Defense), or 334511 (Navigational/Guidance Instruments) combined with keywords like "sixth-generation fighter," "European defense cooperation," or "Foreign Military Sales fighter aircraft." Intelligence Hub will notify you when new opportunities appear on SAM.gov that align with the FCAS restructuring's market implications, and it tracks affected agencies (DOD, Air Force, DSCA, State Department) so you can monitor policy guidance updates.

Proposal Studio (Proposal OS) helps you respond to opportunities affected by this event by maintaining your win themes library with updated positioning on transatlantic defense cooperation, European program risk mitigation, and U.S. technology advantages in sixth-generation fighter systems. When you pursue Air Force or Navy fighter modernization opportunities, Proposal OS can generate compliance matrices that automatically incorporate ITAR, CMMC, and NIST 800-171 requirements relevant to international partnerships. The bid/no-bid decision engine factors in geopolitical risk indicators like FCAS fragmentation when scoring new opportunities.

Proposal Studio Workflow Tracker manages the 9-gate capture process for any opportunities affected by this event, automatically routing ITAR/EAR compliance reviews to your contracts and legal teams when European partnerships are involved. If you're pursuing teaming arrangements with French or German defense entities, Workflow Tracker ensures supplier certifications, export license documentation, and technology transfer agreements are collected and validated before gate reviews. It generates audit-ready documentation packages that demonstrate compliance with DFARS 252.204-7012 and CMMC requirements for any CUI shared with international partners.

Explore these features in your Cabrillo Club dashboard to see how the platform is already working for you on this event. Navigate to Signals War Room to review the full event timeline and related developments, or visit Intelligence Hub to configure custom alerts for FCAS-related opportunities.

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