Based on my research (Assuming that DoD memo DOPSR 24-P-0363 applies to CUI down flowed to contractors), it is perfectly permissible for foreign persons employed by a DIB customer to access CUI — with the exception of CUI marked as not releasable to foreign nationals (NOFORN). This also does not supersede ITAR or Export Control regulations.

Is this reasoning correct? We are trying to navigate CMMC needs for manufacturing facilities that employ non-US citizens/persons.