POLICY MEMO: Mitigating Sovereign Risk in Defense-Integrated Mega-Constellations
TO: Senate Armed Services Committee; House Committee on Financial Services; National Security Council Staff FROM: Sven-Erik Nyberg (Strategic Infrastructure Analysis Group) DATE: February 23, 2026 SUBJECT: Foreign Sovereign Investment in Sole-Sourced Defense Constellations — CFIUS Gaps, Vendor Lock-In, and the Pre-IPO Window I. Executive Summary The events of February 16–22, 2026, have exposed a structural vulnerability in the frameworks governing foreign investment in defense-critical infrastructure operators. While legacy legal mechanisms have engaged successfully with individual actors (e.g., the U.K. arrest of Andrew Mountbatten-Windsor for misconduct in public office), no equivalent mechanism has visibly engaged with the conversion of $3 billion in Saudi sovereign capital into equity in the entity that sole-sources the Pentagon’s primary military satellite communications constellation (MILNET) and hosts AI models on classified networks (GenAI.mil at Impact Level 5). ...