Advertising OCONUS Assistance Opportunities

OMB Circular 89 Revised requires getting a CFDA number for all Federal Domestic Assistants Programs, which are defined by the circular as, " any function of a Federal agency that provides assistance or benefits for a State or States, territorial possession, county, city, other political subdivision, grouping, or instrumentality thereof; any domestic profit or nonprofit corporation, institution, or individual, other than an agency of the Federal Government. A Federal domestic assistance program may in practice be called a program, an activity, a service, a project, a process, or some other name, regardless of whether it is identified as a separate program by statute or regulation. It will be identified in terms of its legal authority, administering office, funding, purpose, benefits, and beneficiaries."

If I have an assistance requirement, providing assistance overseas in theater, my interpretation would be that a CFDA # is not required because it is not a domestic assistance program. Is that interpretation correct?

Thanks