section 889 compliance form

Is your company in violation? EMC endstream endobj 311 0 obj <>/ProcSet[/PDF/Text]>>/Subtype/Form/Type/XObject>>stream EMC @��(��1��q┆��@��^�i�e��/��z^�� p� )��@Z�u�"+��v-bd` �1,80w0t0X1pL`��`��Q i�,`��PW��=C"��'��_�w1��|��{�a.g��,Jp��2p�~��v1f i>ιa>s?��d`=��}�h��Zq|I�8��iV�cp��8�YC�b0 �Q@� Inc. All Rights Reserved. Expanse is an automated Attack Surface Management (ASM) Platform, and solves this problem by providing a complete and accurate list of an organization’s global internet-facing assets and Section 889 violations to continuously discover, evaluate, and mitigate banned technologies because of their known ties to the People's Republic of China. The report will quantify the state of your attack surface to help comply with Section 889, and highlight the most severe risks, if any, curated by a human cybersecurity expert. H�l�� H�l�K� ��U7u��? endstream endobj 300 0 obj <>/Subtype/Form/Type/XObject>>stream endstream endobj 304 0 obj <>/Subtype/Form/Type/XObject>>stream H�l�K�0D��ρ��'Rk��Y0!��2�F�Y1A��d#V�p_`�CF�\4��;�si�7��y�� M? �0D��HɁ�l�M{��C��A3�0-�)`FF1�$%�q�}�케�`m:�� x�0�N��W]��7X�J��U�徊�}�|�� F(� ��#��M��l��V yP�\[|��Ł^z��v�h�g�� ͝W�� g��?��oG�L%��A��G!��Cp��B�s!��'ϠSAg�> N_��\ʧq��Z. H�l�� Specifically, company counsel and compliance functions will need to work with their global counterparts in procurement, finance, IT, and sales and marketing to map company supply chains and identify the areas of heightened risk – leveraging the five elements in Chart 2. There are two parts of Section 889. 0 H�l�;1��[j�ͻ�l��`�h�NP�?�IE��d؍�R�؁D�J�BE�;m�~��F�p(��GZt"�E�H��N��;��DJOՖ;�o?�&,��ȃ?�VKbs��L��VG4"��0e0��hxrө Ӧ~��c��:�� Dz>� Section 889 ("Prohibition on Certain Telecommunications and Video Surveillance Services or Equipment") is part of the Fiscal Year 2019 National Defense Authorization Act (NDAA). Section 200.216 in the final guidance issued Aug. 13 will help security companies and their customers ensure grant funds are spent in compliance with Section 889 by simply making sure equipment that would be covered by Section 889 is excluded from what is purchased with the funds. I acknowledge that I have read and understand the government compliance memorandum related to Section 889 of the National Defense Authorization Act (NDAA). endstream endobj 316 0 obj <>/Subtype/Form/Type/XObject>>stream 425 Market St, 8th Floor San Francisco, CA 94105. Fill out the form and a member of our team will follow up with you to schedule a read out of our findings. EMC Backhaul can be wireless (e.g., H�l�K� D�=EO`��Q�nd��OlAB$.�)�Z $d��ͪ+^�@�'S�̡s��UMtG_G�#�Z\��;A+ZS�,�Sʢg$�/nx �8+� Section 889 of the 2019 National Defense Authorization Act prohibits the federal government, government contractors, and grant and loan recipients from procuring or using certain “covered telecommunication equipment or services” that are produced by Huawei, ZTE, Hytera, Hikvision, and Dahua and their subsidiaries as a “substantial or essential component of any system, or as critical … endstream endobj startxref The NDAA 2019 Section 889 prohibits the U.S. government from procuring video surveillance and telecommunication equipment from certain Chinese companies and their subsidiaries. Section 889 of the FY2019 National Defense Authorization Act imposed significant new compliance obligations on government contractors regarding their ability to sell—and even … I acknowledge I understand that failure to comply with this agreement may result in exclusion from the United States Government AIR Card® and/or SEA Card® programs. The legislation was passed to combat national security and intellectual property threats that face the United States and contains two prohibitions: Part … %%EOF The Part B FAR rule, published on July 14, 2020, requires FAR clause 52.204-25 (AUG 2020) be added to all indefinite delivery acquisition vehicles prior to order placement unless your agency policy specifies otherwise or a waiver is obtained. Section 889 prohibits the federal government from directly procuring “any equipment, system or service that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as a part of any system” or entering into a contract with any entity that uses such covered telecommunications equipment or services. /Tx BMC Section 889 (a) (1) (B) NATIONAL DEFENSE AUTHORIZATION ACT (NDAA) SECTION 889 REPRESENTATION FORM Merchant/Company Name (Offeror) DUNS Number Cage Code Number Owner or Authorized Representative Title e-mail Company Street Address City State Zip Telephone Number Company Website (if applicable) INSTRUCTIONS TO MERCHANT �4^� }g-�^W�p{'��-��^�/]u@��pu(��3X!�� !��s��9��z��u ��[Q��A��ШmKK��ӑ��ɨ&:Bb��y��r��3�# �R�{��zb"�!z$��g�Y��d[��h濷��b^s�L�G�Ě�op��L��:��xڜѪ"aj�*�� .��v�,�� ` ��@+ The report will quantify the state of your attack surface to help comply with Section 889, and highlight the most severe risks, if any, curated by a human cybersecurity expert. The attached document contains the questions from the contract holders and the GSA responses. In the face of rising uncertainty over data security and surveillance by foreign adversaries, DOD, GSA, and NASA (collectively, the FAR Council) released an interim final rulelast month banning Federal agencies from purchasing telecommunications and video surveillance equipment or services from certain Chinese entities. Section 889 of the 2019 National Defense Authorization Act (NDAA) broadly prohibits federal executive branch agencies from obtaining, or contracting with entities that use, certain “covered telecommunications equipment or services,” specifically those produced by five Chinese companies (and any subsidiary or affiliate thereof)—as a “substantial or essential component of any system, or as … The restrictions of Section 889(a)(1)(B) went into full effect yesterday, August 13, 2020. EMC The Federal Acquisition Service (FAS) is here to help our customer agencies with Section 889 implementation. H�l�� 0E�L� Тv �b/�"�6��?�`܁�� YǸ��8k�F��Z� �l�I��ԡ�J��iU�T'��z(z|�� ~�+� *� Fill out the form and a member of our team will follow up with you to schedule a read out of our findings. H�l�K�0��+��ͣi��7/B@�hb��8d��L>6ZoK4i�J��WlmM�3Z :01�I] ��J�N�;:��m��''q��4��7Q�!l��e�bX)(�)��Js�H�PWO25m0ss��#�x 0 �=R endstream endobj 303 0 obj <>/ProcSet[/PDF/Text]>>/Subtype/Form/Type/XObject>>stream As part of a recent wave of supply chain requirements, Section 889 of the 2019 National Defense Authorization Act (“NDAA”) imposed major new limitations on the use of certain Chinese telecommunications products and services in federal procurement, and recent implementing regulations mandate a range of compliance actions relating to the ban. On June 19th, GSA solicited feedback from the current telecommunications contract holders on the implementation of Subsection 889 (a) (1) (B) of the FY19 National Defense Authorization Act (NDAA) Section 889. endstream endobj 295 0 obj <>/Subtype/Form/Type/XObject>>stream Fill out the form and a member of our team will follow up with you to schedule a read out of our findings. October 9, 2020 @ 12:00 pm - 1:00 pm Free « Government Contracts Compliance – Supply Chain Issues; Financial Forum Webinar Series 2020 » Learn More & Register. H�l�K� ��@��i�k��g��iX��Q�l��b0�X}P�֖�x�W'�� ٭�4ϕ�?��Ȱ��?�` gw*� �Q��-��}��Ããc>��9��i��e7�0�o�,��{� ��=�ʫV��^�#��2�S�7K�g�D��Ab��6v�` �d>� SECTION 889 – VARYING COMPLIANCE REQUIREMENTS FOR NON-PROFITS . Government Contracts 2 Section 889 (or to obtain a waiver beyond August 13, 2020) will become a discriminator in the contracting process. j��9�2��ax6��/�¦�[�W�"�1��6p?`��L�� endstream endobj 308 0 obj <>/Subtype/Form/Type/XObject>>stream Section 889 (a)(1)(B) requires a more robust training of the organization's compliance plan, which include business partners that are outside of the typical “covered telecommunications equipment or services” purchases; such as day-day office supplies. On Aug. 12, U.S. Director of National Intelligence (DNI) John Ratcliffe issued a memorandum to the U.S Department of Defense (DOD) granting a waiver to the prohibitions listed in Section 889 (a)(1)(B) of the 2019 National Defense Authorization Act (NDAA). H�l�A�0��益شig��7/BA��]��y�//��p�mth��@��SW��7~��mm�:�7��}��U��$/_��G�&f��^�Y%Z��W��CʱR�t��Α��I�� y;� The rule implements Section 889 of the John S. McCain National Defense Authorization Act (NDAA) for Fisca… endstream endobj 306 0 obj <>/Subtype/Form/Type/XObject>>stream RECOMMENDED CONTRACTOR WAIVER PROCESS Contractors should be aware that Section 889 does not have an exemption for commercial item contracting, and that the prohibition applies to all purchases regardless of the size of the contract or order (including purchases below the Micro-purchase and Simplified Acquisition Thresholds). h��Xmo�8�+��PQ�HQ� ��\}��^� �E�Beɫ�n��fHY��8�-��9��pH��!�� (�Q�2ca�C�p@�� #�w�Ep�Y; ��p�#�O�"�"�7�t|섄 ET . are compliant with section 889. Section 889 Prohibition on Use of Covered Telecommunications Equipment. endstream endobj 307 0 obj <>/ProcSet[/PDF/Text]>>/Subtype/Form/Type/XObject>>stream The Federal Acquisition Regulation (FAR) case 2018-017 prohibits the purchase of covered telecommunications equipment and services from vendors who sell products containing spyware. EMC Effective August 13, 2020, FAR 4.2102 (a) (2) implemented the statutory prohibition 889 (a) (1) (B) for agencies to “enter into a contract to procure or obtain, or extend or renew a contract to procure or obtain any equipment, system, or service that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system,” … As a result, endstream endobj 299 0 obj <>/Subtype/Form/Type/XObject>>stream Section 889(a)(1)(B) prohibits Executive agencies, including DoD, from entering into a contract (or extending or renewing a contract) with an entity that uses any equipment, system, or service that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system. /Tx BMC %PDF-1.6 %�� 1��9�6mڵWћ� xSt��n�?<4��ɗ��&M�,Ģ�t?��N-gS��/�V�T�|�&�l� ��=޿��*u��ߊr"��K�?p+��⚾�a1��Sl!��ITh�Q�XEl�` [�= Please enter your desired quantity. endstream endobj 313 0 obj <>/ProcSet[/PDF/Text]>>/Subtype/Form/Type/XObject>>stream 425 Market St, 8th Floor San Francisco, CA 94105, Terms of Use | Privacy & Security | © 2020 Expanse Section 889 compliance As a US Government contractor, we are required to be compliant with Section 889 of the 2019 National Defense Authorization Act. A central challenge in Section 889 compliance is full visibility and control of your entire universe of IT assets. /Tx BMC )��'`�Y9 $�i�?�,��Q�Vϩ56��"7�N�Q�e6G��A�se��N��mA��h�p networks. 415-590-0129 | "�FGx�� l�N��a!�T�7�gB16TkLW��F��[j,��v �` ?�@# Section 889 Part B Prohibited Telecom Rule Implementation Instructions are here! H�l�K The FAR Ruleimplementing Section 889 of the FY 2019 National Defense Authorization Act (NDAA) is published. Section 889 in effect prevents the sale — or use (starting in August 2020) — of products or services incorporating certain Chinese technology. As used in this certification- Backhaul means intermediate links between the core network, or backbone network, and the small subnetworks at the edge of the network (e.g., connecting cell phones/towers to the core telephone network). endstream endobj 309 0 obj <>/ProcSet[/PDF/Text]>>/Subtype/Form/Type/XObject>>stream h��λ �PD�ٵ,AFJ@D�̧*�� $F�2Z�.��] �0��H�F��hݤ�\*��q�u�z��ؑ�8Œ��C�m�k�mo��&kٗ�� .� /Tx BMC endstream endobj 314 0 obj <>/Subtype/Form/Type/XObject>>stream endstream endobj 297 0 obj <>/Subtype/Form/Type/XObject>>stream The more limited Part A of Section 889, which prohibits the federal government from obtaining any equipment, services or systems from the covered companies, went … Applying For and Processing Waivers – Section 889(d) permits two types of waivers from compliance with Section B obligations. At least 1-in-5 Fortune 500 companies have devices potentially subject to the ban on their I.T. See Webinar Catalog › View Your purchased on-demand webinar(s) › REGISTER NOW. uE� U#��x�6b�� |�>� Section 889 prohibits the federal government from directly procuring “any equipment, system or service that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as a part of any system” or entering into a contract with any entity that uses such covered telecommunications equipment or services. Section 889(B) compliance will require cross-functional collaboration and integration across a range of stakeholders. Citing national security interests in the context of DOD procurement, DNI Ratcliffe exercised existing authorities to offer a … EMC Section 889 of the FY 2019 National Defense Authorization Act (NDAA) includes two prohibitions detailed in Part A and Part B. /Tx BMC endstream endobj 315 0 obj <>/ProcSet[/PDF/Text]>>/Subtype/Form/Type/XObject>>stream H�l�?1��|��Ԧi�u�\��h�NP�?��w��>�K~��;[Ш�� H�l�K�0D��%��'B[�q�� Y2��yP2�&��e��F��xϵ�e�nH7�يk G��z��@UmK'V�N�1��w8 $*W [email protected] | H�l�� 359 0 obj <>stream /Tx BMC �0��{�K��i��7/B@�hb��M�Z,2Yfv�d�:h�ĕ2�b��ښ^W��kn��&�>�+��Y&&� ��ڈ&h��D�Z�F��J�(�3'�o<3��7:�!�wXG��͙��b�4�� endstream endobj 292 0 obj <>/Metadata 20 0 R/Outlines 43 0 R/Pages 289 0 R/StructTreeRoot 55 0 R/Type/Catalog>> endobj 293 0 obj <>/Font<>>>/Rotate 0/StructParents 0/Tabs/W/Type/Page>> endobj 294 0 obj <>/Subtype/Form/Type/XObject>>stream endstream endobj 305 0 obj <>/ProcSet[/PDF/Text]>>/Subtype/Form/Type/XObject>>stream This page serves as the electronic reading room for documents associated with the Implementation of Section 889(a)(1)(A) and 889(a)(1)(B), Prohibition on Contracting with Entities Using Certain Telecommunications and Video Surveillance Services or Equipment. Should an agency require open market micro-purchases (purchases that are not made under an existing Federal contract or order site), the agency should note that obtaining written representations to ensure compliance with section 889 will likely prove difficult, especially given the volume of online purchases. Section 889 Q&A’s Now Available. Notwithstanding these questions, it is plain that the ability to comply with . This requires that our telecomm services not use equipment from 5 Chinese companies or their subsidiaries. Webinar • Tuesday, October 27, 2020 • 1:00-2:30 p.m. %x䇎�s��AI�/�ia�"/�t▎\x \�Twɨ��^H��NW��Cm��^d�>c��y��9�AU�=#��^ě4{�r��ezj��L�ݒ�͈Y��}��GK��39�K]/�tR��83C�a��q �(_e��tV�ͯ`�ؗ ��L�uQ�� c�w��Q^��EZV�`��5�3:u�$��}�*m̚7y 291 0 obj <> endobj :8� ;�x�%�ixIGaX�P��R�0L�DHED�� : ��[:�N�;�}O�Kx��)^��(_I��{5�� .�>;�E^ôa��k�)�Ҥ:K�[��6h�ж4۲�妕�a�mE�Zq�RKC|wv��-}�azl��֒;Gt� ��.L]��?b��1�vq%�^��+�U6�� zQ�2�(N�'0W�Q�p��5��V�i��5��\|hL��x:�.�pt1��F$��^�?�q �d2�"2 �@�d0��/�Kr1�� |�2��N��;H�E��Q��c�˿߾�p�p�:�[��p(�(X�,�B��P��߇�PA�J��N��Hk�� Of�h`"�v��Ὴ��^�e�:�#ø�Ƒ�s��*��8r]Ǉ�^��A��'Q��3��W��D��nash��ƛ�sĕ��c�T��1�w��s�W]-֙v��S�%�"��>=�`�s`�� Please Note: CPE credit can be … /Tx BMC NDAA Section 889 | Smartpay NDAA Section 889 Protect yourself and your agency by checking the prohibited vendor list before making any telecommunications purchase. EMC U.S. Agency for International Development Section 889 Frequently Asked Questions (FAQs) for Contractors and Recipients of USAID awards. We are offering to provide you with an initial report – at no cost – including a snapshot of your network. OnDemand Recording $249.00 (Available for viewing until 10.27.2021) To order by phone, Call 1.800.677.3789. 0 P�*� endstream endobj 312 0 obj <>/Subtype/Form/Type/XObject>>stream Section 889 Compliance Obligations. endstream endobj 296 0 obj <>/Subtype/Form/Type/XObject>>stream H�l�A�0��9�6Mc׫�͋P�)��l��M�5_�6`�"��V(��\��5X#��\}�� ba��dZ�}�Hvo)ż�D�� ! h�b```�+l? The most problematic assets are the unknown assets followed by white-labeled hardware. Section 889 of the NDAA for FY 2019 contains two prohibitions related to Federal contracting: The first prohibition, set forth in section 889(a)(1)(A), took effect August 13, 2019, and prohibits the Government from buying and using covered telecommunications equipment or services from five named Chinese companies and their subsidiaries or affiliates. /Tx BMC endstream endobj 298 0 obj <>/Subtype/Form/Type/XObject>>stream endstream endobj 317 0 obj <>/Subtype/Form/Type/XObject>>stream endstream endobj 301 0 obj <>/ProcSet[/PDF/Text]>>/Subtype/Form/Type/XObject>>stream EMC aliquip ex ea commodo consequat. mx�l�Lf?D��i�Z��վ#�G�E�ҏ�� i�ڬ��r ��`�α��p��πjF��a-n�tz>�u��a;�N��;!ۻh��h@|W8\y��#0�P��J#�ᘷ]��q]�I��q#��H~ 8��qЋ��ޜ�S��$DN�� LAx0��P��^�&�ao��*�)��Q�� "xg��=��#�C3?�#&��= 332 0 obj <>/Filter/FlateDecode/ID[<8C9192F021A4CB45ADADCB81DD589B67>]/Index[291 69]/Info 290 0 R/Length 145/Prev 641185/Root 292 0 R/Size 360/Type/XRef/W[1 3 1]>>stream et dolore magna aliqua. The law, specifically Section 889, prohibits federal agencies, their contractors and grant or loan recipients from procuring or using “telecommunications and video surveillance equipment or services” from specific Chinese companies as a “substantial or essential component of any system, or as critical technology as part of any system.” The NDAA ban includes telecommunications equipment produced by Huawei … endstream endobj 310 0 obj <>/Subtype/Form/Type/XObject>>stream endstream endobj 302 0 obj <>/Subtype/Form/Type/XObject>>stream Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut Submitted by Tim Kievit on Wednesday, September 23, 2020 - 4:10 PM Section 889 of the FY19 National Defense Authorization Act (NDAA) is legislation passed to combat national security and intellectual property threats that face the United States. There are two prohibitions in the legislation, Part A and Part B. These are important considerations all contractors must take into account when evaluating compliance with Section 889. Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore H�l�� E�L�0h��^��֘��!x ��C*��r��;PP��z��Օ{��ס��'S�f�Ҙ�N�iM�� v(z�D��G� ��,' Here is a high-level overview of each: Section 889 Part A says that a contractor cannot sell or provide prohibited telecommunications (telecom) to federal agencies. must take to certify full compliance with Section 889(a)(1)(B), and the likelihood and length of time for waivers. FY-19 National Defense Authorization Act Section 889 Certification Form (Additional Information) (a) Definitions. endstream endobj 318 0 obj <>stream