Section 889 Demystified: How to Reduce Enforcement Risks

Presenters:

David Fletcher, Perkins Coie LLP

Alexander Canizares, Perkins Coie LLP

Section 889 of the FY 2019 National Defense Authorization Act imposes significant new compliance burdens on government contractors.  Under an interim rule implementing Section 889 that took effect in August 2020, in order to do business with the government, prime contractors are required to represent that, based on a reasonable inquiry, they do not use certain telecommunications equipment or services in any part of their company.  Contractors also must make and periodically update representations that no such equipment or services are provided to the government.  The rule also requires contractors to flow down certain reporting obligations to their subcontractors.

This program will provide an overview of the Section 889 rule and its implications, and emerging legal issues arising out of its implementation.  It will also provide several practical steps that companies can take to stay compliant and adopt reporting and other requirements into their policies.  It will also highlight False Claims Act enforcement risks and other issues.

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