Section 889 of the FY 2019 National Defense Authorization Act has imposed significant new compliance burdens on government contractors, including commercial companies. The Coalition is pleased to host David Fletcher and Alexander Canizares of Perkins Coie LLP for webinar on February 25th regarding Section 889: Compliance Strategies and Risk Mitigation for Commercial Contractors.
Numerous questions remain about what steps contractors can or must take to fulfill their obligations to represent, on an ongoing basis, that they do not use certain telecommunications equipment or services in any part of their business. Numerous interpretive issues in the interim rule remain unanswered. The interim rule is expected to become a final rule in 2021, highlighting the importance of a robust compliance policy and approach to enforcement risks.
This webinar will:
- Provide a practical overview of emerging legal issues arising out of Section 889 and its impact on commercial contractors that provide goods or services to the federal government, in particular
- Provide several steps that companies can take to stay compliant and navigate difficult issues arising out of Section 889, such as subcontractor management and the scope of the “reasonable inquiry” required under the rule
- Highlight False Claims Act enforcement risks and other issues