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Reminder

Compliance protocols MUST be approved and linked in SeRA to a SPO project record prior to award acceptance. 

See ORA's Award Acceptance Resources for additional information.

Covered Entities and Prohibited Components

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This page provides notice of government prohibitions related to certain products, services, and equipment. These requirements apply to Stanford due to its receipt of federal awards. If members of the Stanford community become aware of any of these products, services, and equipment covered by these sections being used or potentially used as described or have questions about these prohibitions, please contact prohibitedcomponents@stanford.edu. Departments should ensure faculty and staff with purchasing authority are aware of these restrictions.

NDAA Section 889 - Prohibition on Contracting With Entities Using Certain Telecommunications and Video Surveillance Services or Equipment

National Defense Authorization Act (NDAA) Section 889 prohibits government contractors from providing the federal government with telecommunications or video surveillance equipment, systems, or services (or an essential component thereof) produced or provided by five Chinese companies and their subsidiaries and affiliates. Section 889 also prohibits government contractors from using these prohibited items or services, regardless of whether they are used in the performance of work under a federal contract. The prohibited Chinese companies are listed here:

  1. Huawei Technologies Company
  2. ZTE Corporation
  3. Hytera Communications Corporation
  4. Hangzhou Hikvision Digital Technology Company
  5. Dahua Technology Company

In addition to these companies (and their subsidiaries and affiliates), Section 889 also applies to entities that the Secretary of Defense designates as entities "owned or controlled by, or otherwise connected to, the government of a covered foreign country." To check whether a company is a covered entity under Section 889 or on other restricted lists of entities presenting an elevated risk, utilize the Visual Compliance Screening System or contact exportcontrols@stanford.edu.

Additional information can be found below:

52.204-24 Representation Regarding Certain Telecommunications and Video Surveillance Services or Equipment

52.204-25 Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment

52.204-26 Covered Telecommunications Equipment or Services-Representation

NDAA Section 1634 - Prohibition on Contracting for Hardware, Software and Services by Kaspersky Lab and Other Covered Entities

NDAA Section 1634 prohibits the Federal Government from using any "Kaspersky Lab covered article." This includes hardware, software, and services developed or provided by Kaspersky Lab and Other Covered Entities. Stanford is prohibited from (1) providing any Kaspersky Lab covered article that the Government will use on or after October 1, 2018; and (2) Using any Kaspersky Lab covered article on or after October 1, 2018, in the development of data or deliverables first produced in the performance of the contract.

Additional information can be found below:

FAR Clause 52.204-23 Prohibition on Contracting for Hardware, Software, and Services Developed or Provided by Kaspersky Lab Covered Entities

OMB-M-23-13 - Prohibition on ByteDance Covered Applications (TikTok & Lark)

The federal government has restricted the use of ByteDance (TikTok & Lark) Social Networking Services in certain types of federal contracts and agreements. Per the applicable law and regulations, Stanford personnel who work on federal contracts or other agreements specifically identified by the government, including faculty, postdocs, employees, and graduate students, are prohibited from downloading or using TikTok or Lark on any information technology (including personal equipment) – laptops, cell phones, software, and firmware – used in the performance of a federal government contract or other agreements specifically identified by the government.

Federal contract and other agreements specifically identified by the government Principal Investigators are responsible for complying and ensuring those working on their project(s) are compliant, as described in the Informed Participation Acknowledgement and Certification that must be signed by each relevant federal contract Principal Investigator and each contract personnel. 

Additional information can be found below:

FAR Clause 52.204-27 Prohibition on a ByteDance Covered Application

Stanford TikTok FAQs