Finance & Procurement Activities

What is the risk?

NDAA Section 889 of the 2019 National Defense Authorization Act (NDAA) prohibits US federal government agencies, contractors, grant and loan recipients from procuring or using certain “covered” telecommunications equipment and services as described in the statute, which are sourced from any of approximately 60 companies associated with data penetration/infiltration concerns. Typically, sponsored research awardees are required to certify to the sponsor that none of the of equipment, software, or other inputs used in furtherance of the deliverable is sourced from these entities.

FIU’s Response:

In general, FIU conducts restricted party screening on all proposed vendors and subcontractors including, but not limited to the NDAA-restricted companies to ensure that to the best of FIU’s ability, it is avoiding financial and procurement-related transactions with restricted parties. Specifically, FIU’s standard procurement Terms and Conditions require vendors to comply with Section 889.

FIU’s restricted party screening protocol would also proactively identify persons or entities of concern who are proposed as business partners for purposes of a financial transaction on behalf of the University.