Reasonable Inquiry in Unreasonable Time – Determining Your Obligations Under Section 889(a)(1)(B)

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Event Overview

The clock is ticking . . .On August 13th, a new FAR Interim Rule will require all offerors to represent whether or not they "use any equipment, system or services that uses" Huawei Technologies Company, ZTE Corporation or other Chinese-made telecommunications equipment or services—after conducting a "reasonable inquiry." The Interim Rule implements Section 889 of the FY19 National Defense Authorization Act, which bans federal agencies from contracting with any "entity" that uses such technologies. The law was enacted two years ago with a compliance deadline of August 13, 2020.

The Interim Rule spreads across 15 pages of the Federal Register and provides government contractors little relief from the potentially sweeping reach of Section 889(a)(1)(B). Please join DHG's Bill Walter and Gary McDonald and their guests Alex Sarria and Jason Workmaster from Miller & Chevalier as they provide insight, questions and answers to topics including:

  • What is included in the 15-page Interim Rule?
  • What "entities" are required to comply?
  • What is a "reasonable inquiry?"
  • What constitutes a prohibited "use" of banned technologies?
  • Who will pay for the costs associated with conducting a "reasonable inquiry?"
  • What are the consequences of noncompliance?
About Miller & Chevalier

Founded in 1920, Miller & Chevalier is a Washington, DC law firm with a global perspective and leading practices in Tax, Litigation, International Law, Employee Benefits (including ERISA), White Collar Defense and Internal Investigations, and Government Affairs. Miller & Chevalier is a top-ranked firm sharply focused on targeted areas that interact with the federal government. Over the past three years, the firm's lawyers have represented more than 40 percent of the Fortune 100, one-quarter of the Fortune 500, and approximately 30 percent of the Global 100. Based in Washington, DC, a significant number of firm lawyers have held senior positions in the U.S. government and have written many of the regulations they currently help clients navigate. 

CPE Information

CPE Credit: One hour of CPE (pending approval)

Delivery Format: Group Internet Based (each attendee must be logged in and answer the poll questions in order to receive CPE credit).

Prerequisites/Advanced Preparation: None

Course Level: Basic

Participants: Individuals in the government contracting sector

Program Content: High level discussion on Section 889 of the FY19 National Defense Authorization Act


This event is complimentary. Due to this program being offered free of charge, there will be no refunds issued. If you have any questions regarding administrative policies such as registration or cancellation, please contact


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